Biodiversity Net Gain must not be weakened

Biodiversity Net Gain must not be weakened

Ludgershall Meadows by Andrew Marshall/Go Wild Landscapes

A recent win for nature is under threat from proposed changes for developers

Following consecutive years of reporting on the depleted state of our nature and the erosion of environmental protections, new regulation introducing world leading ‘Biodiversity Net Gain’ (BNG) was a welcome moment, giving renewed optimism for nature restoration across England. 

Just two years on, the Government’s approach to stimulating GDP growth by building all over Britain is sending nature to the top of the risk register.

What is BNG?

The purpose of BNG is to ensure that the environment across the whole of England is improved by development and not diminished by it. 

BNG requires developers to deliver a 10% uplift in biodiversity post-development against the level of biodiversity pre-development. This BNG requirement sits on top of all existing environmental rules, it does not weaken protections but facilitates the creation of new habitats.

Biodiversity uplift can be delivered within the development site or off site, judged by applying the mitigation hierarchy; meaning, if the offset is to occur off site, developers can pay for biodiversity gains on land they do not own. 

BNG and BBOWT

At BBOWT we have worked with partners, local authorities, and developers to create two habitat banks - Duxford in Oxfordshire and Ludgershall in Buckinghamshire; enabling us to provide suitable land for developers to discharge their BNG obligations.

Duxford Habitat Bank

The current biodiversity value of Duxford is low, making it an excellent candidate site. Over the next 30 years we will implement a nature-led management approach applying conservation style grazing to drive the establishment of functioning ecological processes. 

A mosaic of key wetland floodplain habitats will be created plus areas of neutral grassland, broad-leaved woodland, and mixed scrub. This will create a range of ecological niches in which wildfowl, waders, songbirds, and specialist wetland invertebrates can thrive.  

Duxford will form part of a wider nature reserve complex extending to over 350ha. BNG has the potential to create nature’s recovery at scale through habitat creation and restoration and wider landscape connectivity.

Ludgershall Habitat Bank

The floodplain meadows at Ludgershall were once traditionally ploughed into ridge and furrow, which created diverse micro habitats for dry and wet plant specialists. 

In recent times the ridge and furrow topography has been damaged by overgrazing resulting in a reduction in floristic diversity. We have reintroduced a traditional hay meadow management regime with mid-summer hay-cut and aftermath conservation grazing to help increase the diversity and abundance of the key perennial herb species and sward structure which will boost overall biodiversity gain.

Now all of this has been thrown into doubt.

Marbled white on thistle with bulldozers in the background

Marbled white on thistle by Terry Whittaker/2020VISION

The future for BNG?

The Government is consulting on whether BNG should continue to apply to small developments and whether more developments should be exempted. 

Currently, small sites are generally developments with nine houses or fewer, although the consultation is also looking at changing the rules for developments of up to 49 houses. If small sites are removed from BNG, potentially around 80% of demand for BNG units will be wiped out. 

We will see no more Ludgershalls or Duxfords and we will be taking a huge steps backwards in our environmental ambitions.

At BBOWT, the vast majority of BNG enquiries we get from developers relate to small developments that have followed the mitigation hierarchy and now need to provide biodiversity uplift offsite to meet their planning conditions. 

We are able to aggregate these smaller BNG requirements and deliver larger strategic nature recovery projects, such as Duxford and Ludgershall. The process for delivering this service for all stakeholders from the developer through to the determining authority is simple, efficient and accountable to ensure that it integrates well with our broader aims and core purpose as a nature conservation charity. 

BNG works for developers and nature

BNG has only been mandatory for just over a year and already the system is growing and improving to deliver long term measurable improvements for nature. 

In addition, BNG is creating positive dialogue with developers whose awareness and understanding of biodiversity and the nature crisis is increasing as they are required to put into practice measurable activities to restore nature. 

The system is working but the Government risks destroying all this progress.

Bizarrely at the same time as undermining confidence in BNG, the Government is attempting to attract private investment into nature markets. This strategy will be fundamentally undermined, contradicted and irreversibly damaged should BNG regulation be weakened and small sites excluded from the market. 

Nature markets need consistency of regulation in order for stakeholders to invest their time and resources at scale. 

Habitat banking providers like farmers, landowners and the Wildlife Trusts have enthusiastically and tangibly invested into BNG in the belief it can help restore nature and provide a robust platform for private investment in the recovery of nature. 

Government worked extensively over many years with a broad range of external stakeholders to create the framework in which BNG would work. If this Government dismantles that framework, private investors will not further expose themselves to such schemes again and nature would suffer as a result.

Mixed messages for nature

This undermining of BNG comes at the same time as the Government is pushing through its Planning and Infrastructure Bill which Professor Dasgupta, who wrote the Government’s paper on the economics of biodiversity, says will undermine “the core value and purpose of nature markets, which is to halt and reverse the decline of nature, not accelerate it.”

BNG is a world leading policy and many countries are looking to us and studying BNG as a “best practice” model. 

At BBOWT we have had practitioners from as far afield as Japan asking us how our habitat banks work and requesting visits to our new nature reserves.

I will admit that I am confused about the Government’s objectives and actions. They say they want to increase private investment in nature, yet at the same time they characterise nature as a blocker to growth. 

Whatever their objectives, their current actions will harm communities, harm development and harm nature.

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