Natural England supports the inclusion of a policy for achieving biodiversity net gain.

This is in line with the NPPF, and the Government's 25 year Environment Plan. Natural England would welcome the opportunity to work with CDC on the implementation of the net gain policy. We recommend including more detailed guidance for developers on achieving net gain, and suggest the following measures are incorporated into the Local Plan, either through policy wording, or a more detailed guidance:

* Biodiversity metric - developers should apply the Defra biodiversity metric, which is a clear and methodical calculation for net gain in biodiversity for individual planning proposals. The metric is currently being updated by Defra and Natural England to include a wider range of habitat types and incorporate wider benefits of Green Infrastructure (GI).

* Net gain plans - larger applications (and at least strategic allocations) should be required to submit a net gain plan which clearly sets out the ecological issues of the proposals, including clear accounting for residual biodiversity loss and how this is addressed, as well as additional 'net gain' provision which can be on and/or off-site.

You may wish to consider what threshold may be applied to development. We advise that where known ecological interests occur (e.g. ponds, bat roosts etc.), or proposals involving at least 0.1ha of greenfield land, a net gain plan should be required to address these issues.

A standard template for net gain plans may be useful to provide consistency and to facilitate policy reporting and auditing.