Preferred Options 2025
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Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction-38 - Biodiversity Net Gain?
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
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction –39- Environmental Net Gain?
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
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction-40 Green and Blue Infrastructure?
Representation ID: 102211
Received: 07/03/2025
Respondent: Hallam Land
Agent: LRM Planning
The introduction of a “Greening Factor” is another layer of net gain, a fact acknowledged in the wording of the text.
There appear to be three policies covering a similar area.
Other
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction-48- Protecting and Enhancing Landscape Character?
Representation ID: 102223
Received: 07/03/2025
Respondent: Hallam Land
Agent: LRM Planning
t is an inescapable fact that to meet the development needs of the plan area there will be a change to the character and appearance of those locations where new development is situated.
One of the factors in determining where development should be located is the landscape value of a site and the visual effects of new development. It will be important that the extent of change is minimised, but it cannot be avoided.
No
Preferred Options 2025
Do you agree with the approach laid out in Draft Policy Direction-49- Agricultural Land?
Representation ID: 102225
Received: 07/03/2025
Respondent: Hallam Land
Agent: LRM Planning
As presently drafted, the relationship between the first and second bullet points is not clear.
Where land has been allocated for development, and presupposing the development proposed accords with the intent of the Local Plan, it should not then be necessary to demonstrate that the benefits of the proposed development outweigh the loss of best and most versatile agricultural land. That judgement will have been inherent in the site’s selection in the first instance.
