BASE HEADER

No

ID sylw: 108318

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

CEG and Mixed Farms strongly encourage the SWLP to avoid seeking a higher percentage of BNG than the
statutory 10% requirement required by the Environment Act 2021.
Any higher percentage required is likely to have implications on the viability of delivering much needed homes
and jobs across South Warwickshire as where BNG cannot be met on site, this would lead to substantial costs to
purchase habitat units from off-site providers or statutory biodiversity credits from the Government.
There are serious concerns with any policies which seek to increase the level of BNG to be provided given the
likely impact this would have on the deliverability of the full extent of allocations, and/or the ability of residential
allocations to viably deliver the required level of affordable housing and key infrastructure.
Planning Practice Guidance (Paragraph 006 Reference ID: 74-006-20240214) confirms that:
“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either
on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will
need to be evidenced including as to local need for a higher percentage, local opportunities for a higher
percentage and any impacts on viability for development. Consideration will also need to be given to how the
policy will be implemented.”
Given the national microscope on the delivery of biodiversity net gain, there should be no requirement for any
additional local policy requirements over and above that set out statutorily and therefore CEG and Mixed Farms
recommend that the SWLP does not seek to require any greater than 10% BNG to be achieved.