SUMMARY

1   Establish system of EBGs      (Established Biodiversity Guardians).

2   They establish Biome Value (BV) for each site.   

Sliding scales from   Keep 100%    to    All action allowed

3    Especially for Parks etc.,

    >> Intangible Gain Valuation (IGV) (IV is non-cash) decided byLOCALS.

4  Every case is local.

No trade-offs. No tariffs. Every site is a one-off.

5    Advantages:

Author

SF : Editor@city-voice.org     0 78 66 470 409  cel and whatsapp +55 11 9 3346 4762  Twitter : @CityVoicEd  

BELOW :

The full original proposal, which was a reply to a UK government consultation on “Biodiversity net gain”

Defra Net Biodiversity Gain Consultation       Response ID ANON-C7YZ-EBKP-F    Submitted to ‘Net Gain’ 2019-02-10 00:44:48

Introductory information

  1. Name:                        S B Fry                 C.  Email:         editor@city-voice.org        D.  Organisation:           www.city-voice.org @CityVoicEd

E.  Sector or interest :    www.CityVoice.co is to be an interactive T&CPlanning website to empower objectors and ideas-people who are

                                      otherwise marginalised or ignored – by giving their multiple views a platform, to strengthen this component of the dialogue

Scope

Should biodiversity net gain be mandated for all housing, commercial and other development within the scope of the Town and County Planning Act?Yes
 Please provide any explanation for your answer here: The development juggernaut has been hyper-enabled by government, and in general those who can see what’s going on are usually expressing themselves in terms of need for extreme protection for existing intangible assets. It is the fact that this opinion is occurring widely that indicates that protections of intangibles need to be excessively stated, legislated and reinforced so as to counter this trend to excess. Until the planning system returns to delivering a more neutral performance, it is appropriate for ‘extreme’ positions to be adopted to counter it.Making this always a component of planning permissions would make developers AWARE that this is a mandatory aspect of our civilisation, to be respected (not a concern only of an eccentric minority).It has been pointed out (writer Stella Stafford et al) that most ‘biodiversity’ will likely be in fact the fruit of maybe 1,000 years of growth and development of the land and its live components – i.e. highly probable that it is in practice irreplaceable: hence protection should be extreme as standard, to guard against weakness of defence (often in the form of badly-taken local authority decisions). Once gone, it’s gone. Assumption against.Inadequate brief: I ask you to withdraw your brief-item which says:     “Nationally significant infrastructure or other development not requiring planning permission is not in scope.”  
What other actions could government take to support the delivery of biodiversity net gain? Please provide your answer here:     BIODIVERSITY SUMMARY of  BD LEGISLATION                                                          for CPA 4 Nov 2021: 1   Establish system of EBGs      (Established Biodiversity Guardians). = Ecologists registered and approved by two respected organizations (FoE, CPRE, CivicVoice, etc.)With legal powers, they lay down (as law) what can be done to a site 2   They establish Biome Value (BV) for each site.    Sliding scales from   Keep 100%    to    All action allowed For (a) Biome Value     (b) Tree Protection Categories (TPC)    (c) Watercourses               Exemptions only for private gardens ( < 2,000 sq ft?) 3    Especially for Parks etc., Intangible Gain Valuation (IGV) (IV is non-cash) decided byLOCALS. 4      Every case is local. No trade-offs. No tariffs. Every site is a one-off. No future undertakings or covenants. Instead the concept of permanent responsibility Covenants can be broken, lead to lawsuits. Forget it.         No market in these credits. 5    Advantages: i)    Quick, simple, small fee to ecologist is tiny vs. estate agents’ commissions, tax, etc.ii)   Reliance on certified-honest EBGs breathes whole new life into public awareness and consciousness.     LONGER SUMMARY Create the role of EBGs (Established Biodiversity Guardians): – members of ecology profession – and give them LEGAL POWERS as specified below.   BiomeValue (BV) to be a legal concept in legislation (a special case of measured Intangible Value (IV)Established by locally chosen Reliable Organization: Friends of The Earth, CPRE, CivicVoice, Locality.com, CoVop (community Voice on Planning), Open Spaces Society, etc. – there are several others (ii)     Adopt scale from A (sole habitat of a species) to E  (no value)          For A, and B1, B2 ,B3:  breaking ground (or cutting trees) would not be allowed (iii)    Tree Protection Categories (TPC) – T1 (keep 100%),     T2   (% specified by EBG),                               T3 (all felling allowed) (iv)    Watercourses:                                    W1 (irreplaceable), W2 (EBG specifies action – with force of law), W3 (action free) Exemptions: only for private gardens up to say 2,000 sq ft (?) Measuring gain: Devise system of Intangible Gain Valuation of (WITHOUT allocating cash value) as requirement of any development – exact nature and ‘quantity’ or scale DICTATED by local community, preferably at Parish Council, with ASSUMPTION IN FAVOUR of 100% obedience to objections or requirements raised by LOCAL people – Local People being DEFINED AS same street, + <200 yards ‘radius’ drawn from all points on that street. And in the case of a public park, Parish, City, District AND county council must ALL approve, and specify IGV. Developers can pay or make compensating works elsewhere? No. Any works would be defined by the EBD.  Permission to occupy would be withdrawn until EBG approval of completed “works”. 3)    Advantages i)    Procedure proposed is quick, simple, requires only small fee to ecologist (tiny vs. estate agents’ commissions, tax, etc) (ii)  and reliance on certified-honest EBGs breathes whole new life into public awareness and consciousness. 4)    5)     Every case is local. No trade-offs. No tariffs. Every site is a one-off. No future undertakings. No market in these credits.        Instead of any covenants, the concept of permanent responsibility. Covenants can be broken, lead to lawsuits. Forget it. 6)     (Answers to government questions:)         (i)   Should a baseline map of broad habitats be developed? Yes.  Sounds expensive but local associations, and the ecology profession might be able to come up with it: Quick letter to all parish councils, offering services of registered EBG’s (ecologists) might be an idea. IF PCs don’t reply with intention in four weeks, move up the scale of council size.         (ii) Assessment is always by an EBG.    Legal powers = s/he decides.     5 or 10% IVG (Intangible Value Gain) a possible aim. (ii) Mandating net gain through the planning system – by this method – will be enough.



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Biome Valuation
(a)
There should be a clear, sensible and easily executed ‘valuation’ of the existing life and biodiversity existing on a site.
Not monetary, but in the intangible Biome Value (BV)
  – (to be a legal concept in the legislation: BiomeValue would be a special case of IV (Intangible Value).
This could be achieved without great expense by calling a consultation from a professional or ecologist
– from a group of people could be familiarized with the concept and the need.
Members of this group should be in a list approved by /an organization/s such as
 
Friends of The Earth,
CPRE,
CivicVoice,
Locality.com,
CoVop (community Voice on Planning),
Open Spaces Society, etc.
– there are several other, such reliable organizations, incl. local. 
– or preferably 2 of these.
There are many others that could be admitted to the list.
They must all be known and long-established, and obviously appropriate committed
(This would be to guard against even the ecology profession being ‘bought’.)
 
Approval by such org.s would establish membership of a legal category of ‘Established Biodiversity Guardian’ (EBG).
 
A simple scale of A to E could be adopted. An experienced ecologist would allocate this mark quickly:
 
Type
 
BV score
A1
All of: (a) sole habitat of a specific species;
          (b) habitat literally unique; and
          (c) some other element completely unable to be replaced or duplicated elsewhere;
BV=10
 
A2
two of (a), (b) and (c);
9
A3
either (a), or (b) or (c);
8
B50
none of the above but a biome
unable to be reproduced elsewhere by simple implantation within less than 50 years;
7
B20
ditto but 20 years;
6
B10
ditto but 10 years;
5
B5
ditto but 5 years;
4
C
biome reproducible, but any compensating area elsewhere to be:
(i)   as per strict spec and instructions from, and subject to oversight and final approval by, the EBG;
      subject to  (a) severe fine for non-compliance,
                      (b)  and/or withholding of final habitability permission
(ii)  Option (b) is recommended.  Best to exclude money tariffs or penalties,
                                               but require EBG final approval before sale or occupation is allowed / valid in law.
Provided builder acts sensibly this will be smooth and painless.
3
D
Biome with no special needs – immediately reproducible.
 
 
E
No biome present (eg existing asphalt only); or 100% expendable.
 
 





 
          In all cases of A, and B1, B2 ,B3:  breaking ground (or cutting trees) would not be allowed. 
 
Trees
  There would be a Tree Protection Category (TPC) – the 3 categores are T1, T2, T3.
T1 =         100% must be kept.
T2 =         limited felling allowed in accordance with opinion of EBG (who must specify) – this opinion will have force of law.
T3 =         EBG accepts any degree of felling.
  EBG may vary the TPC on separate parts of the site.
 
Watercourses
  EBG shall specify (with force of law) value of Watercourse:  
W1 =        irreplaceable
W2 =        EBG specifies action (with force of law)
W3 =        Action free
 
Prohibitions
            For A, and B50, B20, B10 breaking ground (or cutting trees) would be not allowed.

Should there be any specific exemptions to the mandatory biodiversity net gain requirement
(planning policies on net gain would still apply) for the following types of development? And why?
 
Private house extensions (small scale, individual ‘gardens’ up to say 2,000 sq ft (?) – no requirement.
Requirement waived only when “Brownfield” is genuinely brown = is category E.
4
Are there any other sites that should be granted exemptions, and why? For example, commercial and industrial sites.
No: this is a rule for wherever there is biome.
Gives a little income to professional ecologists;
and if executed with calm and sense heightens awareness of populations that this sort of thing is possible.
Thus gives PEOPLE a SENSE of POWER – an essential element required for revitalizing UK planning.
5
As an alternative to an exemption, should any sites instead be subject to a simplified biodiversity assessment process?
Yes
Please provide any explanation for your answer here:
As above in questions 2 and 3.
 
3         
4        .
5         
6        Do you agree that the Defra metric should allow for adjustments to reflect important local features such as local sites? Should the Deframetric consider local designations in a different way?
Don’t know

Please provide any explanation for your answer here:

I have not allocated time to read info (if any) in your intro about Defra metrics, above, but just stick to the principles I have outlined.

Simple. Easy.

No ifs, no buts, no prolix legislation to interpret.

Just the categories, and approval of EBGs by the NGOs etc named, plus others;

and these powers for EBGs.

7        Should local authorities be required to adopt a robust district level licensing approach for

          great crested newts, where relevant, by 2020?

Don’t know.

Explanation

Not familiar with GCN’s – so probably covered by my responses above.

Please provide your answer here:

Rely on my principles proposed in answers above.

The proposal sounds fishy – like a way to get a Full Council to Vote Round some vital need such as opposing a motorway etc.

Therefore I am opposed. Dilutes required LOCAL power.

Yes

WITHOUT allocating cash value, a system of Valuation of Intangible Gain should be devised.

The Intangible Gain Value (IGV) should be a requirement of any development

– but its exact nature and ‘quantity’ or scale should be DICTATED by local community, preferably at Parish Council,

with ASSUMPTION IN FAVOUR of 100% obedience to objections or requirements raised by LOCAL people

Local People being DEFINED AS same street, + <200 yards ‘radius’ drawn from all points on that street.

And in the case of a public park, Parish, City, District AND county council must ALL approve, and specify IGV.

IGV may be expressed in a convenient nationwide unit – requires some thought. ·  

 

Measuring biodiversity

  1. Is the Defra biodiversity metric an appropriate practical tool for measuring changes to biodiversity as a result of development?

No

          Explanation:

          Use assessment by EBGs (Established Biodiversity Guardians) – members of ecology profession – as per answers above

          – and give them LEGAL POWERS as stated.

  1. What improvements, if any, could we most usefully make to the Defra metric?

          Do not use it.

          Use assessment by EBGs (Established Biodiversity Guardians) – members of ecology profession – as per answers above

          – and give them LEGAL POWERS as stated.

  1. Would a mandatory 10% increase in biodiversity units be the right level of gain to be required?

Yes

Explanation:

Use local assessment by EBGs (Established Biodiversity Guardians) or – as stated above – adapt the 10% concept to fit.

Perhaps 10% increase would be measured in the language / scale of the VIG (Valuation of Intangible Gain) as defined above.

  1. In clearly defined circumstances, should developers be allowed to pay through the tariff mechanism without fully exhausting on-site and local compensation opportunities?

No  (mistyped as ‘yes’ in pdf submitted)

Explanation for your answer here:

No – would be done by ecologist as defined above. Permission to occupy would be withdrawn until EBG approval of completed “works”.

  1. Would this be an appropriate approach to directing the location of new habitat?

I don’t know – Explanation: Question not clear, seems irrelevant.

Certainly tariff not acceptable idea. People in big business are masters of money.

  – Too easy for them to seek to compensate in money. That’s not the point.

15      How could biodiversity assessments be made more robust without adding to burdens for developers or planning authorities?

Please provide your answer here:

Procedure proposed is quick, simple, requires only small fee to ecologist

(tiny compared with estate agents’ commissions, tax, etc)

– and reliance on certified-honest EBG’s breathes whole new life into public awareness and consciousness.

  1. Should a baseline map of broad habitats be developed?

Yes

Explanation:

Sounds expensive but local associations, and the ecology profession might be able to come up with it. Quick letter to all parish councils, offering services of registered EBG’s (ecologists) might be an idea. IF PCs don’t reply with intention in four weeks, move up the scale of council size.

  1. Should this be applied, as a minimum baseline, to:

Please provide any explanation for your answer here:

Every case must be local.

Assessed by an EBG.    No ‘suspected’= s/he decides.     Yes to assume 5 or 10% IVG (Intangible Value Gain).    Follow principles given above.

  1. What other measures might reduce the risk of incentivising intentional habitat degradation?

Please provide your answer here:

I think this proposed scheme is adequate.

19      How can the risks of penalising landowners making legitimate land use change decisions before deciding to sell their land for development be mitigated?

Answer:

Requires complete rethink of things such as

              (e.g.    heavy stuff, such as community gets 60% of gain in value, for example,

                         or SOLID requirements for social housing at TRUE social rents in all developments.

          SEE     the luxury Foster Albion Riverside dvt on the Thames with exquisite keyworker housing also designed by Foster behind it,

                               (negotiated by Dickon Robinson when head of Peabody)

              or     https://www.fosterandpartners.com/projects/albion-riverside/#gallery     and   https://tinyurl.com/yyl327bk

Also see CityVoice article on completely upending the planning system based on a bias in favour of a system based on absolute rights for locals:

https://www.cityvoice.co/nppf-response-upend-the-system

Delivering biodiversity outcomes

          At what scale should these maps bedeveloped?

          Locally (e.g. local authority or National Character Area)

    Explanation:

PARISH COUNCIL level.

1.       Gvt writes to all PCs requesting they be the prime supplier of input.

2.       Gvt offers services of   – local EBG ecologist, free of charge.

3.                                         – S/he does the survey.

4.       IF PC does not respond gvt escalates upwards the councils at 4 week intervals.

          OR Instructs County Council or lower echelon to do this STARTING with PARISH councils.

These initial EBG services provided free by the nation. One-off.

    Please provide your answer here:

          Raising ‘priorities’, as an idea, immediately gives a weasely local council an opportunity

                – an opportunity to wipe out one or other local situation on pretext of priorities or ‘that it itself will make a compensating decision elsewhere’.

No.

ALL LOCAL.

Site by site.

As described above.

Yes

          Please provide any explanation for your answer here:

          Not clear whether biodiversity units this means

                               – Units that operate and provide advisory on BD

          or                  – a VALUE UNIT you may have described in your intro.

I am against credits and tradeoffs.

Each site, each applications, is a one-off. Site by site.

As per scheme above.

23  What further measures would help to ensure that the market provides:

a. Sufficient biodiversity units for development?:

So – It looks increasingly like that you mean a UNIT OF VALUE that you may have described in your intro.

      – and such as the proposed system has devised in

          IVG (Intangible Value Gain)

                 – subcategory = Biome Value Gain  (not ‘Units’ in the sense of ‘Offices’ that operate and provide, e.g., advisory on BD)

              I am against credits and tradeoffs.

              Each site, each application, is a one-off.

              Site by site.

                – As per scheme above.

I am against a market in said credits.

Creating a market for good advisors on BD is good.

          b. Cost-effective biodiversity units?:

Don’t understand this.

No market in credits allowed.

Each deal is local as described.

Other (please provide an explanation)

It should be large.           Good question.        Discuss at “committee stage” !!

Ideas: permanent.          If owner lets it slip, suffers some kind of SERIOUS tax charge or disadvantage.

d. Permanent

Explanation:                       Sorry to say, on reflection, it’s got to be permanent.

Responsibility is responsibility; etc.

But keep for “Committee Stage”.

Answer: Other (please provide an explanation)

Please provide explanation:

Better than covenant, merely use permanent responsibility, with severe tax or other financial sanction if not complied with.

See the whole system described above.

Covenants can be broken, they lead to lawsuits. Forget it.

Better than covenant, merely use permanent responsibility, with severe tax or other financial sanction if not complied with.

See whole system described above.

Covenants can be broken, lead to lawsuits. Forget it.

Calculating and collecting the tariff

          Not Answered

    Please provide any explanation for your answer here:

          Don’t use tariffs – use the complete and 100% system set out above.

          Developers can play around with tariffs etc., but not with:

                      à   defined site-by-site requirements

          and      à  severe sanctions (eg withdrawal of planning permissions),

          – if not complied with.

          Not Answered

    Please provide explanation:

          Don’t use tariffs – use the complete and 100% system set out above.

          Developers can play around with tariffs etc., but not with:

                      à   defined site-by-site requirements

          and      à  severe sanctions (eg withdrawal of planning permissions),

          – if not complied with.

Do you agree with the proposed principles for setting the tariff rate, as set out in this section? Please suggest any other factors thatshould be taken into account.

          Not Answered

Please provide any explanation for your answer here:

Don’t use tariffs – use the complete and 100% system set out above.

          Developers can play around with tariffs etc., but not with:

                      à   defined site-by-site requirements

          and      à  severe sanctions (eg withdrawal of planning permissions),

          – if not complied with.

How should the tariff revenue be collected?

          Not Answered

Please provide any explanation for your answer here:

Don’t use tariffs – use the complete and 100% system set out above.

          Developers can play around with tariffs etc., but not with:

                      à   defined site-by-site requirements

and    à  severe sanctions (eg withdrawal of planning permissions),

          – if not complied with.

How should the tariff revenue be spent?

          Not Answered

Please provide explanation:

Don’t use tariffs – use the complete and 100% system set out above.

          Developers can play around with tariffs etc., but not with:

                      à   defined site-by-site requirements

          and      à  severe sanctions (eg withdrawal of planning permissions),

          – if not complied with.

          Not Answered

Please provide any explanation for your answer here:

          Don’t use tariffs – use the complete and 100% system set out above.

          Developers can play around with tariffs etc., but not with:

                      à   defined site-by-site requirements

          and      à  severe sanctions (eg withdrawal of planning permissions),

          – if not complied with.

Delivering net gain in the planning system

Please provide your answer here:

System as proposed above is self-sufficient.

          And oh by the way: after the initial mapping assessment      – (approved by EBG ecologists, paid for by central government) –

          it’s the developer who pays for the IVG (Intangible Value Gain (etc.)survey and all the ecologist’s services.

Please provide your answer here:

          No relation: separate system, self-contained and watertight for EACH SITE only.

          Not Answered

Please provide any explanation for your answer here:

          (i)

          No ! don’t allow central government – or even local government – into any financial or credits scheme !

          (ii)

Dont use tariffs – use the complete and 100% system set out above.

          Developers can play around with tariffs etc but not with defined site by site requirements and severe sanctions (eg withdrawal of planning permissions) if not complied with.

Please provide your answer here:

          System proposed herein is self-sufficient.

Please provide your answer here:

          System proposed herein is self-sufficient.

Please provide your answer here:

          No.

          Purpose of Planning system is not to facilitate dvlprs (or otherwise)

          It is to provide an environment that is sane, fair, beautiful and useful.

          Sane and fair includes not abandoning public or private Intangible Value Units as conceived above.

          Simple.

          Scheme proposed here is constructive and sensible. Complete.

          Not Answered

          Please provide your answer here:

          No.

          Staggered transitional arrangements smells of cop-out.      Not needed.

          Proposals above are simple, fair, practical, reasonable, functional, advisable.

No

Please provide any explanation for your answer here:

No.

All goes into hands of local EBG (Established Bio Guardians) as described above.

No disagreement. EBG is king. Note who chooses him (above).

No

Please provide any explanation for your answer here:

No.

All goes into hands of local EBG (Established Bio Guardians) as described above.

No disagreement. EBG is king. Note who chooses him (above).

Monitoring and evaluation

Please provide your answer here:

No.

System provided above is a sure, complete and reliable backbone.

Yes

Please provide any explanation for your answer here:

Could include this as responsibility of the EBG.

But LA would have near zero cost.

Local authority could hold a single standardized website page (paid for by central government) on to which registered EBGs would be obliged to file their reports and data numbers as part of their procedure.

Please provide your answer here:

Web filing system and EBG responsibility as per 44 above.

Key evidence gaps

G  We would welcome further evidence that addresses the following identified evidence gaps. Please submit evidence, or related enquiries, below or to netgainconsultation@defra.gsi.gov.uk.

Please provide any relevant evidence here:

On implementation cost, system proposed is self-expl., and self-sufficient financially.

Only cost is for local authority to host and presumably keep an eye on website ( IT could be provided by central government, for example ).

Simple, clear, easy, sensible, almost zero-cost.

Please upload any relevant information in common word, PDF or spreadsheet formats. Other formats may be uploaded, but might not be reviewed.: No file was uploaded

Consultee feedback on the online survey

F  Overall, how satisfied are you with our online consultation tool?

Very satisfied

Please give us any comments you have on the tool, including suggestions on how we could improve it. :

If author (SF) had not been stimulated to do this (by a leading commentator in the campaigning sphere (Stella Stafford?)), he would not have considered the subject even a feasible subject for discussion. Regarded the subject as arcane, abstruse, difficult, etc etc.

THE EXISTENCE of these questions posed in this way has enabled the creation of a GOOD, NEW system – that is practicable, fair, cheap, robust – and thoroughly attractive – and puts the responsibilities and authorizations in the right places.

Note: This author would never have created this without your questionnaire – So – thanks and CONGRATulations.

Additional requirements

By the way – in NATIONAL projects – HS2, alleged @OxCamArc, etc., the SAME procedure applies except that here, where the developer is the government, yes the government has to undergo EXACTLY the same procedure, and obligations, and sanctions, etc (e.g. highway can be cancelled by High Court) in the event of non-compliance.

In these cases, jurisdiction is exercised LOCALLY. FIRST each parish council along the route gets a say and procedure, this escalates up the LG levels if PC does not reply, as stated above.

Power is NOT automatically given to large even elected bodies, e.g., district and county councils that can so easily make mistakes. The beacon, torchlight and gatehouse power, and power to sanction, is set firmly in the hands of a series of LOCAL inspectors, the EBGs.

About the author

[ Author is: SF : Editor@city-voice.org

( Twitter : @CityVoicEd )  07866 470 409  2nd Mobile and whatsapp +55 11 9 3346 4762   also +55 11 3042 1962

( CITY VOICE was founded in 1976 to defeat Siefert’s Trafalgar square – success! )

( Commitment and passion, and sense of people-power and detail, acquired from D and C Robinson, as Secretary of the Soho Society) ]

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