HGH Consulting


Biodiversity Net Gain, Without the Pain

As mandatory Biodiversity Net Gain (BNG) policy is introduced in late 2023, hgh Director Adam Gostling shares the views of three experts on the subject, from a recent Planning Futures breakfast event.

Biodiversity net gain (BNG) is an approach to development, and/or land management, that aims to leave the natural environment in a measurably better state than it was beforehand.

New focus

The recent shift towards environment-led planning calls for greater transparency from land owners and developers and, increasingly, a more proactive approach to preserving biodiversity.  Rather than employing an ecologist to assess plans or drawings, now the onus will be on providing the potential and evidence of ‘net gain’, for a period of at least 30 years, as a legal duty.

However, how will the process be conducted and what are the steps to take before the policy is in place? 

Expert insight

Each of the three speakers at the event – Dr Nick White of Natural England, Laura Grant of DEFRA and Patrick James of The Landscape Agency – brought insights from their own practice and experience, albeit subject to the on-going government consultation on the finer points of BNG.

Nick White of Natural England described these changes as a ‘paradigm shift’, arguing that it will bring opportunities and benefits to people, places and the local economy, in addition to the natural environment. White’s recommendation:  act sooner, rather than later; engage different groups and stakeholders; identify potential sites; and see if Local Plans may throw up areas of BNG opportunity, such as local nature recovery schemes.

Laura Grant, Policy Lead at DEFRA talked through the main points of the proposed Biodiversity Net Gain process in three ‘layers’ of delivery: on site; off site; and a new system of Statutory Credits to be sold by the Government with accredited brokers. This new market effectively creates a new set of habitat ‘banks’ and ‘deals’ whereby land owners offer to facilitate BNG schemes and developers invest in them, with legal covenants in place.  

BNG Balancing Act

DEFRA’s Grant responded to questions from attendees about what she called the ‘balancing act’ between market integrity and investor confidence – and on the resilience of the policy in the real world. 

Meanwhile, Patrick James of The Landscape Agency, demonstrated recent examples of what he referred to as ‘putting the landscape back’ into sites outside London, including the Green Belt.  Working with farmer land owners, The Landscape Agency has helped transform arable land into ponds, nature reserves and protected areas.  Achieving BNG, in James’ view, is all in the detail of the metric, although his slides provided visible proof that farming land is often ‘oven ready’ off site BNG schemes.

Planning Issues

From the panel discussion, it’s clear there are a number of grey areas clouding the positive outcomes of BNG policy. Three planning issues come to mind: process, pricing and proof.

Firstly, how will the process take shape?  Although we can assume local authorities (and their metrics) will favour BNG schemes within their local boundary, how off site schemes are identified, funded and implemented seems unresolved. With new digital platforms to facilitate the matching-making of BNG-ready land and developer intent, plus the system of statutory credits, these platforms need to be trustworthy, consistent and efficient in practice.

Secondly, how will credits be priced? DEFRA’s Grant mentioned the need to have realistic pricing to raise enough funds to run the BNG scheme, but whilst pricing at a level that limits these, as a ‘last resort’ in the process.

Thirdly, the metrics question: how will these provide proof of the delivery of BNG in the longer-term? The commitment to 30 years is longer than the career of the average planning officer, let alone the tenure of a developer, so this brings doubt into the equation.

Higher Stakes

With the results of the consultation process due in a few months answers the above are hopefully on their way. Whatever the outcome, the stakes of the BNG ‘game’ just got higher. 


hgh Consulting offers an advisory service that includes land promotion and Environmental Impact Assessment (EIA) through a dedicated team. For further information, please contact Eve Campbell, Director, hgh Consulting: [email protected]

Useful links

  1. Metrics https://www.gov.uk/guidance/biodiversity-metric-calculate-the-biodiversity-net-gain-of-a-project-or-development
  2. Technical consultation on metrics https://www.linkedin.com/feed/update/urn:li:activity:6960107705906696192/


Image: Chris Dack on Unsplash


Adam Gostling, Director, hgh Consulting
[email protected]

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