Other

Representation ID: 100560

Received: 07/03/2025

Respondent: Mrs Vanessa Chivers

Whilst I understand and fully support this policy in line with the 2024 law, any development on Hareway Lane X1 etc, would wipe out biodiversity almost 100%. It would be impossible to acheive a 10% net gain.

Yes

Representation ID: 100624

Received: 07/03/2025

Respondent: Mrs Janine McComiskey

sounds like a great idea. I hope it can be put into practice.

No

Representation ID: 100714

Received: 07/03/2025

Respondent: Drayton Manor Farms Ltd

Agent: Stansgate Planning

No.
Whilst paragraph 187 of the Framework requires planning policies and decisions to contribute to
and enhance the natural and local environment there is currently no requirement, or indeed
reference, to Environmental Net Gain at a national level.
The Draft Policy Direction provides no justification for the inclusion of an ENG policy, nor any
information about how such a policy would function in practice. There are no other examples of
adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG. It is
likely to harm viability, duplicate BNG requirements, cause longer lead-in times and the uncertainty
could delay the deliverability of sites. As such this policy direction should be removed from the
emerging Plan

No

Representation ID: 100748

Received: 07/03/2025

Respondent: Gladman Developments

Gladman believe it is inappropriate and unjustified to require a specific percentage of Environmental Net Gain. This would sit alongside requirements to provide a minimum 10% BNG. There is a danger that going further than national policy will make development undeliverable and/or unviable. The mandatory requirement for 10% BNG is already proving more complicated and difficult to implement than envisaged particularly for SME housebuilders, a part of the sector the government is very keen to support. The introduction of yet another, as yet undefined and uncosted, regulatory burden will add further costs - financial, land-take and time, and unnecessarily increase uncertainty. It would feel like another hurdle for housebuilders to overcome to achieve planning permission on sites and would frustrate delivery of much needed market and affordable housing across the South Warwickshire area.

No

Representation ID: 100841

Received: 07/03/2025

Respondent: Friends of Radfords Green Environment (FORGE)

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.

Yes

Representation ID: 101121

Received: 07/03/2025

Respondent: Rowington Landowner Consortium

Agent: Knight Frank LLP

Draft Policy Direction 39 offers an opportunity to integrate environmental enhancements, including biodiversity net gain through wildlife corridors, hedgerows, and wetlands. The policy's broader focus on environmental net gain, such as carbon sequestration, ensures that the development contributes to both local ecosystem restoration and long-term sustainability. The approach aligns with the SWLP goals, supporting sustainable growth and environmental stewardship while enhancing the local biodiversity and landscape.

Other

Representation ID: 101232

Received: 07/03/2025

Respondent: Mac Mic Group

Agent: Marrons

Along with this Policy Direction, the concept of Environmental Net Gain is relatively nebulous at this stage, and not explicit in national planning policy. Mac Mic Group reserve the right to comment further as a comprehensive Framework is prepared. However, the Councils should be mindful of not duplicating policy requirements (with for instance biodiversity net gain and net zero policies) and ensure that any additional requirements are fully viability tested.

No

Representation ID: 101332

Received: 07/03/2025

Respondent: Ashberry Strategic Land Ltd

Agent: Stansgate Planning

Whilst paragraph 187 of the Framework requires planning policies and decisions to contribute to and enhance the natural and local environment there is currently no requirement, or indeed reference, to Environmental Net Gain at a national level.

The Draft Policy Direction provides no justification for the inclusion of an ENG policy, nor any information about how such a policy would function in practice. There are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG. It is likely to harm viability, duplicate BNG requirements, cause longer lead-in times and the uncertainty could delay the deliverability of sites. As such this policy direction should be removed from the emerging Plan

No

Representation ID: 101381

Received: 07/03/2025

Respondent: Bellway Strategic Land / Ashberry Strategic Land

Agent: Marrons

No evidence has been published to justify its inclusion or how this policy would work in practice. object to the approach laid out in this policy, particularly the production of a ‘greening factor’ to establish the levels of green infrastructure that will be required for major development. This policy will need robust evidence to demonstrate that this is feasible, deliverable and does not impact on viability, especially when combined with other requirements such as Biodiversity Net Gain and Environmental Net Gain. The policy needs to be justified and will require proportionate evidence in line with paragraph 36 of the NPPF.

No

Representation ID: 101543

Received: 07/03/2025

Respondent: Hallam Land

Agent: Marrons

Greater clarity is required in relation to what this policy will require, how it will be measured, and what its implications are for delivery in terms of viability and density.

Yes

Representation ID: 101607

Received: 07/03/2025

Respondent: Ms Zoe Leventhal

Support. This emerging policy feels like work in early progress. Research needs to be done on other authorities that have introduced similar policies. It will be important to avoid overlap with DPD 38 (BNG) so as not to increase the burden on developers through duplication. A clear definition of how ENG goes above and beyond BNG is important as is how ENG will be measured.

No

Representation ID: 101608

Received: 07/03/2025

Respondent: Bellway Homes Ltd

Agent: Stansgate Planning

Whilst paragraph 187 of the Framework requires planning policies and decisions to contribute to and enhance the natural and local environment there is currently no requirement, or indeed reference, to Environmental Net Gain at a national level.

The Draft Policy Direction provides no justification for the inclusion of an ENG policy, nor any information about how such a policy would function in practice. There are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG. It is likely to harm viability, duplicate BNG requirements, cause longer lead-in times and the uncertainty could delay the deliverability of sites. As such this policy direction should be removed from the emerging Plan.

Yes

Representation ID: 101689

Received: 07/03/2025

Respondent: Mr Bart Slob

I agree with the approach laid out in Draft Policy Direction-39 on Environmental Net Gain (ENG). Expanding the focus beyond biodiversity to include other ecosystem services such as air and water quality, climate resilience, and flood management is a positive step toward achieving a holistic and sustainable environmental framework. However, it is crucial that ENG requirements are closely aligned with local priorities, including safeguarding areas like SG04, where any development should demonstrate clear benefits to the environment. Additionally, it is essential that the delivery of ENG is well-supported by evidence, ensuring that these measures are both practical and effective.

No

Representation ID: 101730

Received: 07/03/2025

Respondent: Mr Vincent Rollason

This development is not good for the area

Yes

Representation ID: 101907

Received: 07/03/2025

Respondent: Bishop's Tachbrook Parish Council

Agree

No

Representation ID: 101976

Received: 07/03/2025

Respondent: Miss Isabel Collins

improving public transport links is what is needed more

No

Representation ID: 102035

Received: 07/03/2025

Respondent: Miss Bianca Hollis

Why is the council still using pesticides on the grass verges along Avon Crescent, Dale Avenue and Banbury Road??
I’m deeply concerned by The River Avon being polluted. Wildlife, plants, soils and humans are suffering.
The town air is terribly polluted and the traffic is terrible!
Transport and air and water pollution must be addressed!

Other

Representation ID: 102208

Received: 07/03/2025

Respondent: Hallam Land

Agent: LRM Planning

Our comments in relation to BNG are amplified in the context of Environmental Net Gain. To heighten the extent to which BNG should exceed the statutory minimum, and then to add a separate burden of environmental net gain, risks compounding the extent to which other legitimate development objectives can be achieved.

Other

Representation ID: 102227

Received: 07/03/2025

Respondent: IM Land 1 Limited

Agent: Turley

Consideration will need to be given to how any additional requirements would impact site deliverability and viability, with sufficient evidence provided to demonstrate and justify the need to go above and beyond national standards.

Other

Representation ID: 102416

Received: 07/03/2025

Respondent: Taylor Wimpey Strategic Land

Agent: Turley

Taylor Wimpey welcome the opportunity to comment further on any environmental net gain policy. Again, consideration should be given to how any additional requirements would impact site deliverability/viability, and sufficient evidence provided to demonstrate and justify the need to go above and beyond national standards.

No

Representation ID: 102802

Received: 07/03/2025

Respondent: The Ragley Estate

Agent: Stansgate Planning

Whilst paragraph 187 of the Framework requires planning policies and decisions to contribute to and enhance the natural and local environment there is currently no requirement, or indeed reference, to Environmental Net Gain at a national level.
The Draft Policy Direction provides no justification for the inclusion of an ENG policy, nor any information about how such a policy would function in practice. There are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG. It is likely to harm viability, duplicate BNG requirements, cause longer lead-in times and the uncertainty could delay the deliverability of sites. As such this policy direction should be removed from the emerging Plan.

Other

Representation ID: 102857

Received: 07/03/2025

Respondent: Turley

The University supports the concept of Environmental Net Gain. However, consider that as currently drafted, the draft policy direction does not include enough detail on which to provide significant comments at this stage. The draft policy direction states that the Council’s aim to have a policy that requires development to contribute positively to the natural environment by providing measurable net improvements in biodiversity and ecosystem services. The University would request that clarification be provided on how such requirements will be measured and controlled and what evidence is going to be used to support this policy.

Yes

Representation ID: 103004

Received: 07/03/2025

Respondent: Mr David Bailey

I agree.

Yes

Representation ID: 103142

Received: 07/03/2025

Respondent: Mr Jem Brown

A holistic view of a healthy environment is badly needed - for our nature but also the health of the citizens of South Warwickshire.

Yes

Representation ID: 103261

Received: 07/03/2025

Respondent: Elizabeth Simpson Yates

I support the development of a comprehensive ENG framework, so we can deliver meaningful environmental protections.

Other

Representation ID: 103690

Received: 07/03/2025

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

Agent: Turley

Richborough note that this is an emerging area of policy and highlight the justification text at page 158 of the Preferred Options Plan, which states: “Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan”. Until this further information is available to demonstrate there is a need for Environmental Net Gain Strategy, stakeholders are unable to provide a robust response.

Other

Representation ID: 103691

Received: 07/03/2025

Respondent: Richborough - Gaydon Road, Bishop's Itchington

Agent: Turley

Richborough note that this is an emerging area of policy and highlight the justification text at page 158 of the Preferred Options Plan, which states: “Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan”. Until this further information is available to demonstrate there is a need for Environmental Net Gain Strategy, stakeholders are unable to provide a robust response.

Other

Representation ID: 103692

Received: 07/03/2025

Respondent: Richborough - Lighthorne Road, Kineton

Agent: Turley

Richborough note that this is an emerging area of policy and highlight the justification text at page 158 of the Preferred Options Plan, which states: “Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan”. Until this further information is available to demonstrate there is a need for Environmental Net Gain Strategy, stakeholders are unable to provide a robust response.

Other

Representation ID: 103694

Received: 07/03/2025

Respondent: Richborough - Sycamore Close, Stockton

Agent: Turley

Richborough note that this is an emerging area of policy and highlight the justification text at page 158 of the Preferred Options Plan, which states: “Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan”. Until this further information is available to demonstrate there is a need for Environmental Net Gain Strategy, stakeholders are unable to provide a robust response.

Other

Representation ID: 103696

Received: 07/03/2025

Respondent: Richborough - Kineton Road, Wellesbourne

Agent: Turley

Richborough note that this is an emerging area of policy and highlight the justification text at page 158 of the Preferred Options Plan, which states: “Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan”. Until this further information is available to demonstrate there is a need for Environmental Net Gain Strategy, stakeholders are unable to provide a robust response.