About this page
How this part of the Local Plan Options Document works
These Development Management policy option pages contain the following sections:
Policy background
- Relevant national policy or regulations
- National or regional trends
- Local situation and needs/li>
- How we have dealt with this issue in the past
- The thinking behind the policy
Policy options for the new Local Plan
We may suggest a variety of approaches:
- Keeping existing policy as it is
- Making small changes
- Replacing the policy with something that is substantially different
- Identifying factors or events which may affect this policy in the future
Policy option analysis
- A list of the advantages and disadvantages that we have identified for each of the policy options we are presenting.
Read the Natural Environment Topic Paper, for in-depth focus about this topic, and the evidence which informs our policy. Visit our library of Local Plan Options supporting documents to learn more.
Explore the policy
Select a section below to read more.
9.182 Biodiversity Net Gain (BNG) is a process designed for the planning system to make sure new development delivers a net positive impact on the natural environment.
9.183 The Construction Industry Research & Information Association provide a useful description of the BNG process:
9.184 “Enhancing biodiversity is integral to sustainable development, and BNG is an approach to embed and demonstrate biodiversity enhancement within development. It involves first avoiding and then minimising biodiversity loss as far as possible, and, achieving measurable net gains that contribute towards local and strategic biodiversity priorities” (CIRIA, C776a).
9.185 This clarifies a key aspect of the BNG approach which is to first avoid and then minimise biodiversity loss before considering and then calculating BNG values pre and post development. The approach therefore requires continued use of the mitigation hierarchy and existing and updated Natural Environment Policies.
9.186 Local Plan Partial Update (LPPU) Policy NE3a sets out development will only be permitted for major developments where a BNG of a minimum of 10% is demonstrated and secured in perpetuity (at least 30 years) subject to meeting the criteria listed within the policy.
9.187 The LPPU sets out the intention for research to be undertaken to explore introducing a higher requirement of BNG through preparation of the new full Local Plan. This is also set out in the council’s Ecological Emergency Action Plan.
9.188 The detailed background and evidence relating to the following options is set out in the Natural Environment Topic Paper.
9.189 National Guidance sets out that plans should: “promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.” As such, the following options are proposed:
Option A
Rely on the existing policy approach and emerging national legislation.
Advantages of Option A
- Approach is already in place and has recently been tested as part of the LPPU examination.
- The approach responds to the Council’s declared Ecological Emergency in July 2020.
Disadvantages of Option A
- Existing approach is limited concerning a distinction between the requirements on greenfield sites and brownfield sites.
- Further issues raised revolve around how development schemes requiring BNG will be implemented, monitored and enforced.
- Relying on a 10% minimum BNG requirement may not deliver sufficient habitat gains.
- Existing policy approach will be out of kilter with mandatory requirements for small sites after March 2024 and so will need updating to require at least 10% net gain for minor applications.
Option B
Require a minimum 20% biodiversity net gain on:
- Previously developed land (Major Applications)
- Strategic housing sites (can then be a development requirement for allocated sites)
- All major development within protected landscapes
- Ground array solar farms
- For all council developments
Advantages of Option B
- The LPPU sets out the intention for research to be undertaken to explore introducing a higher requirement of BNG through preparation of the new full Local Plan.
- The approach will increase a development’s contribution to nature recovery, and as a result help to better address the ecological emergency.
Disadvantages of Option B
- Potential viability concerns may require weighing up or balancing benefits against other spatial priorities.
- Further work needed on sufficient evidence to justify the approach.
Option C
A staggered/ graded approach to BNG requirements for different schemes i.e. require a minimum 20% biodiversity net gain on all major developments, down to 10% on minor applications.
Advantages of Option C
The LPPU sets out the intention for research to be undertaken to explore introducing a higher requirement of BNG through preparation of the new full Local Plan.
Disadvantages of Option C
- Potential viability concerns may require weighing up or balancing benefits against other spatial priorities i.e., amount / type of housing provided on site.
- Further work needed on sufficient evidence to justify the approach.
9.190 Government guidance refers to habitats of significance but as of now this is not defined
Discussion questions
Question 1
Which of the policy Options A to C do you prefer? Please say why
Question 2
Would an additional policy approach be needed for influencing the location of off-site gains and their proximity to point of habitat loss?
Question 3
Question: Should we be seeking a minimum of no net loss and appropriate net gain for schemes exempt from mandatory BNG?
Question 4
Do we need to define when long-term management of on-site biodoversity gains is required?