Biodiversity Net Gain (BNG) forms a core part of planning approval for many new housing developments, calling for at least a 10% measurable improvement in habitats on or off site to ensure that development leaves biodiversity in a better state than before.

But exactly what is it, why it’s been brought in, and how can homebuilders stay compliant?

Chris Gaze's guests for this episode are:

• Becky Moberley from the Planning Advisory Service
• Paul Dodd, Head of Design Advice at Urban Design Learning.

Get all the latest hints and tips on BNG here.

Mentioned in this episode:

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Hi and welcome to the Future Homes podcast.

My name is Chris Gaze and this is where we look closely at the ideas, policies and practical challenges shaping how homes are being designed, built and delivered in the UK today.

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Our focus this time is all about biodiversity net gain, which has been a real challenge to many. Our guests are Becky Moberly from the Planning Advisory Service and Paul Dodd,  Head of Design Advice at Urban Design Learning.

I kick this chat off by asking Becky, why does BNG matter?

There are several answers to that one, but I think the key one really is because we're in a biodiversity crisis.

You know, there's been nature conservation policy and legislation around for a long time and in the end it hasn't worked to stop that crisis happening.

So as things continue to get worse, actually, the uk, which often surprises people, is one of the places in the world that is most deprived in terms of its biodiversity. So it's a particularly important in the uk.

So, yeah, it's just really around that sort of wider context, around the biodiversity we've lost already and how do we address that? But I think there's a couple of other answers as well.

I mean, one of them you could say is just you've got to do it because it's required and it's been required for two years. Another one is just the wider benefits that biodiversity brings.

It's as simple, actually, as just even things like looking at a tree from your hospital window can make a difference to how quickly you recover. There's so much more evidence now around, you know, how green stuff and nature makes a difference to us, both in terms of mental and physical health.

But, you know, there's all sorts of other benefits around, you know, air quality, etc. And I think there's just huge amounts of evidence now, particularly on that sort of physical and mental health side of things.

And actually, from a developer point of view, it can help bring local communities on board if you demonstrate biodiversity net gain.

And it's one of the things that some of the developers who started early on, before it was required, they very much came from that perspective, was like, well, if we're concerned about local communities that perhaps don't want housing or something built near to them. We can persuade them by, you know, demonstrating the value that we bring in terms of things like biodiversity net gain.

So we talked about, you got to do it, you have got to do it anyway.

Yeah.

So when we look at that, what are the, you know, if you were asked to sort of sum up the policy, what's it mean, doing biodiversity net game, what do we have to achieve?

I mean, basically, you've got to get 10% more biodiversity as part of your development than you had to start with. So you've got to get at least up to where you were before and then another 10% and that preferably on site, so within the development footprint.

But as a second step, you can go off site, so you can look beyond your development site or buy units from a habitat bank. And then there's a last resort is a credit scheme that's run by Natural England. But in the end, you've got a kind of.

Your balance sheet has got to add up to 110%. So that involves measuring what's on there before you start development, predicting what you're going to have afterwards.

The other thing that's really important is that for all off site biodiversity net gain and for on site biodiversity net gain, that's significant, you have to secure that for 30 years as well. So there's 30 years management and monitoring of that. So, yeah, I think that's a. I don't know if. Have I missed anything, Paul?

I just had a couple of things, actually.

We talk about nature and the loss of nature and the challenge we have with that with communities at the moment, the mhclg, they've got their draft consultation out for MPPF and for the design and placemaking planning practice guidance. Further, there was a mouthful, but that's a DPP pg.

The title's challenging, but what's interesting is in there, the government have set out quite clearly what the seven features of well, design places are. One of those elements is nature. The other one of those elements is climate.

And when you wrap up with livability, identity, public space, build form, movement, you put all of those together, you consider all of those at the right time. What you get is sustainable development, you get well designed places.

The key thing really is how it's one piece of the pie that delivers something which is livability and good homes and sustainable homes for people.

Yeah, great places to live and. Yeah. And over the emphasis on place.

I'm an engineer, I tend to think about the building you know, and it's about saying, look, it's far more than that and we've been on a journey with bng. I was wondering if you could give us a bit of the background of how we got to where we are and what sort of things we're looking at in the future.

Yeah. So, I mean, I guess if we go way, way back, biodiversity net gain started as a biodiversity net no net loss approach.

So basically, make sure you have at least as much biodiversity as you started with in the end. So where you're going to impact on biodiversity, you will be creating or enhancing habitats to make sure that you end up your balance sheet at zero.

There was a bit of negative feedback about offsetting and it was seen as a bit of a way to pay to damage, which it wasn't necessarily, but that's sort of how it came. And actually the private sector then really took it up.

So actually quite a lot of developers and some local authorities started taking forward, first of all, biodiversity, no net loss, and then biodiversity net gain.

And then in terms of where it's going, I mean, I guess we're still learning.

There's been various studies that have looked at what was brought in before it became mandatory and perhaps there's been some critique around that, perhaps particularly on site biodiversity net gain and how it's been secured. And we're still very much learning.

And that's, as Paul said, you know, that's where this good practice comes in, is around, you know, how can we learn from each other? But we've also got some changes coming imminently.

Government has just published a couple of responses to consultations which were out last year, and also a consultation on residential brownfield. So we're looking at some. Some tweaks in terms of the exemptions. And I think what's really good there is just, you know, learning from how it's going.

There were some challenges. You know, it's still not. It's. It was a huge change to the way the planning system works and the way things are delivered.

And so just learning from that, and particularly for very small sites, it's proving particularly challenging.

So one of the big changes that's coming in is an exemption for sites of 0.2 hectares or less in size and helpfully, hopefully address that where really those sites are tending to take a lot of time and resource.

And so when Paul's talking about local authorities being under resourced, you know, they take a disproportionate amount of time and resource and actually for the biodiversity benefits you get, it's not really worth it. So hopefully will mean more time can be spent on the larger sites. But yeah, we're definitely, we're definitely still learning.

So as it goes along, even if it's even things that stay as they are, you know, I think we'll get better over time and it's not going to be perfect, but it's definitely much, much better than what it was before.

And that's what I always say, you know, let's not make perfect the enemy of the good with this, because we do need to have to learn by doing, really, don't you?

It's incredible. It's just been two years, really, and such a lot of experience and development has taken place in those. Those two years.

One of the big challenges with local planning authorities was at the early stages of BNGs, how do the authority align the regulation, the BND regulations, with planning process development management? Because it's a regulation, development management's a slightly different thing around relating to policy, perhaps in the local plan and so on.

And so aligning those two things through what the planning application process.

And as you know, Chris, it's quite a complicated process to go through was a big challenge for local authorities and they've learned from, from each other in terms of how they navigate that, how they align resources at different stages of the process, how they train their officers in understanding of what BNG is, even where they're perhaps not an ecologist or an expert in BNG at all, but rather they're doing a planning function, perhaps it's validation or whatever it might be for the planning application.

It's that balance, I think, between policy and legislation that's really tricky.

And we see that in other areas of, you know, for example, nature conservation, legislation, it's how do you balance, you know, because you generally, as a planner, for example, you'll look across and, you know, weigh up the different aspects. But when you've got a legislative requirement, it's sort of how does that come in and how pragmatic can you be?

Because in the end, you know, when you're dealing with a particular development site, there's always something different to think about and how, you know, and it's. But it's, it's more tricky to be Pragmatic when you've got this sort of legislation.

So in some ways it's been really great having that legislative angle because it's, you know, it's got folk up to the same level and a lot of thinking about it, but sometimes it can pace some frustrating constraints. But I think what's really great hearing from the good practice is how it doesn't have to do that. With experience and confidence you can work.

And I think, you know, the big thing we've learned isn't it, Paul, is around that collaboration because actually, even with legislation, it doesn't give you yes, no answers. And as planners, you're often making decisions on the margins. It's not a yes or a black and white, it's a oh.

And I think sometimes people expect BNG to give you a yes, no answer. It doesn't. And ecology doesn't, you know, the natural environment's weird and complicated and mad. You have to work it out.

And I think working together is going to be the best way to do that.

And from the local authority side, have they got the capacity to cope with something that's this complicated?

It's a super challenge for local planning authorities, as we know that the budgets are ever tighter and tighter, that the expertise that is required for BNG is different. It's specific expertise around ecology primarily.

We know that that is a sector where there are fewer experts, so they are struggling and they are challenged with it.

But what they are doing and what's clear from us, particularly those authorities that are doing really well, they're addressing, they're dealing with issues around the planning balance, as Becky mentioned, and they're also dealing with a small amount of resource that they need to challenge in the most efficient way to deliver what they're required to deliver through the regulation.

And really, it's kind of enabled the green side of planning really to kind of shine because it's an opportunity to deliver nature recovery, to deliver great, well designed places.

I do hope that actually the changes that are coming through may make things a bit easier, just because it will allow, you know, that focus on some of the stuff that's perhaps more significant in terms of its importance for biodiversity. So, yeah, I mean, and other things as well.

And I know that Paul's been looking at the good stuff. What does the good stuff look like, Paul?

I mean, what are the takeaways for both local authorities, but also for developers from the work you've been looking at?

Yeah, that's a good question. What are the key takeaways? We've Done five reports looking at five different areas.

We've looked at local plans, good advice in local plans, local policy. We've looked at good practice in monitoring and enforcement and developing habitat bank protocols.

We've looked at good practice of LPAs and APCAs working together and we've looked at faster decision making. The key things really are developers need to understand the requirements of BNG foresight at the absolute earliest stages.

And it this actually will be perhaps even before you've purchased a site. You need to have an understanding of the cost associated with BNG and how you might manage the process, purchasing, valuing it.

And then when you start going down the route of planning, the key thing, the key learning really is to start early. Get your ecological baseline in as early as possible, look at what the challenges are, speak to your local planning authority as early as possible.

We always recommend doing performance agreements for planning to start conversations early. In terms of pre apps, we've found that good practice typically involves pre application processes.

And in that buying process, I mean, you've got two things, haven't you? What's the state of the land now?

I mean, so it could be a brownfield site with really great bng, but frankly you're going to do a load of remedial work to it because it may be a great place for the plants, but it's not necessarily a great place for the people to live until you've done the remedial work.

Or it could be on a floodplain and then you have to lift up the site, at which point you presumably will lose loads of BNG and you'll suddenly find yourself way back from where you need to be.

Yeah, absolutely.

And you know, BNG's, there's a hierarchy and if you are looking at developing on land in floodplain that's adjacent to watercourses and wetlands, and so then you will be hit very hard in terms of bng, in terms of how you might mitigate that impact, because the impact is substantially negative for nature.

So, yeah, when you start looking at your land banking, you will probably want to prioritize previously developed land, urban land, and less likely any land that's associated with local nature, protected species and so on and so forth. And that's the earliest point of decision making. Greenfield sites as well typically do have quite a bit of biodiversity involved in them.

Yeah, yeah.

I mean, and do local, I mean, do local plans take that into, I mean, have they been taking that into account, that going well, actually, if we try and develop this brownfield site, it's going to be really tough potentially because actually there's this biodiversity there.

Well, I think when in the plan making, when local authorities looking at plan making, they do prioritise those locations that have previously been developed, whether they have things like open mosaic habitats in there and so on. They're also looking at sites which developers are bringing forward and lobbying for.

I think the question is for developers really is to look at the sites they're thinking about and really factor into what the BNG regs are and how it impacts on them and how it impacts on their cost. Because we know that there's a huge challenge in this country in terms of the cost of development.

Part of that is to understand what the risks are associated with green infrastructure.

And if you're looking at a couple of sites and weighing it up and one perhaps has less green infrastructure in there already or biodiversity, then it may be an easier win to get yourself through planning if you choose those sites first.

Okay, and so what are the other good practice things that we should be that you've been seeing and looking at.

Some of the bigger developers that are building quite phased master plans.

Some good practice that came from them really was to consider how you frame BNG in the wider narrative for wider community and existing residents, for local authority officers, but also for the political side.

So rather than just reducing BNG to a regulatory requirement, the narrative is about well designed places because we found those developers that do that, they're able to offer a higher value product at the end of it because those that housing is embedded within a much more attractive environment. So it's a win for nature, but also it's a win for the people who would like to live there. And therefore it comes at a premium.

We also talk about liaising with local authority planning officers regularly and all the way through the process. And I think local planning authorities have been really good at this.

Not necessarily having formal discussions all the time that require written commentary, but rather ad hoc conversations about getting on the telephone like we used to do.

Chris we got on the telephone and we found where people have been having human relationships with each other that respect each other's positions, that things move along much more smoothly and that's a much.

More proactive approach, I guess is what you're looking for. It's like you can see that the developers heading down a route that which you might regard as suboptimal. Let's just get on the phone, talk to them.

And I think if you've got a, you know, if you've got a Planning performance agreement that that's, that's all set out in there and that would be paid for.

So it comes back to the resourcing because I think, you know, some of the listeners maybe say, well, I tried to pick up the phone to the planning planner but I couldn't get through. And you know, they're not available because we know that they're really under the cosh in terms of capacity. So what can you do to help that?

So the, the idea is to, if they do do pre app advice, again, some local authorities do not, but we would definitely encourage them all to do that for BNG just because it's so helpful to do that and then have those conversations up front.

So then when you put your planning application in, at least those issues you know, that you've dealt with at that stage should hopefully go through relatively easily without having to have those conversations, you know, while you're waiting for planning approval. But get it in early.

And also, you know, I think the points that Paul was making about the design and integrating in early, you know, it's just good design generally is to look at your site and design around what is on your site already. And that comes into things like areas that floods.

It comes into things like sustainable urban drainage systems which are, you know, coming, have now come in as a, you know, much requirement.

If you're trying to pretend that your site is empty and you're just putting things in without designing around what's already there, it's going to be much more difficult just across the board, not just for biodiversity net gain.

I think what we don't have in these reports, Becky, is what does it look like, what the layouts, corridors look like, what the dimensions are for those just really so officers particularly can understand that it's. The BNG metric isn't a mathematical art, actually.

What it is, it's about place building and it's about bringing all of those complex elements together in a manner which really, really sings. And they all sing together in harmony definitely.

And I think that point about thinking about things together.

So, you know, you may have green space standards, green infrastructure here, but you do need to think carefully about that biodiversity net gain and what habitats can be supported. So if you start saying, ah, right, okay, this is me going to meet my open space requirements and my BNG and it's going to be a sud.

Is that actually possible? Because you know, if it's going to flood periodically, does it meet the open space requirements? But also is it going to actually create that habitat?

But if you Design, you know, think about that up front and get the ecologists and landscape architects involved early on. You know, there's some really great examples out there, but we, yeah, we would.

Like to see more working with landscape architects, working with ecologists, working with tree officers and so on. A lot of the elements they're talking about can be open to interpretation.

And we know developers have said, well, I think with yourself, Chris, engineering background and so on, there's a process and you kind of run through that process quite rationally and you get to a thing.

But I think what we're talking about with green infrastructure, bng, is something which is a bit more interpretive and therefore you need to have those conversations and those discussions with the local planning authority, with your team, with your experienced ecologist who's on board, or with the landscape architect that's helping you with format to have those debates to get to a point where you've got to the agreed option. I think that's the key thing. It's not just a tick box exercise, is it, Becky?

No, but that does mean there is some flexibility.

So although we've got this legal structure in there which sets these, you know, 10% and you've got to do it this way actually because of the way that nature works and because of the way you can integrate it in design, it does mean there's flexibility. But again, you can't do that at the last minute.

You have to think about that early on in terms of your design because as soon as you start constraining, potentially by setting a layout at a very early stage, which doesn't take account of perhaps your biodiversity net gain, it becomes difficult.

Yeah, okay. I'm expecting most of the listeners for this podcast are probably going to be developers.

I'm aware of the HBF report on biodiversitynet gain that came out recently where 29% of the respondents had said that they found BNG very challenging. I mean, the good news was it was down from 38% the previous year. I know a lot of developers are really worried in this space.

Can we expect things to get easier, do you think?

Yeah, and I agree it's tough because it's been a real change. You know, with anything where you've got a big change, it, it just takes time to get used to it.

And I think at least we're seeing those figures, you know, that they've gone down quite a lot in just a year in terms of what who's finding it, you know, the number that are finding it very challenging. But you know, there's all sorts of really useful resources out there.

And I know, you know, I definitely, I probably just point to future homes hub, they run events, all sorts of things on, on, on this and they have forum and I think we' and we're working together on all of this, which is really, really good. You know, you could see it as a problem, but we definitely see, you know, from an LPA point of view who we primarily work with. Yes.

I don't think many people are saying it's easy, but the number who find it very challenging is definitely reducing over time.

Well, I think this is the point in the podcast. I'm feeling in a jealous mood and I want to give, give you one wish. I don't go, I don't stretch the three wishes. I only do one wish.

What's the one thing that would make a big difference in this space off the tops of your heads?

I mean it's something I always say, let's just work more collaboratively across the board.

You know, that's developers, LPAs, consultants and then getting to the other sort of side in terms of long term management management companies, habitat banks. Let's not look at each other as one versus the other. You know, developers complaining about LPAs or LPAs to complaining about developers.

I think that would be my one wish. Let's, let's work together on this and view it positively. So.

Yeah, well, obviously Becky took what I was about to say, so I'll go to my second one and I guess really what it's something that I mentioned earlier on really and it's really about realizing that anything around nature, anything around climate change, anything around good homes and so on, delivers well designed places. In delivering well designed places and homes people want to live in, the demand will be there for your housing, for your products.

My experience really is that those developers who've taken that on board are able to sell their units at the end of the day and ideally for a profit, which is what we're all after, isn't it?

That would always help.

Well, where there's risks, there needs to be profit, Chris. And we don't deny that. And I think we're all here really to, to smooth that process.

Okay, well, thank you, thank you so much, Paul and Becky for joining me today on the podcast. It's been a real pleasure having this chance to talk to you.

It's been great to be here. Thanks very much.

Hopefully we had a good time and you've enjoyed listening to it.

Thanks for listening to this episode of the Future Homes podcast and thank you once again to Becky and Paul for sharing their insights.

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