Category: Biodiversity Gain Plans

Understanding Biodiversity Gain Plans

Since BNG became mandatory in February 2024, qualifying developments in England must show how they will deliver at least a 10% gain, to be set out in a Biodiversity Gain Plan (BGP) submitted to the local planning authority. We have transcribed 102 BGPs from 12 LPAs into a single, comparable dataset.

What the data shows so far:

  • Just over half (61 of 109) deliver their gain entirely on site. Another 24 use a mix of on-site and off-site measures, while 11 rely wholly on off-site units and 13 did not state an approach. Two bought Statutory Credits.
  • Off-site reliance is a recurring theme. A number of plans record an on-site biodiversity loss offset by purchased habitat units — a legitimate route, but one that moves the gain away from the community where the development happens.
  • Net gain has to be met habitat type by habitat type (area, hedgerow, watercourse), not as a single blended figure. Several plans that pass overall are marginal — or fall short — on an individual module.

Accessing this data was harder than it should be:

  • There is no central register of gain plans – why can’t Defra or Natural England include them in their BGS allocation dataset? These documents should be easily accessible.
  • Each council’s portal has to be searched separately, with no consistent way of identifying the relevant application. Only a few authorities (City of York, Bristol and Cotswold among them) have a dedicated application category for BNG discharges. Otherwise the BGPs sit inside generic “discharge of conditions” applications and are very difficult to find.
  • BGPs are produced in a variety of forms – as clean PDFs, fillable forms or scanned images requiring OCR which is challenging, especially if they are hand-written.
  • They are often internally inconsistent — off-site figures just copied from the on-site section, credits confused with habitat-bank units, headline numbers that do not reconcile.
  • Off-site claims frequently differ from what the Biodiversity Gain Sites register records as allocated.
  • Many applications do not include by the required BNG Metric calculation.
  • Some applications cannot be analysed because all that is produced (and approved) is the certificate of the off-site HU purchase – sometimes not even that. As a result, we have been unable to include these in our analysis.

The information exists, but the planning approval system makes meaningful public scrutiny far harder than it needs to be. A standardised form and a single searchable register of BGPs would be a straightforward improvement.

The full dataset and analysis are here — comments, corrections and more data are welcome:

https://docs.google.com/spreadsheets/d/1BEcf6q5nfSAcghmFAymKtROLplEHPwqU/edit?pli=1&gid=1363229587#gid=1363229587.

NB. This analysis will grow as we add more data.

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