10 Jun 2020 Setting a standard for biodiversity net gain for development
The British Standards Institute (BSI) has launched a public consultation on the draft British Standard – BS 8683 Process for designing and implementing Biodiversity Net Gain – Specification. The main purpose of BS 8683 is to set out the requirements for the biodiversity net gain assessment process for all developments across the UK.
Why this standard matters
The provisions within the draft Environment Bill will mandate biodiversity net gain as part of the planning process in England, adding a new requirement to the existing biodiversity duty for local planning authorities (set out in Section 40 of the Natural Environment and Rural Communities Act 2006). This proposed new British Standard applies to all countries within the UK and is likely to be adopted by local planning authorities, at least in England, to help them ‘deal with biodiversity net gain’ requirements quickly by asking all applicants to adhere to it as part of pre-planning application validation checklists.
As such the standard could become the process that has to be followed in designing and delivering biodiversity net gain for each and every development regardless of scale. It is important to note that as the standard is written as a specification, all elements of the specification must be met in order to be compliant with the standard. Hence, it is important that the standard is practical, clear and most of all deliverable, providing a usable common approach to which to work.
Next steps: how you can help shape the new standard
The public consultation, which lasts until 24th June 2020, is the opportunity to help shape the final form the new standard takes. It is important that representatives from all sectors across the UK contribute to ensure it is fit for purpose.
BSG Ecology and LDA Design are working closely together to review and contribute constructively to the standard. Some of the key questions the draft standard raises are highlighted below.
– Is the purpose and scope of the draft standard clear and applicable across the UK? It is intended for development projects and the structure takes you through a typical project life cycle. In addition, it is also for land managers and land management outside development. Will this dual-pronged approach lead to confusion? Will the new standard be truly applicable across the UK given the different country based approaches to biodiversity net gain? Biodiversity net gain in England is to be measured using a metric based approach whereas the approach taken in Wales is termed ‘enhancement’ and there is not currently a metric-based approach.
– How does the draft standard relate to the draft Environment Bill requirements? There appear to be some differences between the Environment Bill and the draft standard. Will these differences slow down the planning process and generate further additional costs associated with biodiversity net gain requirements over and above those set out in the draft Environment Bill?
– Is it appropriate for there to be broader requirements within the proposed standard compared to the Environment Bill, specifically in relation to social and other environmental considerations? For example, in project feasibility (5.1.1), there is a need to commit to ‘addressing any negative impacts on people from BNG whilst maximising opportunities for BNG to generate positive social outcomes.’ There is a requirement to identify and measure the impacts on people, using social surveys, and how biodiversity net gain will provide positive outcomes for people. This goes beyond the Environment Bill requirements to demonstrate a 10% net gain in biodiversity value. Is it clear how such assessments will be made and by whom and as such would this be more suited to natural capital accounting and ecosystem services assessments so that biodiversity remains the primary objective of the standard.
– Developments which would result in negligible or no effect on biodiversity shall still be required to deliver biodiversity net gain – how practical will this be to achieve? Is there enough land available to do this?
– At the pre-planning stage, the reporting for biodiversity net gain feasibility assessments appears extensive. Is there always going to be a need to have a vision for biodiversity net gain to meet the standard? Or will the ‘ambitious 10% national requirement’ set by Defra and reflected in the draft Environment Bill generally become the accepted vision meaning that the 10% is always the commitment in England. How will other countries in the UK measure their biodiversity net gain delivery without the use of a metric to quantify the net gain?
– At present, there is little reference to off-site compensation provision in England by buying biodiversity credits where the 10% cannot be achieved within the planning application boundary or the applicant’s landholding. How will local planning authorities then provide a service back to the applicant so that guarantees can be given on how the developer monies generated will be suitably spent? Would those land owners/organisations delivering net gain offsite be required by local planning authorities to follow the standard? Would it be useful for more information to be provided on this option particularly in England given the availability and increasing use of the Defra Biodiversity Metric 2.0 developed in conjunction with Natural England?
How to respond
If you wish to respond and have your organisation or sector represented, the full document is available for you to read and comment on at the link below. The deadline is 24 June 2020.
BSG Ecology and LDA Design have been working successfully together for more than 20 years on integrating green infrastructure, good urban design and biodiversity net gain into development at landscape scale. As a consequence, we bring together our mutual experience of how biodiversity and good design come together as part of place making for biodiversity and people.