No

Representation ID: 101727

Received: 07/03/2025

Respondent: Mr Vincent Rollason

This development is not good for the area

Yes

Representation ID: 101908

Received: 07/03/2025

Respondent: Bishop's Tachbrook Parish Council

We strongly support exceeding the 10% Biodiversity Net Gain requirement to maximise ecological benefits. Biodiversity enhancements must be delivered near the original site to support local resilience and community well-being. The Anchitel Green development in Bishop’s Tachbrook highlights the risks of offsite mitigation, where biodiversity loss in the Parish was offset by gains in Stratford, creating an uneven distribution. In line with NPPF principles, biodiversity net gain should be secured where it is most needed—within or near the affected community—to maintain ecological balance and prevent biodiversity deserts.

Other

Representation ID: 102003

Received: 07/03/2025

Respondent: Mr Simon Walkden

In principle this would seem OK but the reality it relies on these to be followed through and history shows that this is often not the case. Lets retain and support existing biodiversity first.

No

Representation ID: 102005

Received: 07/03/2025

Respondent: Dr Dave Steele

It is not clear if this allocation will be used to replace the important Green Belt, green infrastructure corridors and Wildbelt designations which should already be included in the Plan and given substantial weight. Green Belts shouldn’t include housing allocations.

Other

Representation ID: 102010

Received: 07/03/2025

Respondent: Heart of England Forest

The Heart of England Forest acknowledges the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain. However, rather than the statement to ‘explore opportunities’ there should be a clear statement of commitment with the intention to include a higher percentage than the minimum, to ensure that the loss of nature is adequately addressed, and this trend is reversed.

Other

Representation ID: 102049

Received: 07/03/2025

Respondent: Barwood Land

Agent: Savills (UK) Ltd

We understand why the Council would look to include a policy approach which duplicates the requirement of the Environment Act to provide a 10% Biodiversity Net Gain (BNG) on site. We do however question whether there is any merit in doing so since the requirement is covered by separate legislation and therefore has a higher status than a development plan policy in any event.
Notwithstanding, there is potential for the details of national BNG policy to change and, over time, for the legislation and local plan policy to diverge. On balance therefore we recommend removing the policy and leaving the requirements to deliver BNG to separate legislation.

Yes

Representation ID: 102096

Received: 07/03/2025

Respondent: Miss Anne Page

Hard to believe there would be a biodiversity net gain when high density housing replaces old trees hedgerows.

No

Representation ID: 102205

Received: 07/03/2025

Respondent: Hallam Land

Agent: LRM Planning

We would caution against imposing a higher percentage of BNG above the statutory minimum requirement in order to achieve greater biodiversity benefits. Whilst higher percentages may be achieved in the context of individual development proposals, to mandate a higher percentage as a development plan policy could prejudice the achievement of other equally legitimate development objectives.

Other

Representation ID: 102219

Received: 07/03/2025

Respondent: IM Land 1 Limited

Agent: Turley

79. Consideration should be given to increasing the requirement for BNG above statutory 10% and any implications this may likely have for development delivery and viability.

Yes

Representation ID: 102379

Received: 07/03/2025

Respondent: Richborough

Agent: Marrons

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

Other

Representation ID: 102410

Received: 07/03/2025

Respondent: Mr Philip Alton

Residents have no confidence that the Council does this in practice.

Other

Representation ID: 102415

Received: 07/03/2025

Respondent: Taylor Wimpey Strategic Land

Agent: Turley

Careful consideration should be given to increasing the requirement for BNG above 10% and the implication this will likely have for delivery and viability.

Draft Policy Direction 38 should also recognise that landowners and developers may have access to additional land within the LPA or elsewhere, where they can provide for any additional offsite mitigation required. Offsite mitigation should not be limited to those sites identified through the LNRS.

No

Representation ID: 102459

Received: 07/03/2025

Respondent: BDW Trading Limited

Agent: Knight Frank LLP

The policy should alignment with national legislation and robust evidence is necessary to justify any increase above 10%.

No

Representation ID: 102483

Received: 07/03/2025

Respondent: Mrs Karen Rollason

10% BNG is inadequate and should be at least 20%.

No

Representation ID: 102627

Received: 07/03/2025

Respondent: Carl Barthorpe

This is all just twaddle, we have natures biodiversity, to think humans can improve on this by urban sprawl is nieve.

Stop using natural language to green wash development the local community do not want.

If you are so confident of your plan put it to a referendum

Other

Representation ID: 102676

Received: 07/03/2025

Respondent: Hatton Parish Council

The NSs and SGLs, all on greenfield sites will result in loss of habitat and biodiversity and it is difficult to see how this can be offset within the district unless large areas of land are set aside with low-intensity agriculture and rewilding.
Site B1 Land at Hatton would be a suitable such area.

No

Representation ID: 102799

Received: 07/03/2025

Respondent: The Ragley Estate

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

Other

Representation ID: 102858

Received: 07/03/2025

Respondent: Turley

Clarification requested as to when and where it is proposed to apply a greater than 10% net gain requirement and what evidence will be used to support this.
University wish to discuss how the hierarchy in the adopted University SPD will be translated into this policy.

Other

Representation ID: 102872

Received: 07/03/2025

Respondent: Miss Phoebe Withnall

Draft Policy Direction 38 is a positive step. However, the reliance on off-site biodiversity units could undermine the policy’s effectiveness.

Yes

Representation ID: 103001

Received: 07/03/2025

Respondent: Mr David Bailey

I agree.

Yes

Representation ID: 103118

Received: 07/03/2025

Respondent: Bloor Homes

Agent: Marrons

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

No

Representation ID: 103127

Received: 07/03/2025

Respondent: Mr Jem Brown

This policy has an opportunity to make a substantive commitment to nature by setting the bar higher for BNG. The councils could make a real statement of intent by setting the minimum level of BNG at a high level that 10%. As reported on the website LocalGov.co.uk (https://www.localgov.co.uk/Biodiversity-Net-Gain-failing-to-deliver/61899) BNG is not delivering the expected increase in wildlife habitats. Wouldn't it be great if South Warwickshire took a lead in specifying 20% or 25% BNG and use this as a means towards the councils commitment to 30 by 30.

Other

Representation ID: 103675

Received: 07/03/2025

Respondent: Richborough - Salford Road, Bidford-on-Avon

Agent: Turley

Richborough broadly support the approach laid out in Draft Policy Direction 38 in that it aligns with current national policy/legislation.

There is some concern regarding the reference to “or any higher percentage mandated through local or national policy/legislation” and it is considered that any proposal to increase the level of BNG beyond national policy should be tested as it may impact delivery and viability.

Other

Representation ID: 103676

Received: 07/03/2025

Respondent: Richborough - Gaydon Road, Bishop's Itchington

Agent: Turley

Richborough broadly support the approach laid out in Draft Policy Direction 38 in that it aligns with current national policy/legislation.

There is some concern regarding the reference to “or any higher percentage mandated through local or national policy/legislation” and it is considered that any proposal to increase the level of BNG beyond national policy should be tested as it may impact delivery and viability.

Other

Representation ID: 103677

Received: 07/03/2025

Respondent: Richborough - Lighthorne Road, Kineton

Agent: Turley

Richborough broadly support the approach laid out in Draft Policy Direction 38 in that it aligns with current national policy/legislation.

There is some concern regarding the reference to “or any higher percentage mandated through local or national policy/legislation” and it is considered that any proposal to increase the level of BNG beyond national policy should be tested as it may impact delivery and viability.

Other

Representation ID: 103681

Received: 07/03/2025

Respondent: Richborough - Sycamore Close, Stockton

Agent: Turley

Richborough broadly support the approach laid out in Draft Policy Direction 38 in that it aligns with current national policy/legislation.

There is some concern regarding the reference to “or any higher percentage mandated through local or national policy/legislation” and it is considered that any proposal to increase the level of BNG beyond national policy should be tested as it may impact delivery and viability.

Other

Representation ID: 103683

Received: 07/03/2025

Respondent: Richborough - Kineton Road, Wellesbourne

Agent: Turley

Richborough broadly support the approach laid out in Draft Policy Direction 38 in that it aligns with current national policy/legislation.

There is some concern regarding the reference to “or any higher percentage mandated through local or national policy/legislation” and it is considered that any proposal to increase the level of BNG beyond national policy should be tested as it may impact delivery and viability.

Other

Representation ID: 103685

Received: 07/03/2025

Respondent: Richborough - Wellesbourne Road, Wellesbourne

Agent: Turley

Richborough broadly support the approach laid out in Draft Policy Direction 38 in that it aligns with current national policy/legislation.

There is some concern regarding the reference to “or any higher percentage mandated through local or national policy/legislation” and it is considered that any proposal to increase the level of BNG beyond national policy should be tested as it may impact delivery and viability.

Other

Representation ID: 103688

Received: 07/03/2025

Respondent: Richborough - Plough Lane, Bishop's Itchington

Agent: Turley

Richborough broadly support the approach laid out in Draft Policy Direction 38 in that it aligns with current national policy/legislation.

There is some concern regarding the reference to “or any higher percentage mandated through local or national policy/legislation” and it is considered that any proposal to increase the level of BNG beyond national policy should be tested as it may impact delivery and viability.

Other

Representation ID: 103842

Received: 07/03/2025

Respondent: Claire Jones

Numbers 3, 4 and the last resort should not be options. It needs to be here in the locality. Otherwise south warwickshiee is just going to become hideous urban sprawl - look what you have allowed to happen around gallows hill!