Local Plan Issues and Options (Regulation 18)

Support

Representation ID: 16777

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15495
The LPIO’s suggested approach is to combine Local Plan (Part One) Policies ENV 3 and ENV4, with elements of Local Plan (Part Two) Policies DM 44 and DM 45, to create a single new green infrastructure, biodiversity and nature policy. Bloor welcomes the streamlining of numerous existing policies into one policy. LPIO Question GI3 asks whether the new Local Plan policy should go above the statutory 10% biodiversity net gain requirement. The National Planning Practice Guidance [PPG] states that “Planmakers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.” 1 In the absence of any such evidence, the proposal for Local Plan policy to be above the statutory 10% biodiversity net gain requirement would be contrary to the PPG. The implementation of such a policy without due consideration to viability, could have significant implications on development in the borough. The proposals have the potential to create a barrier to housing delivery and reduce the ability of developers to provide other contributions which may be required to make development acceptable. Furthermore, the requirement to deliver more onsite BNG has a significant effect on the ability to redevelop brownfield sites particularly where there is the presence of habitats such as Open Mosaic Habitat. Coupled with that, the delivery of onsite BNG can affect the net developable area of a site therefore requiring more land to deliver the development requirements of the plan.

Support

Representation ID: 16778

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15496
LPIO Question QI2 asks whether the new Local Plan policy should impose a 2:1 ratio for a tree replacement policy. The Council should fully consider the impact of the proposed policy on the viability of schemes, to ensure that any future requirements do not prevent the delivery of homes. The policy should also be worded with sufficient flexibility to allow for proposals to reflect local characteristics and the efficient use of land. It would be more effective to base the replacement of trees around the value of trees lost and enable reduced provision where it can be justified through appropriate evidence.