BASE HEADER

No

ID sylw: 106438

Derbyniwyd: 05/03/2025

Ymatebydd: Porterbrook Mid Leasing Company

Asiant : Planning Prospects

The draft policy direction sets out that Environmental Net Gain (ENG) is an approach to development that leaves the environment in a measurably better state than prior to development. It looks holistically across all ecosystem services, beyond just biodiversity, including air quality, water quality, climate resilience, etc. And addresses these in tandem to ensure an overall net gain in ecosystem services. It sets out that the broader scope, compared to Biodiversity Net Gain (BNG) alone, provides additional benefits for both the environment and people. The policy will require development proposals to contribute positively to the natural environment by enhancing biodiversity and ecosystem services. The direction says that further work is required to develop a comprehensive ENG framework, but an initial focus on BNG and carbon sequestration will provide a solid foundation. Additionally, Porterbrook’s response to draft policy 38 (BNG) highlights that the current requirement for a minimum of 10% BNG is already a significant barrier for some development proposals to achieve, and in some cases makes development unfeasible and unviable. With this in mind it would not be justified or effective for the swlp to require a further policy requirement in the form of an ENG percentage. In conclusion, whilst further work is noted before a comprehensive ENG framework can be confirmed and developed, the draft policy direction, in seeking to deliver measurable improvements in biodiversity and ecosystem services (including carbon sequestration) is duplicating other policy requirements around BNG, air quality, water quality, climate resilience etc. And in doing so is adding another, and unnecessary, policy layer (or burden) which duplicates requirements that are already covered by other national and (draft) local policy, and legislation. As such it is not justified or effective