BTF Preliminary Comments 07 May 2024

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biodiversity which will have to be mitigated offsite, a full Statutory Metric Calculation (BM)

ought to be produced.

8. For the purposes of our BM calculation, we have included individual trees T19, T28 and two

of the trees in tree group G20. This is provisional until we see better evidence. On this

basis, we calculate that the onsite baseline Individual trees habitat area is 0.0652 hectares,

of which 0.0489 will be retained. On the basis that this habitat is in moderate condition

and of high strategic significance (the trees are growing within the SNCI and are specifically

protected by SADMP DM17), this habitat has a value of 0.60 habitat units.

9. If the trading rules are complied with, 11 small BM category will need to be planted to

mitigate the loss. This includes the four trees required under DM17/BTRS.

10. Until we see the other habitats identified in the applicant’s evidence, we cannot comment

on any other biodiversity gain mitigation that may be required. However, on the basis of

our calculation above, this will produce a biodiversity gain of 1.25%.

11. Whilst we acknowledge that the applicant is not obliged to achieve at least a biodiversity

gain of 10% (because the application predates the requirement that came into effect on 02

April), we are pleased that it has committed to doing so.

12. Even if that were not the case, the applicant is still obliged under paragraph 185 b) of the

NPPF to ‘...identify and pursue opportunities for securing measurable net gains for

biodiversity.’6 At the moment, we understand, the biodiversity gain evidence is showing a

net loss of -63.77%. Proposals will need to be made to resolve this and achieve at least the

NPPF requirement and the promised 10% biodiversity gain, whilst also complying with the

BM trading rules.

6 https://assets.publishing.service.gov.uk/media/65a11af7e8f5ec000f1f8c46/NPPF_December_2023.pdf