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ID sylw: 108375

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

14.1 In Draft Policy Direction-38 the PO document highlights that all developments (unless
exempt) must achieve a minimum of 10% BNG. In this regard, Mackenzie Miller Homes
supports the inclusion of compensatory measures, including biodiversity offsetting (i.e.
BNG). Indeed, Paragraph 33 of the NPPF is clear that Local Plans should demonstrate how
plans have addressed relevant economic, social and environmental objectives, which
includes opportunities for net gains. Furthermore, Paragraph 180(d) of the NPPF states
that planning policies should contribute to and enhance the local and natural environment
by:
“minimising impacts on and providing net gains for biodiversity, including by
establishing coherent ecological networks that are more resilient to current and future
pressures and incorporating features which support priority or threatened species such as
swifts, bats and hedgehogs;”
14.2 However, the PPG is clear that:
14.3 “Plan-makers should be aware of the statutory framework for biodiversity net gain, but
they do not need to include policies which duplicate the detailed provisions of this
statutory framework…” (PPG ID: 74-006) (Emphasis Added)
14.4 In this respect, it is recognised that the Councils are at the early stages of plan-making and
Mackenzie Miller Homes would like to advise that it is not necessary to include the BNG
policy to avoid duplicating policies within the statutory framework for BNG.