It is hard to comment on this due to the lack of detail and lack of detail describing which species and habitats are being considered. Mention is made of areas, locations and species being considered in promoting net gain, but these areas and locations are not described in any way making it hard to comment? Have swift nest boxes been considered as an essential design feature for new houses? RSPB is happy to advise if this would help.
Paragraph 188 mentions the HRA, but our opinion is this document isn’t thorough enough and considers potential sources of impact in isolation but not in combination. RSPB has evidence of such ‘in-combination’ impact from our nature reserves, specifically related to bird disturbance and the water environment.