Support

Representation ID: 11182

Received: 12/12/2020

Respondent: Environment Agency

We are supportive of Defra’s proposals to mandate biodiversity net gain as an important first step, but we are equally keen to collaborate on developing and testing a wider approach to environmental net gain. We are supportive of this policy’s inclusion of net gain, with a specific requirement of 10%.

Delivery of net gain should follow the sequential steps of the mitigation hierarchy: avoid impacts to biodiversity, mitigate impacts and finally compensate impacts. In addition, delivery of net gain should follow the spatial preference: deliver within the footprint of a development first and where this is not possible delivered at a suitable alternative site. Where net gain cannot be delivered on site or at a suitable alternative site the last option would be to compensate through a tariff system.

Consideration should be given to including issues relating to contaminated land and the chance to clean it up plus also need to consider the ‘underground environment’ i.e. groundwater resources, as water supply to rivers and wetlands and as a drinking or process water supply, rather than only in P11 and P14.