Proposed Main Modifications

We welcome the requirement for all developments to provide a measurable biodiversity net gain but recommend that a more ambitious target of 20% is set.
Norfolk has a wonderfully rich and varied biodiversity but it is not in a safe or stable condition, and it remains under serious threat. Our wealth of varied habitat supports 2328 of species which are classified as ‘Species of Conservation Concern’, meaning they are rare, threatened or protected by law, with some of these nationally rare and special species only found in the UK in Norfolk. Almost 13% of Norfolk is made up of Priority Habitat and Norfolk is home to a high proportion of the UK’s most wildlife-rich habitats, including chalk streams, reedbed, fens, dry acid grassland and coastal sand dunes. Norfolk is also a national stronghold for Priority Species including barbastelle bat, swallowtail butterfly, bittern and stone curlew.
Norfolk has 163 SSSIs, covering an area of 121,223 ha, equating to 23% of the total area of the county. Of these, 30% of the SSSI features are in unfavourable (no change) unfavourable declining, or unknown condition. For County Wildlife Sites, the non-statutory network of sites important for wildlife at the county level, monitoring data shows that 66% are either in declining, unfavourable condition or unknown. This compares to a national average of 48% in favourable condition.
There is sometimes a misconception that increasing BNG from 10% to 20% is doubling the amount of habitat to be delivered. This is not the case. The increase is only from 110% to 120% of pre-development biodiversity levels. The vast majority of the cost of BNG is on meeting the 110% statutory target, and the extra 10% is a small extra cost that does not impact on viability.
A 10% minimum gain has been set by the Environment Act, as this is the lowest level that Defra consider would actually deliver biodiversity gains. But we consider that given the pressures facing the county’s biodiversity, a greater ambition of 20% should be set to provide greater confidence in genuine gains for biodiversity and ensure the successful recovery of nature in Norfolk.
Relevant findings from Defra’s Impact Assessment document (21/11/2018) include (our emphases):
“..In simple terms, [10%] is the lowest level of net gain that [Defra] could confidently expect to deliver genuine net gain, or at least no net loss, of biodiversity and thereby meet its policy objectives.”
“..Advice from some Natural Capital Committee members suggests that a level of net gain at or above 10% is necessary to give reasonable confidence in halting biodiversity losses.”
“..The department therefore favours as high a level of net gain as is feasible...The analysis undertaken in this Impact Assessment indicates that the level of requirement makes relatively little difference to the costs of mitigating and compensating for impacts.”
The Defra impact assessment also found that the level of net gain requirement makes relatively modest difference to the costs of mitigating and compensating for impacts when assessed against the more significant costs of achieving no net loss and wider development policy objectives. It found that the majority of the costs associated with net gain are incurred to correct for the initial loss of biodiversity through development (i.e. achieving only ‘no net loss’). Careful design and early consideration can see the achievement of significant biodiversity improvement with little or even no additional spend.


We recommend that the text “wherever possible” is removed from the sentence relating to the contribution to the delivery of the national Nature Recovery Network objectives.
We support the requirement for the use of sustainable transport

We welcome the requirement for all developments to provide a measurable biodiversity net gain but recommend that a more ambitious target of 20% is set (see our comments relating to MM01)
We support the requirement for any temporary developments to make a contribution to the delivery of the national Nature Recovery Network objectives.

We welcome the requirement for all developments to provide a measurable biodiversity net gain but recommend that a more ambitious target of 20% is set (see our comments relating to MM01). We support the requirement for any temporary developments to make a contribution to the delivery of the national Nature Recovery Network objectives.

We welcome the requirement for all developments to provide a measurable biodiversity net gain but recommend that a more ambitious target of 20% is set (see our comments relating to MM01)
We support the requirement for any temporary developments to make a contribution to the delivery of the national Nature Recovery Network objectives

We support the proposed new text around energy use and the inclusion of river flows.

We support the inclusion of irreplaceable habitat

We support the new text but recommend setting a target of 20% BNG (see our comments relating to MM01)

We support the inclusion of this paragraph.

We support the inclusion of irreplaceable habitat

We recommend including 20% BNG (see our comments relating to MM01).