Please find below comments from Brighton and Hove’s Wildlife Forum in response to BH2022/02232
Brighton and Hove’s Wildlife Forum members come from a range of local wildlife groups, also known as 'Friends Groups', and local experts in their field, such as volunteers from Butterfly Conservation, naturalists, students and professional environmental consultants. But we all share the same enthusiasm for wildlife and the same concerns for its future. Our commitment is to conserve and enhance Biodiversity across the Brighton and Hove area.
We believe nature has intrinsic value and is vital for our wellbeing. We want to make our city richer in nature and increase people's engagement with the natural world. We will work with others to protect, enhance, celebrate and increase awareness of the habitats, features and species special to Brighton and Hove. BHWF looks forward to a future where nature and our community live together to our mutual benefit, enabling our city to play its part in addressing the nature and climate crises."
BHWF objects to the planning proposal for the following reasons:. -
There is currently a 83.93% loss in biodiversity according to the metric. Obviously, this is not acceptable or policy compliant. The applicants should do more to both preserve habitat on site and outline viable offsite delivery.
It is not ok to leave these discussions until after permission is granted.
If they can’t evidence at least a 10% net gain, the planning permission must be refused.
Also given the habitat being lost is scrub and usually net gain requires replacement of the same or higher value habitat, the applicants need to think really carefully about what habitat is appropriate offsite and where it would go. Clearly they shouldn’t be creating scrub on chalk grassland for example. Without this required detail in the proposals, BNG measures cannot be assessed.
- The Ecological Impact Assessment shows that the reptile, bat and dormice surveys are still outstanding, so again a decision can’t be made until this information is provided and assessed.
- The EcIA also relies on offsite BNG to conclude a positive impact and again has no detail. Overall the application says that the existing habitats (scrub) don’t have much value and that the new habitats on site will have more value. However, there seems to be very little onsite habitat creation and all of them will be negatively impacted by the people and cars using the site. Offsite BNG might be the better but it needs to be really well thought out.
With the lack of surveying thus far, onsite scrub may have more value than is being stated.
- Finally, overall, the development is being sold as ‘carbon neutral’, but is providing significant car parking spaces. This appears contradictory.