No

ID sylw: 108344

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

The preamble to Draft Policy Direction 38 correctly identifies that the Environment Act mandates that Local Planning Authorities may seek greater than 10% net gain for biodiversity, but only where there is justified local need.

Draft Policy Direction 38 then goes on to state that all development must achieve a minimum of 10% BNG.

However, it then goes on to state that “as work on the SWLP progresses we will explore evidence to seek a higher percentage of BNG above the statutory 10% requirement to achieve greater biodiversity benefits.”.

In this regard, Planning Practice Guidance (PPG) states:
"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." Paragraph: 006 Reference ID: 74-006-20240214

In the context of the above, ‘local need for a higher percentage’ is considered to refer to areas where biodiversity is demonstrably in decline, thus requiring a greater percentage gain as compensatory mitigation. Similarly, viability evidence at the local level needs to be provided.

At present, the SWLP does neither of the above and accordingly any requirement for biodiversity net gain in excess of 10% is not justified.

No

ID sylw: 108345

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

The supporting text to this policy confirms that the intention is that this policy look at all ecosystem services, beyond just biodiversity, including air quality, water quality, climate resilience and carbon sequestration, and will look to address these in tandem to ensure an overall net gain in ecosystem services.

Whilst this approach is commendable, it is difficult to foresee how such a policy will be formulated to deliver measurable outcomes. The evidence base for the SWLP must also include a thorough assessment of the viability of this policy to ensure that it does not unduly stifle
development.

Yes

ID sylw: 108346

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

Detailed comments provided in support of site Ref ID 116, addressing the following issues:

- Neighbourhood Plan Policy Context
- Landscape, Visual and Green Belt impact
- Highways and Access
- Illustrative Masterplan
- Deliverability

Site promotion document enclosed.