Object

Representation ID: 23674

Received: 12/03/2021

Respondent: Home Builders Federation

Legally compliant? No

Sound? Not specified

Duty to co-operate? Not specified

17. This policy requires all development to deliver a significant enhancement of at least a 10% net gain for biodiversity in accordance with the Environment Act. However, it is important to note that the legislation does not set this as a minimum and the Council should not to seek to do so either. It is the Government’s opinion that 10% strikes the right balance between the ambition for development and reversing environmental decline providing certainty in achieving environmental outcomes, deliverability of development and costs for developers. As such the Council should not specify a requirement above 10%. The prefix “at least” should be deleted. This would not prevent a developer from going further but it ensures clarity to decision makers that a scheme delivering a 10% net gain is compliant with the legislation.
18. In addition, the Council have not appear to have included the impact of a 10% net gain in biodiversity on development in the Greater Norwich Area. There are significant additional costs associated with biodiversity gain. The impact assessment produced by DEFRA to support the consultation on Biodiversity Net Gain & Local Nature Recovery Strategies sets out in table 14 the costs of implementing a 10% net gain. In the East of England, it was estimated that it would cost £18,329 per hectare based on a central estimate. However, there are significant increases in costs to £62,983 per hectare for off-site delivery under Scenario C. There may also be an impact on the net developable area of site that will need to be considered in the viability assessment.
19. The Government has confirmed that more work needs to be undertaken to address viability concerns raised by the housebuilding industry in order that net gain does not prevent, delay, or reduce housing delivery. It is therefore important that the full cumulative costs on development are considered in the local plan and this must be addressed prior to submission. Without the inclusion of this additional cost the Council cannot provide the required certainty that the plan and the sites it has allocated are deliverable.