BASE HEADER

No

ID sylw: 107758

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to Draft Policy Direction 39 as evidence has yet to be published to justify the inclusion of an Environmental Net Gain (ENG) policy, or how this works in practice. To our knowledge, there are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG to demonstrate how this can be delivered. As with our comments to Policy Direction 38, we also consider that the inclusion of an ENG policy could impact viability and site yields. It is also unclear how ENG will align with BNG and whether this is an additional requirement which will be placed on developers. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).