BIO0049

Salisbury & Wilton Swift Group

Biodiversity and Ecosystems Inquiry

We would like to respond to the above inquiry on the following issue:

Evaluating measures to conserve and enhance biodiversity:

• How effective are the new measures to enhance biodiversity within the Environment Bill, particularly biodiversity net gain and Nature Recovery Networks?

As a voluntary group we comment on planning applications of over 5 dwellings on both the Wiltshire and Swindon planning portals.

Whilst we are primarily concerned with the provision of nesting opportunities for birds, our experience is that the depth of information within ecology reports is extremely varied.  This is somewhat understandable given the width of the subject involved.  With funding stretched for Local Authorities (LAs), the reports provided by ecologists have an important role in the ecological mitigation and enhancement conditions set by LAs for developers.  This knowledge can be enhanced by using the more specialist expertise of the many voluntary nature groups we are lucky enough to have in the UK.

Several government documents give guidance on measures to help achieve biodiversity net gain:

• National Planning Policy Guidance (NPPG, 2019) states: “…relatively small features can often achieve important benefits for wildlife, such as incorporating ‘swift bricks’ and bat boxes in developments and providing safe routes for hedgehogs between different areas of habitat” (Natural Environment, Paragraph 023, Reference ID: 8‐023‐20190721).

• Living With Beauty (Government’s Building Better Building Beautiful Commission, 30/01/20) recommends: "Bricks for bees and birds in new build homes" (Policy Proposition 33, page 110).

Ministry of Housing, Communities & Local Government press release (21/07/19) stated: “For the first time the government has set out its expectations on how developers can protect specific species, including using ‘hedgehog highways’ and hollow swift bricks – which are installed into the walls of new build homes, allowing the birds to nest safely. This follows public interest for protecting these much-loved animals, with one petition receiving support from over half a million people.”

Yet these integrated measures which have been recognised by government are not included in the DEFRA biodiversity metric calculations.  Therefore there is no incentive for ecologists to include such measures in the calculations they submit to show that a development has achieved a ‘biodiversity net gain’ leaving a mismatch between government policy and the means to achieve that policy via the metric.  As a group we have experienced rebuttal from ecologists who use the metric, and of course developers are not keen to include ‘additional’ biodiversity measures.  This inquiry is a valuable opportunity to remedy this oversight.

September 2020