Object

Representation ID: 14942

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P10 Bullet Point 12:
- Approach is inconsistent with Environment Bill.
- Govt will make provision for statutory biodiversity units in the Environment Bill, purchasable at a standard cost.
- This approach will allow Councils, landowners and organisations to set up local habitat compensation schemes, where they wish to do so; if this is not the case, the Govt will provide a last-resort supply of biodiversity units, which will prevent delays to development.
- Viability assessment should fully account for additional costs associated with biodiversity gain, HBF view that Council’s viability evidence significantly underestimates costs.
- Govt has said more work needs to be done to address viability concerns of net gain by the housebuilding industry.
- DEFRA Biodiversity Net Gain and Local Nature Recovery Strategies Impact Assessment (Table 14) sets out costs of £18,527 - £63,725 per hectare of development for the West Midlands region (based on 2017 prices).
- Environment Bill makes provision for a 2 year transition period, and will work with stakeholders on guidance, what will be required and when.