Yes

Representation ID: 96274

Received: 05/03/2025

Respondent: John Dinnie

It would also help if, where land is set aside for biodiversity net gain, suitable public access to that land could also be achieved.

Yes

Representation ID: 96361

Received: 05/03/2025

Respondent: Southam Town Council

Southam Town, District and County elected representatives support this Policy Direction.

Other

Representation ID: 96438

Received: 05/03/2025

Respondent: Mrs Sara Sweeney

Flooding in Henley in Arden and surrounding villages and roads is an increasing regular occurance impacting homes, businesses, roads, public transport.
Flooding causes health concerns with drainage systems unable to cope with current drainage requirements. How will additional building protect local wildlife from flooding, pollution caused by additional vehicles and what improvements will be made to public transport to protect our wildlife?

No

Representation ID: 96478

Received: 05/03/2025

Respondent: Mr Adam Ledger

Net gain is impossible with plans provided. Existing aged habitats cannot be replaced with new and expect neg gain. Flawed logic in the plans.

Yes

Representation ID: 96512

Received: 05/03/2025

Respondent: Shipston Town Council

It's unclear 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: 96625

Received: 05/03/2025

Respondent: Mr Peter Nixon

The target of 10% biodiversity gain is not enough.

Other

Representation ID: 96685

Received: 05/03/2025

Respondent: Janet Gee

Last resort option above is a cop-out, and mean that you cannot deliver this objective.

As above, my concern is that a lack of open. undisturbed space will make this achievement very difficult.

Other

Representation ID: 96875

Received: 05/03/2025

Respondent: Mrs Margaret Jeffery

I cannot see how building 6700 houses would result in BNG. The settlement would result in the removal of 329ha of agricultural land as well as hedges and trees all of which provide a habitat in the Green Belt for a considerable variety of animals and plants

Yes

Representation ID: 97076

Received: 05/03/2025

Respondent: Alcester Town Council

This approach is agreed by Alcester Town Council, Arrow with Weethley Parish Council, Kinwarton Parish Council, Wixford Parish Council and Great Alne Parish Council (together referred to as Alcester Parishes Group or ‘APG’).

Yes

Representation ID: 97100

Received: 05/03/2025

Respondent: John Dinnie

yes

No

Representation ID: 97178

Received: 05/03/2025

Respondent: Sir Thomas White’s Charity and The King Henry VIII Endowed Trust, Warwick

Agent: Stansgate Planning

Meeting the statutory 10% BNG requirement is challenging and causes delays and viability concerns to many developments but is unavoidable as a national validation requirement. Draft Policy Direction 38 indicates the Council’s will explore evidence to adopt a higher percentage to achieve greater biodiversity benefits. The inclusion of a higher figure is not supported.
National planning guidance states that a higher figure must only be adopted on either an area wider basis or for specific allocations if it is fully justified. As set out in Framework Paragraph 006 Reference ID: 74-006-20240214 fully justified means evidence of:
• local need for a higher percentage
• local opportunities for higher percentage
• impacts on viability for development
As yet the Council has failed to provide evidence to support a higher figure and on the basis of knowledge of the industry it seems highly unlikely such justification could be provided. The policy proposal must therefore be dropped.
If work towards a higher BNG figure is progressed then detailed consideration should be given as to how any such policy could be implemented – particularly in respect of viability, without undue pressure on applicants to undertake lengthy and complicated viability assessments.

Yes

Representation ID: 97209

Received: 26/02/2025

Respondent: Tysoe Parish Council

Yes

Yes

Representation ID: 97279

Received: 05/03/2025

Respondent: Squab Hall Farm

Agent: Mr Jack Barnes

This policy reflects the national requirements with regards to Biodiversity Net Gain.

Other

Representation ID: 97408

Received: 05/03/2025

Respondent: Godwin Developments

We acknowledge that all development proposals must achieve a minimum of 10% biodiversity net gain (BNG) based on the DEFRA Statutory Biodiversity Metric. However, we do not support exceeding this requirement as it may affect viability. It is crucial to balance biodiversity benefits with meeting Objectively Assessed Need (OAN) targets. Regarding the Land at Aylesbury Road, while the site mainly features habitats of low ecological importance, the development concept aims to retain valuable features and create opportunities for net gain, including native tree planting and improved habitats for bats and birds.

Other

Representation ID: 97452

Received: 05/03/2025

Respondent: Mr David Turner

You seem to be paying lip service to promoting biodiversity but what safeguards will be in place to ensure these fine ideals will be carried out? You even have a get out of jail card in the form of buying statutory biodiversity credits from the government (a fudge if ever I heard of one)

Yes

Representation ID: 97635

Received: 05/03/2025

Respondent: Mr Martin Winter

N/a

Yes

Representation ID: 97739

Received: 05/03/2025

Respondent: Mr Gary Jeffery

It's a good idea but 6,700 new homes plus offices and industrial buildings in B7 would not result in BNG given that the settlement would result in the desecration of329 ha of agricultural land including hedges and trees all of which comprise an important habitat in the green belt for a wide variety of fauna and flora

No

Representation ID: 97890

Received: 05/03/2025

Respondent: Mr Jonathan Stafford-scott

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. Developers are only interested in profit and capital so in the net gain can never really be quantified especially during any meaningful timescale which can be held to account. This is green washing to the max.

Other

Representation ID: 97893

Received: 05/03/2025

Respondent: Mr Jonathan Stafford-scott

carbon sequestration is not the answer to increased carbon emissions. Improving
public transport links with new stations to reach more local areas and actually reducing emissions is needed.

No

Representation ID: 97907

Received: 05/03/2025

Respondent: E Innes

I have no issue with a net biodiversity gain target but allowing this to be achieved outside of the planning authority area, or neighbouring area, does not present a gain. Targeting a numeric gain also ignores the unique mix of habitat that currently exists and is inevitably destroyed, replaced by something unsuitable for the area and needs of wildlife. More effort should be made to retain existing features and habitat such as tree lines and hedge rows which could be easily retained within plans and hold higher value than is attriubted by a biodiversity gain calculator.

Other

Representation ID: 97929

Received: 05/03/2025

Respondent: Brenda Stewart

i worry that bio-diversity net gain is often poorly implemented and does not result in real gains for biodiversity. The original biodiversity of a site is often much more complex than is realised. Some types of wildlife do not have the option to move to the new areas of newly planted saplings. The whole exercise of calculating BNG is suspect.

Yes

Representation ID: 98131

Received: 06/03/2025

Respondent: William Davis Limited

Agent: Marrons

This policy reflects the national requirements with regards to Biodiversity Net Gain.

Other

Representation ID: 98361

Received: 06/03/2025

Respondent: Catesby Estates

Agent: Mr Will Whitelock

The draft policy direction states that a higher percentage of BNG above the statutory 10% requirement is being explored. Such an approach may unnecessarily burden development sites as the provision of net gains in biodiversity can impact on the viability of proposals and the capacity of sites. It is hence requested that the South Warwickshire authorities explore evidence on how a higher BNG would affect the capacity of sites when balancing other technical and environmental considerations and planning obligations.

Yes

Representation ID: 98397

Received: 06/03/2025

Respondent: Mr Andrew Newbould

na

No

Representation ID: 98505

Received: 06/03/2025

Respondent: Mrs Lucy Flynn

Agent: Stansgate Planning

Meeting the statutory 10% BNG requirement is challenging and causes delays and viability concerns to many developments but is unavoidable as a national validation requirement. Draft Policy Direction 38 indicates the Council’s will explore evidence to adopt a higher percentage to achieve greater biodiversity benefits. The inclusion of a higher figure is not supported.
National planning guidance states that a higher figure must only be adopted on either an area wider
basis or for specific allocations if it is fully justified. As set out in Framework Paragraph 006 Reference ID: 74-006-20240214 fully justified means evidence of:
• local need for a higher percentage
• local opportunities for higher percentage
• impacts on viability for development
As yet the Council has failed to provide evidence to support a higher figure and on the basis of knowledge of the industry it seems highly unlikely such justification could be provided. The policy proposal must therefore be dropped.

Other

Representation ID: 98527

Received: 06/03/2025

Respondent: Mr Kim James

Support for the 10% Biodiversity Net Gain (BNG) requirement and exploring a higher target to enhance local biodiversity. A 30-year habitat management commitment is essential for long-term ecological benefits. While on-site BNG should be prioritized, we recognize challenges for smaller developments.
Off-site biodiversity units should be secured locally first, avoiding reliance on statutory biodiversity credits, which risk biodiversity loss within our parish. #
We advocate for community-led conservation, habitat restoration, and rewilding projects to strengthen local ecosystems. Policies should be practical, enforceable, and tailored to rural needs to ensure effective long-term environmental stewardship.

Other

Representation ID: 98580

Received: 06/03/2025

Respondent: Salford Priors Parish Council

Support for the 10% Biodiversity Net Gain (BNG) requirement and exploring a higher target to enhance local biodiversity. A 30-year habitat management commitment is essential for long-term ecological benefits. While on-site BNG should be prioritised, we recognise challenges for smaller developments. Off-site biodiversity units should be secured locally first, avoiding reliance on statutory biodiversity credits, which risk biodiversity loss within our parish. # We advocate for community-led conservation, habitat restoration, and rewilding projects to strengthen local ecosystems. Policies should be practical, enforceable, and tailored to rural needs to ensure effective long-term environmental stewardship.

Yes

Representation ID: 98632

Received: 06/03/2025

Respondent: X2 New Settlement Consortium

Agent: Mr Jack Barnes

This policy reflects the national requirements with regards to Biodiversity Net Gain.

No

Representation ID: 98641

Received: 06/03/2025

Respondent: Mrs Alice Hibbert

A greater target should be delivered - a number of other Councils have already got plans with 20% net gain.

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/

No

Representation ID: 98645

Received: 06/03/2025

Respondent: Mrs Alice Hibbert

carbon sequestration is not the answer to increased carbon emissions. Improving public transport links with new stations to reach more local areas and actually reducing emissions is needed.