Draft policy 3 of the GNLP does not refer specifically to County Wildlife Sites (‘CWS’) but states that development proposals will be required to conserve and enhance the natural environment avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development and the harm has been minimised. This means that a CWS designation does not preclude development, but it will be a high and undefined bar to demonstrate that the benefits of development overrides harm unless policy is clearer. We therefore propose that draft policy 3 is amended to set out a clear benefit a development can provide, such as a 10% biodiversity net gain. Draft Policy 3 is proposed to read as follows:

“Development proposals will be required to conserve and enhance the natural environment (including valued landscapes, biodiversity including priority habitats, networks and species, ancient trees and woodlands, geodiversity, high quality agricultural land and soils) through: • being designed to respect and retain, and add to, natural assets; taking account of local design and other guidance, and undertaking landscape, biodiversity or other appropriate assessments if significant impacts might arise; • avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development, for example at least a 10% biodiversity net gain, and the harm has been minimised”.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.