We looked at every Full Planning application that Bristol validated between 6 and 31 August 2026 (the applications carrying the suffix ‘/F’, householder applications having their own suffix and their own exemption from the BNG regime). There are 28 of them, and every single one is on a site of 0.2 hectares or less. This means that none of them now needs to deliver any biodiversity gain: all are under the threshold, and none records an impact on a priority habitat.
However, only eight of these applications would have had to deliver BNG before 6 August in any case. Eighteen were already exempt under the de minimus rule (which remains in force, though perhaps now redundant for small sites like these), while one was covered by the self-build exemption, itself withdrawn on 6 August, and another cannot be decided from the published evidence.
The de minimus rule exempts a development from the BNG regime if it impacts less than 25 square metres of on-site habitat carrying any biodiversity value, and less than 5 metres of linear habitat such as a hedge with biodiversity value, and doesn’t include a priority habitat. The limit is on what the development impacts, not on how big the development is. Sealed surfaces, buildings and hardstanding all score zero in the metric, so a proposal can cover such a site entirely and still impact nothing above the de minimus threshold. Fourteen of the 18 applications are exactly that, even though they are all larger than 25 square metres: they include the installation of shop frontages, air conditioning units and parcel pick-up lockers, a replacement conservatory on to an existing terrace, and a basement-level extension on existing hardstanding.
This leaves eight (almost a third of the sample) that would not have been exempt before 6 August but are now. Each is a dwelling or a subdivision of land that is, or was, garden. The new exemption never asks what stands on the site. It asks only whether a priority habitat is impacted and if the site is 0.2 hectares or less; the habitat on the site is not measured at all. The de minimus rule did measure it — and so a single small tree, which has a habitat area of 41 square metres, would defeat the de minimus exemption if affected. But an individual tree is not priority habitat, so, even if the combined tree habitat area within a development site might be greater than 0.2 hectares, the new exemption still applies.
This is why we are asking for a new way to protect urban trees: a tree replacement standard in every local plan.
This is a follow-up from Small sites, big losses: The BNG exemption is the strongest argument yet for a national tree replacement standard
The full analysis is in the accompanying spreadsheet – Sub 0.2 ha applications – BNG analysis.xlsx.
