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ID sylw: 108199

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction –39- Environmental Net Gain? 2.105 The purpose of the planning system is to contribute to the achievement of sustainable development (Para 7, NPPF), and the NPPF is clear that sustainable development comprises three overarching objectives: economic, social and environmental (Para 8). It is also clear that opportunities should be taken to achieve net gains (Para 8). On the face of it, the delivery of Environmental Net Gain [ENG] would align with the NPPF and also be appropriate given that the SWAs have declared climate emergencies – it would also align with WDC’s ‘Climate Emergency Action Programme’ and SOADC’s ‘Council Plan 2019- 2023’. Therefore, in principle, St Philips broadly supports the SWA’s wider sustainable development aspirations and the principle of ENG. 2.106 St Philips understands that ENG comprises a series of holistic ‘net improvements’ to nature, such as water quality and air quality (etc.). In this regard, and notwithstanding St Philips’ broad support, the SWAs should again have regard to paragraph 16(f) of the NPPF (i.e. serve a clear purpose and avoid ‘unnecessary duplication). Crucially, Development Plans should be read as a whole. To this end, in its current form, St Philips considers that the draft policy would not ‘serve a clear purpose’, nor avoid ‘unnecessary duplication’ as the decision taker would need to have regard to the wider SWLP policies – such as (inter alia) draft Policy Directions 22, 24, 29, and 39 – when reading the SWLP as a whole. 2.107 Moreover, the NPPF is clear that policies should be aspirational, but deliverable (Para 16b), and be clearly written and unambiguous, so it is evident how a decision-maker should react to development proposals (Para 16d). Whilst it is recognised that the SWAs are at the early stages of plan-making, at present, St Philips is concerned that the SWAs may seek to make provision for a policy that is ‘aspirational’, but not ‘deliverable’ as – at present – the policy is ‘unclear’ as no ENG framework presently exists. Indeed, the SWAs recognise this in the PO (Pg.158), stating that one has not been formulated.