No

Representation ID: 4868

Received: 17/02/2017

Respondent: St Francis Group

Agent: Pegasus Group

Recognise importance of protecting the environment.
Policy P10:
'Full ecological survey' and 'net gain or enhancement' to each development is overly arduous and not in spirit of NPPF, which states 'provide net gains in biodiversity where possible.'
Policy P11:
Approach in policy alludes to sequential test, but this is not explicit.
Unreasonable to state 'there are no other viable site at lower risk of flooding'. Viability is a much more restrictive test than availability, which is not in accordance with national guidance and should be revised accordingly.