Bucks Council are consulting on a Biodiversity Accounting "Supplementary Planning Document" (SPD) which planning applications will be required to comply with in the future.
A SPD is a planning document which provides more detail or guidance on local planning policies.
The SPD sets out: the biodiversity "net gain" requirements; how to measure existing biodiversity and achieve the required net gain; how to avoid biodiversity loss; and, more controversially, mitigation and "biodiversity accounting financial contributions."
You can read the consultation document here:
So, here’s the view from the Wheelhouse on this document which, at first sight, seems positive but unfortunately lists so many exemptions and, as usual, includes the ultimate get out clause – that old chestnut, the “financial contribution in lieu” – that it doesn’t do what it says on the tin.
My heart sinks when these SPDs refer to financial contributions....it's like saying "we'd like you to do X to protect biodiversity, but if you can't, you can just pay instead." It’s a sort of “off-setting” scheme which will be easy for developers to manipulate.
You can reply to the consultation by emailing planningpolicyteam.bc@buckinghamshire.gov.uk or complete the on-line consultation survey. The deadline is 19th March.
In a nutshell, I have responded to this consultation to say:
· There are too many exemptions. As an example, “permitted development” is an exemption but the Government have relaxed these rules to such a degree (and are planning even greater relaxation of the permitted development rules), that the SPD SHOULD apply to permitted development such as change of use.
· If viability is a factor in determining whether the SPD applies, developers will apply the “viability loophole” to avoid compliance. Offsetting could enable development in areas of high land value for example where land pressure is high, yet developers could avoid compliance by exploiting the viability loophole.
· Why exclude nationally significant infrastructure, which could be one of the worst offenders, e.g. HS2?
· I fundamentally question whether financial contributions from developers should count as “mitigation.”
· Biodiversity would not be protected where it is established and needed within an existing eco-system, just destroyed for profit.
· Offsetting cannot compensate for the loss of the social well-being of a greenfield site.
· Land offered as compensation may not be accessible by the community losing a site.
· There is no guarantee that new sites will flourish.
· There is no penalty if the new sites fail.
· It takes many, many years between destruction of the old site and establishing and flourishing of the new one.
· Biodiversity is valuable where it is.
· Wider eco-system benefits are ignored such as soil sinks, pollinators, flood relief and habitat connectivity which would be permanently destroyed.
· Direct conservation should be prioritised.
· On-site harm can never be truly compensated.
· Negative projects should simply be refused.
· Off-setting may not be a gain.
· Offset sites may not endure in perpetuity.
· Expense of running the offset schemes is an issue.
· The SPD does not address the problem of rapid biodiversity loss.
· Biodiversity is not a commodity to be traded.
· The SPD is a ruse to enable developers to develop over wildlife habitats.
· The focus should be on reversing the decline.
· Areas could become devoid of biodiversity as developers target profitable areas and rely on compensation sites miles away.
· Who will pay if the offset site fails? Will this last in perpetuity?
· All new development should respect existing nature in addition to improving it.
Here’s an extract from the SPD which lists the exemptions from the obligations:
How the scheme will work:
How will offsetting work?
And then we get to the bottom line:
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