The publication of the Environment Bill in October 2019 saw the subject of biodiversity net gain “get real”, with a commitment to the introduction of mandatory net gain for all new developments.
Simply put, this will require developers to provide evidence of the pre and post development biodiversity values of their site. Based on these calculations they will then have to prepare a biodiversity gain plan to demonstrate that either through a biodiversity focused design of their landscaping, open space and other habitat opportunities they are able to show a 10% increase in biodiversity value.
If they are unable to do so they will need to demonstrate that they are able to secure offsite biodiversity gains that can be allocated to the development, or purchase biodiversity credits from the Secretary of State.
At present it is proposed that the value of biodiversity on the site is measured using the Biodiversity Metric that has been developed through the recent Defra pilot project. It is fair to say that there is still considerable concern around this metric from many parties, including some leading operators in the environmental sector. They feel that the current iteration of the metric is still needs further refinement in that many habitats, that will over their lifetimes deliver high quality environmental gains, are unfairly down weighted. As a result this would see the creation of amenity grassland scoring more highly than most other habitats, in particular woodland and parkland/wood pastures that are deemed to take longer to create.
With others including Forestry Commission, the Woodland Trust and the National Forest we have sought to highlight these issues to ensure they are addressed before this policy becomes law.
We would encourage all landowners and developers bringing schemes forward to take the opportunity, whilst the new metric is out to consultation, to run some test calculations on real example sites and feedback to Defra so that hopefully the final version is more fit for purpose.
Many developers and consultants are already using Metrics, with one of the best and most advanced examples being the Metric developed and used by Warwickshire Country Council and the Environment Bank.
Although well understood and certainly more transparent, this issues around habitat still exist.
Biodiversity Net Gain as against Environmental Net Gain
One of the key arguments against simply focusing on biodiversity is that you can miss the real target of the wider, some would say more sustainable, goal of wider environmental net gain. By focusing on biodiversity there is a real danger that wider environmental benefits could be affected, for example:-
- Clean air;
- Clean water;
- Carbon sequestration;
- Flood prevention;
- Soil protection;
- Food/Timber production;
- Physical health and well-being;
- Landscape; and
In their own consultation document the government admitted that biodiversity net gain is unlikely to be the best way to deliver wider environmental objectives.
However, given the complexities of a holistic environmental approach they have reverted to a simplistic biodiversity focus, which on initial inspection looks to be seriously flawed on many levels.
There are some good news stories that are really starting to look at the wider environmental net gain and use this to shape the development options.
In North Northamptonshire we have been supporting the Joint Planning Unit in conjunction with East Northants Council in pioneering a Natural Capital led approach that was recognised at the recent planning awards.
- Click here to view the Eco-System Assessment and Valuation reports for the Tresham Garden Village.
- Click here to view an article confirming that this work had been highly commended at the recent National Planning awards.
We have also been involved in assisting the Cambridgeshire Local Nature Partnership (Natural Cambridgeshire) has been developed the “Developing with Nature Toolkit” which again aims to look much more widely than pure biodiversity and focuses on engagement with key stakeholders and a proactive response to the wider green infrastructure networks.
This has now been adopted as policy by both Peterborough and Cambridge and South Cambridgeshire Councils.
Natural Cambridgeshire and the stakeholders see this as a key element of the aspiration to see a doubling of nature across the county and this is highlighted in their publication “Doubling Nature – A Vision for the Natural Future of Cambridgeshire & Peterborough in 2050”. A copy of which can be downloaded here.
Actions to undertake now
In light of the above we feel it is important for those parties whom are likely to be affected act now now, and in particular take steps to:
- Understand the baseline position for your sites and ensure that these are managed effectively to develop opportunities and control risks.
- Undertake trial assessments on existing and new projects to ensure that you effectively feedback in to the current consultation.
- Understand the cost implications of both the development of, and purchase of biodiversity credits.
- Understand the impact on place and value of a shift of focus from wider public benefits to biodiversity.
We are right at the heart of these debates, with Chairman John Lockhart taking the lead on behalf of the company. If you would like to discuss any projects with John please contact him on 01536 408840 / [email protected].