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Policy 3 Environmental Protection and Enhancement

Representation ID: 23453

Received: 09/03/2021

Respondent: Chet Valley B-Line

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

General: we are unable to tell from the Green Infrastructure Corridors maps if these include all the Norfolk B-Lines, including the Chet Valley B-Line. The National B-Line launch takes place 23/03/2021, but the routes in Norfolk are already well known.
GNLP “Tools such as the Defra biodiversity metric should be used to demonstrate the expected biodiversity net gain that will be achieved through development.”
GNLP “It will need to be demonstrated that the gain to biodiversity is a significant enhancement (at least a 10% gain) on the existing situation.”
Concern: SMART targets need to be applied to BNG. They should be Specific, Measurable. Attainable, Relevant and Time Specific.
Concern: unless all LAs use the same tool no consistent measurement will be possible. Similarly, LAs should follow the same assessment and monitoring procedures, practices, and principles to ensure consistency. We recommend the CIRIA Good Practice Principles for Development: a practical guide. We also understand that a new British Standard BS8683 is being developed.
Concern: all LAs need access to specialist ecological advice and to be able to identify sites of ecological value that may have no formal designation e.g., brownfield. Within the B-Line corridors we recommend surveys are conducted using Buglife’s Good Planning Practice for Invertebrates: Surveys.
Concern: Developers should be penalised if they reduce the sites biodiversity value before submitting applications. Habitat removal prior to application submission can seriously reduce biodiversity value and should be strictly discouraged by measuring value prior to removal.
Concern: The BNG 10% gain should be time specific and prior to the developer relinquishing responsibility for the site.

Change suggested by respondent:

General: we are unable to tell from the Green Infrastructure Corridors maps if these include all the Norfolk B-Lines, including the Chet Valley B-Line. The National B-Line launch takes place 23/03/2021, but the routes in Norfolk are already well known.
GNLP “Tools such as the Defra biodiversity metric should be used to demonstrate the expected biodiversity net gain that will be achieved through development.”
GNLP “It will need to be demonstrated that the gain to biodiversity is a significant enhancement (at least a 10% gain) on the existing situation.”
Concern: SMART targets need to be applied to BNG. They should be Specific, Measurable. Attainable, Relevant and Time Specific.
Concern: unless all LAs use the same tool no consistent measurement will be possible. Similarly, LAs should follow the same assessment and monitoring procedures, practices, and principles to ensure consistency. We recommend the CIRIA Good Practice Principles for Development: a practical guide. We also understand that a new British Standard BS8683 is being developed.
Concern: all LAs need access to specialist ecological advice and to be able to identify sites of ecological value that may have no formal designation e.g., brownfield. Within the B-Line corridors we recommend surveys are conducted using Buglife’s Good Planning Practice for Invertebrates: Surveys.
Concern: Developers should be penalised if they reduce the sites biodiversity value before submitting applications. Habitat removal prior to application submission can seriously reduce biodiversity value and should be strictly discouraged by measuring value prior to removal.
Concern: The BNG 10% gain should be time specific and prior to the developer relinquishing responsibility for the site.

Full text:

General: we are unable to tell from the Green Infrastructure Corridors maps if these include all the Norfolk B-Lines, including the Chet Valley B-Line. The National B-Line launch takes place 23/03/2021, but the routes in Norfolk are already well known.
GNLP “Tools such as the Defra biodiversity metric should be used to demonstrate the expected biodiversity net gain that will be achieved through development.”
GNLP “It will need to be demonstrated that the gain to biodiversity is a significant enhancement (at least a 10% gain) on the existing situation.”
Concern: SMART targets need to be applied to BNG. They should be Specific, Measurable. Attainable, Relevant and Time Specific.
Concern: unless all LAs use the same tool no consistent measurement will be possible. Similarly, LAs should follow the same assessment and monitoring procedures, practices, and principles to ensure consistency. We recommend the CIRIA Good Practice Principles for Development: a practical guide. We also understand that a new British Standard BS8683 is being developed.
Concern: all LAs need access to specialist ecological advice and to be able to identify sites of ecological value that may have no formal designation e.g., brownfield. Within the B-Line corridors we recommend surveys are conducted using Buglife’s Good Planning Practice for Invertebrates: Surveys.
Concern: Developers should be penalised if they reduce the sites biodiversity value before submitting applications. Habitat removal prior to application submission can seriously reduce biodiversity value and should be strictly discouraged by measuring value prior to removal.
Concern: The BNG 10% gain should be time specific and prior to the developer relinquishing responsibility for the site.

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