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Representations on VALP Proposed Submission - NE2 Biodiversity and geodiversity
OBJECT Natural England (Ms Kirsty Macpherson)
There is no requirement for the
monitoring and evaluation of
biodiversity or GI works. Installing
the required plants and physical
works is only the first stage. How
will you know if implementation was
successful? How will you know if the
GI is providing the ecosystem
services it was designed for? How
will you know if the habitat created
is providing habitat for the desired
SUPPORT Wendover Neighbourhood Plan Steering Group (Mr Jonathan Clover)
The SG generally welcomes the above Policies and looks to develop its own local
policies to enhance and protect the green environment appropriately.
OBJECT Malvern Homes Limited represented by RCA Regeneration Ltd (Mr Gareth Sibley)
We consider that parts a and b of policy NE2 are currently unenforceable without the supplementary
SPD which sets out the biometrics calculator. Within the draft Local Plan, there is currently no agreed
method to calculate the net gain in biodiversity and without it the Council are expecting the applicant
to second guess the calculation. This creates uncertainty and confusion between the Councils ecologist
and the applicant's ecologist over how this should be calculated.
OBJECT The Environment Agency (Michelle Kidd)
Point i in policy NE2 states:
"i. Planning conditions/obligations will be used to secure no net loss and net gains in
biodiversity where possible by helping deliver Bucks and MK Biodiversity Action Plan
targets in the biodiversity opportunity areas. On greenfield sites, the Council is seekingto achieve a net gain in biodiversity."
As with point 'a' his wording doesn't appear to the consistent with the supporting text.
OBJECT The Environment Agency (Michelle Kidd)
Policy NE2 (a) We would like to understand why greenfield sites and 'other sites' are being treated differently as this does not reflect the supporting text in paragraph 9.17 as we understand it. The value of greenfield sites and 'other sites' vary and should be given the same protection. Some brownfield sites are highly valuable for protected species due to the habitats found. This policy wording needs to be much clearer to ensure that it is interpreted as intended.
OBJECT Persimmon Homes North London represented by Woolf Bond Planning (Mr Steven Brown)
Whilst we support and encourage policies that seek to protect and enhance
biodiversity, geodiversity and the natural environment, we object to the specifics
of Policy NE2 in so far as part (a) requires a net gain in biodiversity for all
8.2. Whilst we have no particular objection for that to be set out as a policy aspiration,
we are concerned that the policy could be used to ensure a net increase in
biodiversity on every site for housing. In our view, such an approach is too
restrictive and could serve to prevent otherwise sustainable development from
OBJECT Wates Developments Ltd. represented by Boyer Planning Ltd (Jonathan Liberman)
Wates object to the requirement for a 'net gain in biodiversity' on greenfield sites as set out in criteria (a). It is not consistent with the NPPF para 109. Also suggest amendments to NE2 (b).
OBJECT Richborough Estates represented by RPS Planning & Development (Mr Cameron Austin-Fell)
The policy (criterion b) should also allow for off-site mitigation as a way of mitigating the harmful effects of a development. Several authorities (Warwickshire County) are now using landbanks as a way of ensuring a development has a net gain in biodiversity, by enabling financial contributions towards off-site mitigation.
Criterion D appears to replicate policy NE1 and should be deleted.
OBJECT Gladman Developments Ltd (Ms Nicole Penfold)
No mention of mitigation or instances when this may result in schemes being considered acceptable.
OBJECT Catesby Estates Limited represented by Barton Willmore (Alastair Bird)
does not accord with Paragraph 109 of the NPPF, which sets out that the
planning system should contribute to enhance the natural and local environment by minimising impacts
on biodiversity and providing net gains in biodiversity 'where possible'.
SUPPORT Berkshire, Buckinghamshire & Oxfordshire Wildlife Trust (Mr Neil Rowntree)
We support these policies which are necessary in order to comply with NPPF requirements regarding biodiversity and the natural environment, and the NERC Act (2006) duty with regard to biodiversity.
Note that we are aware that the Natural Environment Partnership (the NEP, which is the equivalent of a Local Nature Partnership in Buckinghamshire) is asking for a modification with respect to the supporting text of Policy I1 Green Infrastructure. We support that modification which in the interests of brevity we do not repeat here - please refer to the NEP response.
OBJECT Chiltern Area of Outstanding Natural Beauty Conservation Board (Dr Lucy Murfett)
The Chilterns Conservation Board supports the policy approach of biodiversity net gain and use of metrics.
However the policy should not extend to the principle of mitigation for harm to the Chilterns Beechwoods SAC or SSSIs, which are irreplaceable, as are ancient woodlands and veteran trees (as stated in para 9.2 of the Local Plan).
OBJECT Define (on behalf of Bovis Homes) (Mr Mark Rose) represented by Define (on behalf of Bovis Homes) (Mr Mark Rose)
Bovis Homes object to Policy NE1, which is considered unsound on the basis that it is inconsistent with national policy.
SUPPORT Royal Society For Protection Of Birds (RSPB) (Mr Colin Wilkinson)
The RSPB welcomes and strongly supports Policy NE2 as an appropriately rigorous, detailed and sensible response to halting the further loss of biodiversity from the District due to development. In future, the Council's ability to deliver this policy effectively will depend significantly on retaining in-house ecological expertise, and a properly resourced biological/LWS recording and designation system in Aylesbury Vale, and on a well thought out and properly justified system of biodiversity accounting.