No

Representation ID: 93326

Received: 02/03/2025

Respondent: Mr geoff marston

The councils’ intention to ‘explore opportunities’ for higher than 10% Biodiversity Net Gain (the absolute bare minimum) is somewhat pathetic. Explore is a cop out word for do nothing.

Local planning evidence derived through planning applications shows that more than 10% BNG is achievable in Warwickshire (Warks wildlife Trust), and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.

Yes

Representation ID: 93390

Received: 02/03/2025

Respondent: Mr David Haggarty

N/A

Yes

Representation ID: 93477

Received: 02/03/2025

Respondent: Mrs Vivien Haggarty

N/A

Yes

Representation ID: 93554

Received: 02/03/2025

Respondent: Wellesbourne and Walton Parish Council

We agree with all these policy directions but they tend to be the last things that developers do and are either not done well or not at all so implementation needs to be monitored and the planning authority must ensure compliance. Planning approval should include penalties if developers do not do what they say they are going to do.

No

Representation ID: 93600

Received: 02/03/2025

Respondent: Mr JAMES STEWART

I do not agree with this policy because purchasing biodiversity units as a form of “offsetting” does nothing to improve real biodiversity. Protecting and enhancing existing ecosystems is far more effective than relying on theoretical compensation. Research shows that developers often fail to implement the ecological enhancements they promise, making “net gain” an empty commitment in over 50% of cases. This is a systemic issue and a regulatory failure. Instead of allowing biodiversity loss on paper, we must safeguard and support areas of high ecological value already in existence. Source: Wild Justice Report

No

Representation ID: 93677

Received: 02/03/2025

Respondent: Mrs Claire STEWART

I disagree with this policy because purchasing biodiversity units as “offsetting” fails to deliver real environmental benefits. Protecting and enhancing existing ecosystems is far more effective than relying on theoretical compensation. Research shows that developers frequently neglect their promised ecological improvements, with “net gain” often remaining unfulfilled in over 50% of cases. This represents a systemic failure in regulation and enforcement. Rather than allowing biodiversity loss to be justified on paper, we must prioritize safeguarding and strengthening areas of high ecological value that already exist. Source: Wild Justice Report

Yes

Representation ID: 93719

Received: 02/03/2025

Respondent: Cllr David Armstrong

Yes, particularly in looking to a higher level of BNG than the 10% minimum. Also it is key to ensure biodiversity unit assessment takes into account changes at a site before the application, to avoid developers removing trees/habitats before submitting plans in order to reduce the BNG they have to meet. This practice is possibly in evidence already at a site near Kenilworth (ref [redacted] - significant reduction in hedgerow height). Remote sensing timeseries data provides an archive of sites going back several years and could provide evidence.

Yes

Representation ID: 93834

Received: 02/03/2025

Respondent: Warwick District Green Party

Yes. In looking at whether BNG in excess of 10% is desirable the plan should draw on the experience of other local authorities where a higher rate has been approved. Measuring BNG is a process involving both evidence and judgement, and the authorities need to be confident that they have the resources and expertise to review and interrogate BNG plans put forward by developers. There is otherwise a danger that this becomes another box-ticking exercise rather than a genuine commitment to enhance biodiversity. SDC and WDC should start now to develop a scheme of offsite biodiversity units within their areas.

Other

Representation ID: 93842

Received: 02/03/2025

Respondent: Dr Penny Gray

It concerns me that this direction encourages monetising the natural environment. Alternative provision through purchasing 'offsite biodiversity units' sounds like numerous carbon offsetting schemes that have proven to be scams. Biodiversity gains should be demonstrable on site, not off site.

No

Representation ID: 93922

Received: 02/03/2025

Respondent: Mrs Beverley Comley

Biodiversity should be at the site not offloaded elsewhere

Yes

Representation ID: 93989

Received: 02/03/2025

Respondent: Mrs Sue Scurrah

-

No

Representation ID: 94129

Received: 02/03/2025

Respondent: Mr David Kelly

Purchasing of ‘biodiversity units’ as a way of ‘off-setting’ will never improve
biodiversity. Supporting the existing biodiversity, safeguarding and supporting areas of higher biodiversity already in existence is crucial. Research shows that developers aren’t implementing the ecological and biodiversity enhancements they originally claim to. This is a huge systemic issue and regulatory failure. In over 50% of cases the ‘net-gain’ exists only in on paper not in practice. Article reference: https://wildjustice.org.uk/general/lost-nature-report/

Other

Representation ID: 94142

Received: 02/03/2025

Respondent: Mrs Samantha Stafford Scott

“Offsetting” is not an option and shouldn’t be considered as a means of improving biodiversity. It is counterintuitive to not simply protect and safeguard the existing biodiversity. Developers have no interest in providing this and I am yet to see any evidence that they are implementing the regulations. As such, Development should not be permitted on sites that put current biodiversity at risk!

Other

Representation ID: 94156

Received: 02/03/2025

Respondent: Ms Holly Whittaker

The purchasing of 'biodiversity units' as a way of 'off-setting' will never improve biodiversity.

Supporting the existing biodiversity, safeguarding and supporting areas of higher biodiversity already in existence, is crucial. Research shows that developers are not implementing the ecological and biodiversity enhancements they originally claim to. This is a huge systematic issue and regulatory failure. In over 50% of cases the 'net gain' exists only on paper and not in practice. Article reference: https://wildjustice.org.uk/general/lost-nature-report/

No

Representation ID: 94379

Received: 03/03/2025

Respondent: Mr Alan Blandamer

Warwickshire Wildlife Trust is not satisfied with the councils' intention to 'explore opportunities for higher than the bare minimum of 10% Biodiversity Net Gain.
Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire.
Purchasing of 'biodiversity units' as a way of 'off-setting' will never improve biodiversity. Supporting the existing biodiversity is crucial. Research shows that developers aren't implementing the ecological and biodiversity enhancements they originally claim to. Article reference: https://wildjustice.org.uk/general/lost-nature-report/

No

Representation ID: 94658

Received: 03/03/2025

Respondent: Miss Renny Wodynska

No. The councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain is pathetic and neither here nor there.

Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.

Other

Representation ID: 94950

Received: 03/03/2025

Respondent: Mr Jonathan Ainsworth

'Off setting' will eved improve biodiversity. I work as an estate agent and new developments never stick to their claims when developing sites and creating biodiversity.

Other

Representation ID: 95065

Received: 03/03/2025

Respondent: Mrs Tracey Grimes

Developers are notorious for spending the bare minimum or not fulfilling what they said they would do. Enhancing an existing biodiversity ecosystem would be far superior than offsetting new ideas.

No

Representation ID: 95245

Received: 04/03/2025

Respondent: Kineton Parish Council

as drafted it is hard to agree the approach. The policy appears to give a developer the chance to over develop a site, prove that on-site mitigation is not achievable, and turn to an apparently un-monitored trading arrangement to “buy credits”. Furthermore those credits can be for theoretical locations nowhere near the site where the damage is being created. Local biodiversity is therefore irreparably damaged and unproven gain is claimed for unknown locations

No

Representation ID: 95267

Received: 04/03/2025

Respondent: Mrs Emma Restall Orr

It is unclear how this will deliver wider connecting corridors which are more substantial than the proposed small scale on-site improvements. The councils should update their Green/Blue Infrastructure evidence base, in line with the NPPF and in time to influence chosen housing sites in the Local Plan. The approach here shows a lack of understanding and a lack of commitment to fundamental ecological requirements.

No

Representation ID: 95311

Received: 04/03/2025

Respondent: Alamo

Agent: Harris Lamb

No justification for a higher than 10% requirement. If this is to be pursued it should be viability tested.

Other

Representation ID: 95337

Received: 04/03/2025

Respondent: Mr Lee Tallen

Agree generally, but we have seen through things such as 'offsetting schemes' through air travel that off setting never makes up for the damage done. Feel the purchase of biodiversity credits would represent a 'cop out' and not have any impact of positive biodiversity gains.

No

Representation ID: 95339

Received: 04/03/2025

Respondent: Kristina Tristram

No. Not satisfied with the councils' intention to 'explore opportunities' for higher than the bare minimum of 10% Biodiversity Net Gain. Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.

No

Representation ID: 95470

Received: 04/03/2025

Respondent: Ms Sue Cuff

Warwickshire Wildlife Trust is not satisfied with the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain.

Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.

No

Representation ID: 95526

Received: 04/03/2025

Respondent: Mr Martin Freeman

I am not satised with the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain.
Local evidence through planning applications shows that more than 10% BNG is achievable in
Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater
target should be delivered. A number of other Councils such as Cornwall Council have already
got plans through Examination with 20% net gain.

No

Representation ID: 95710

Received: 04/03/2025

Respondent: David Wilson Homes

Agent: Harris Lamb

seeking BNG of more than 10% will have viability issues. It shouldn't be sought if the councils want to ensure an efficient use of land.

Yes

Representation ID: 95776

Received: 04/03/2025

Respondent: Bloor Homes Western

Agent: Marrons

This policy reflects the national requirements for a minimum of 10% with regards to Biodiversity Net Gain.

Other

Representation ID: 95965

Received: 04/03/2025

Respondent: Mr Paul Tesh

Yes. How will the commitment to 30 years be secured from developers? What sanctions will there be if a developer goes bankrupt during the 30 year period or reneges on his commitments (local authorities often have difficulty in getting developers to fulfil their obligations under current S106 and S278 agreements)?

No

Representation ID: 96085

Received: 04/03/2025

Respondent: Ms Tamsin Kashap

No. Warwickshire Wildlife Trust is not satisfied with the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain.

Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.

No

Representation ID: 96126

Received: 04/03/2025

Respondent: Mrs Rosemary Collier

I am not satisfied with the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain.

Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.