BASE HEADER

No

ID sylw: 100712

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
Meeting the statutory 10% BNG requirement is challenging and causes delays and viability
concerns to many developments but is unavoidable as a national validation requirement. Draft
Policy Direction 38 indicates the Council’s will explore evidence to adopt a higher percentage to
achieve greater biodiversity benefits. The inclusion of a higher figure is not supported.
National planning guidance states that a higher figure must only be adopted on either an area wider
basis or for specific allocations if it is fully justified. As set out in Framework Paragraph 006
Reference ID: 74-006-20240214 fully justified means evidence of:
• local need for a higher percentage
• local opportunities for higher percentage
• impacts on viability for development
As yet the Council has failed to provide evidence to support a higher figure and on the basis of
knowledge of the industry it seems highly unlikely such justification could be provided. The policy
proposal must therefore be dropped.
If work towards a higher BNG figure is progressed then detailed consideration should be given as
to how any such policy could be implemented – particularly in respect of viability, without undue
pressure on applicants to undertake lengthy and complicated viability assessments