Category: Planning Policies

Small sites, big losses: The BNG exemption is the strongest argument yet for a national tree replacement standard.

Since 6 August this year, the smallest developments in England (those 0.2 hectares or smaller) no longer have to deliver biodiversity net gain (BNG). To understand what this means for trees, we’ve analysed 505 biodiversity gain plans and 320 readable metric calculations gathered from 59 planning authorities.

The answer is uncomfortable: the exemption removes roughly half of all development sites from the BNG regime, and these are precisely the sites on which trees make up the largest share of the habitat being lost.

In December 2023 we argued for a new Bristol Tree Replacement Standard (BTRS) calibrated to the statutory biodiversity metric. That argument was about making the local standard consistent with national policy. It’s now about something much more critical: on half of all sites, a local standard is the only thing left to protect trees being lost to development.

What changed on 6 August 2026

The Biodiversity Gain (Town and Country Planning) (Amendments and Transitional Provisions) (England) Regulations 2026 (SI 2026/790) took effect for planning applications made on or after 6 August 2026. The three changes made matter here:

  1. A site of 0.2 hectares or less, measured by the red-line boundary of the application, is exempt from mandatory BNG unless on-site priority habitat is negatively affected.
  2. Development that’s wholly temporary, with permission granted for five years or less, is also exempt on the same proviso.
  3. For minor development above the area threshold, the mitigation hierarchy has been relaxed: off-site gains are now seen as just as desirable as created or enhanced habitat on the site itself, so a developer may go straight off site without first showing that on-site provision is unachievable.

The self-build and custom-build exemption has also been removed, on the reasoning that most such schemes now fall inside the new small-sites exemption anyway. While applications already submitted before 6 August continue under the old rules, Defra in its 15 April 2026 response to the consultation, estimated that ‘the new area based exemption for sites of less than 0.2 hectares is expected to remove more than 50% of the smallest planning applications which are currently delivering mandatory BNG, from the BNG requirement’.

Trees aren’t priority habitat

The priority habitat proviso sounds protective, and for some sites it is, but it does nothing for trees. Depending on where it is, an individual tree is recorded in the statutory metric as urban tree or rural tree, both of medium distinctiveness; neither is a habitat of principal importance under section 41 of the Natural Environment and Rural Communities Act 2006. Only ancient and veteran trees sit outside these two categories, as irreplaceable habitat, and they are a vanishingly small proportion of the trees felled for development.

So a mature street-side lime, a garden oak, or a row of maturing London planes on the edge of a school playing field — none of these will be protected if they’re in the way of a 0.2 hectare development. Below the threshold, they can be removed without any obligation to count them, replace them, or compensate for their loss anywhere. Unless the tree is protected by a Tree Preservation Order, or unless the local plan says otherwise, nothing now requires their loss to be made good.

This is the gap; and it’s much larger than the word ‘small’ implies.

Half of all development sites now fall outside the system

We measured site area for every gain plan in our dataset that came with a usable metric calculation — 305 sites across 59 authorities. Site area here is the baseline area-habitat total, net of any individual trees, taken from the statutory metric or, for small-sites metrics.

Table 1. Development sites by size, 305 sites with a usable metric calculation
Site size Sites Share Baseline area HUs Post-development area HUs On-site change
0.2 ha or smaller 151 49.5% 48.79 48.67 −0.25%
Over 0.2 ha 154 50.5% 506.88 512.82 +1.17%
All sites 305 100% 555.67 561.49 +1.05%

Habitat units are on-site figures from sections 6.3 and 6.4 of the biodiversity gain plan. Hedgerows and watercourses are excluded as linear features.

Just under half of the sites that have been going through the BNG process fall at or below the new exemption threshold — consistent with Defra’s own estimate. Two further things stand out in that table. First, small sites were barely holding their own on site even under the old regime that’s just been withdrawn: a baseline of 48.79 area habitat units became a mere 48.67 after development, a small net loss, with any gain bought off site from elsewhere. Second, the small-site total is dwarfed by the large-site total, which is exactly why the exemption looked politically cheap. In habitat unit terms these sites are a rounding error. In tree terms, though, they aren’t.

Small sites are where the trees are

Of the 320 metric calculations we could read, 163 relate to sites of 0.2 hectares or less. Sixty of these — 36.8% — record individual trees in the on-site baseline. Between them they carry 3.12 hectares of tree canopy ‘oversailing’ 15.22 hectares of land.

Table 2. Individual trees in the on-site baseline, by site size
Site size Metrics With trees Site area (ha) Canopy (ha) Canopy as % of site area Tree baseline HUs
0.2 ha or less 163 60 (36.8%) 15.22 3.12 20.5% 26.71
Over 0.2 ha 157 81 (51.6%) 219.64 13.79 6.3% 133.22
All sites 320 141 (44.1%) 234.85 16.91 7.2% 159.94

Site area is net of individual trees, because tree canopy oversails the habitat beneath it and is not additional land. Canopy can therefore exceed 100% of the site area it overlies.

That last comparison is the heart of it. On sites above the threshold, tree canopy is equivalent to about 6% of the site area. On sites at or below 0.2 hectares it’s 20.5% — more than three times the share. Small sites are disproportionately tree rich, probably because they’re disproportionately urban: they include infill plots, back gardens, corners of school and hospital grounds, and the fringes of existing built-up land. These are the places where we usually find the mature tree canopy of a town.

The concentration is sharper still for twenty of the 163 small-site metrics, which record canopy covering more than half the site area. Seven record canopy exceeding the whole of it. One example is a 0.18 hectare site at 22 York Road in Sutton, which carries 0.33 hectares of canopy across 18 recorded tree entries — canopy equal to 182% of the site, and worth 3.42 habitat units. At an average of 0.019 hectares of canopy each, these are mature trees, not saplings — on the replacement standard set out below, losing 18 medium trees would require 90 replacements. On an application made today, that site would be exempt and the trees could be removed without any obligation to replace them under the new BNG regime.

Expressed as trees rather than hectares, the 3.12 hectares of canopy on small sites is equivalent to 762 small trees, using the 0.0041 hectares the June 2026 metric assigns to a small tree. Because much of that canopy belongs to medium, large and very large trees, the actual number of trees is likely to be lower — and their replacement cost, in the metric’s own currency, correspondingly higher.

And they’re where the new trees were coming from

The exemption removes an obligation to plant as well as an obligation to compensate. Of the 163 small-site metrics, 72 record individual trees created as part of the post-development scheme.

Table 3. Individual trees created in post-development proposals
Site size Metrics With tree creation On-site trees Off-site trees Total trees
0.2 ha or smaller 163 72 (44.2%) 597 8 605
Over 0.2 ha 157 97 (61.8%) 3,135 205 3,340
All sites 320 169 (52.8%) 3,731 213 3,944

Tree numbers are the recorded habitat creation area divided by 0.0041 ha per small tree, rounded up. Off-site units bought from a registered gain site do not appear here, because they sit in the seller’s metric.

Over 600 trees across a dataset of a few hundred plans covering barely two years and 59 authorities out of 306. If you scale that across every planning authority in England and across the years ahead, the tree planting foregone is substantial.

BNG was never going to save urban trees anyway

It’s worth being clear that the case for a local tree standard doesn’t rest solely on the exemption. Even where BNG still applies, it often doesn’t keep compensation anywhere near the trees that were lost.

The Biodiversity Gain Sites register as of 19 August 2026 — 2,328 developments across 306 authorities — shows that 87% of developments in urban authorities offset outside their own authority area. Those authorities needed 1,835 area habitat units and hosted 889. In London the pattern is near total: 98% of the 113 registered London borough developments offset elsewhere, requiring 46.8 units and hosting 3.3.

The units are real, and the receiving sites may well be excellent. But a habitat unit delivered in a rural county doesn’t provide shade in Bristol, intercept its rainfall, cool it in a heatwave, or stand outside anybody’s window. Urban tree canopy is a local public good, yet BNG systematically moves its replacement to some distant field that few, if any, will ever visit.

Why we need a tree replacement standard

A tree replacement standard is a local plan policy, not a national biodiversity calculation. It attaches to the tree, not to the site area; it applies whether or not a metric has to be completed; and it keeps the replacement in or close to the place where the loss occurred. It’s the mechanism best suited to fill the gap the exemption has opened.

This is not a novel invention. Bristol has operated the BTRS since 2014 under Core Strategy policy BCS9, and a replacement table is carried forward into proposed local plan policy BG4. What we argued in 2023 was that the ratios should be recalibrated so that the standard delivers what the statutory metric would have delivered, plus the 10% uplift. Our proposal was not adopted then, though our argument stands. What’s changed is who needs it: not just Bristol, but every planning authority that wants any control at all over tree loss on the majority of its planning applications.

We would encourage authorities without such a policy to adopt one, and those with one to check that it’s calibrated to the metric rather than to a historic rule of thumb whose rationale was and remains hard to understand. As the standard is a local plan policy, it can be applied to exempt sites without cutting across the national BNG regime: BNG sets a floor for biodiversity, and a replacement standard sets a separate, local requirement for canopy.

Recalculating the standard against the June 2026 metric

Our 2023 proposal derived replacement numbers from the tree area equivalents then in force. Those figures have since changed. Table 15 of the Statutory Biodiversity Metric User Guide (June 2026), at page 62, now assigns the areas set out below. Applying the same method — the area of the lost tree divided by the area of one small tree, since a newly planted tree is recorded as small, plus the 10% net gain, rounded up because a fraction of a tree is not a tree — gives revised numbers.

Table 4. Replacement trees required, recalculated against the June 2026 metric
Tree size (DBH) Area equivalent (ha) Multiple of a small tree Plus 10% net gain Replacement trees 2023 proposal
Small (>7.5–30 cm) 0.0041 1.00 1.10 2 1
Medium (>30–60 cm) 0.0163 3.98 4.37 5 3
Large (>60–90 cm) 0.0366 8.93 9.82 10 10
Very large (>90 cm) 0.0765 18.66 20.52 21 20

Areas are from Table 15 of the Statutory Biodiversity Metric User Guide (June 2026), p62. Replacement numbers are the tree’s area divided by the area of one small tree, plus the 10% net gain, rounded up.

Two categories of tree size move. A medium tree is now worth almost four small trees rather than three, so its replacement requirement rises from three to five. A very large tree rises from 20 to 21. Large trees are unchanged at ten.

The small-tree row needs a decision rather than an arithmetic answer. One small tree replaced by 1.1 small trees rounds up to two, which is a real doubling for the commonest category in the surveyed population. The alternative is to hold the small category at one-for-one and take the 10% uplift from the scheme as a whole. We think the honest position is to state the arithmetic and let the policy make the choice explicitly, rather than round the uplift away in silence.

What we’re asking for

  • That local planning authorities adopt, or retain and strengthen, a tree replacement standard in their local plan, applying to all development including sites exempt from mandatory BNG.
  • That the replacement ratios be calibrated to the current tree area equivalents in the statutory metric, so that a local standard delivers no less than the national regime would have done.
  • That replacement be required within the same authority area and as close to the loss site as is practicable, so that canopy is replaced where people live.
  • That authorities continue to require a BS 5837:2012 tree survey with applications on exempt sites, so that the loss is properly recorded even where no metric is required.
  • That Defra keep the 0.2 hectare exemption under review, and specifically consider whether the priority habitat proviso should be extended to sites carrying significant tree canopy.

The exemption was introduced to reduce costs and delays for small applications. Whatever one makes of that aim, it shouldn’t be paid for with the mature canopy of our towns and cities. A tree replacement standard is a cheap, well-understood, locally enforceable way of making sure it’s not.

About the data

Figures are drawn from the Bristol Tree Forum biodiversity gain plan dataset (v11): 505 gain plans logged from 59 planning authorities, of which 320 carry a readable statutory or small-sites metric calculation and 305 a usable site area. Plans are dated 2024 (58), 2025 (254) and 2026 (165). Register figures are from the Biodiversity Gain Sites register extract of 19 August 2026, covering 2,328 developments and 2,686 allocations across 306 authorities.

Two caveats:

  1. Site area in this analysis is the metric’s baseline habitat area net of individual trees, which is a close proxy for the red-line boundary the exemption uses but not identical to it; a handful of sites near the threshold may fall on the other side of it in practice.
  2. The sample is of applications that produced a gain plan, so it describes the population the exemption removes rather than all development across the country.

What Bristol’s biodiversity duty report doesn’t tell you

By the end of March this year, every council in England had to publish a report on what it is doing for biodiversity. Councils that are also local planning authorities — Bristol among them — must go further, and give details of the biodiversity net gain resulting, or expected to result, from the biodiversity gain plans they have approved.

This is done through the submission of a Biodiversity Gain Plan (BGP).

Some time earlier this year, Bristol City Council published its Biodiversity Duty Report (the Report) covering the period from January 2020 to December 2025. It is a handsome document, and much of it is genuinely positive: it lists 43,523 trees planted, canopy cover up to 18.2%, and pesticide use down 42%. 

On the question of BNG, though, it publishes only a single table which can’t answer the question a local resident might ask: Is new development in Bristol leaving our local nature better off or worse off?

What BNG is meant to do

Since February 2024 most new developments in England have had to deliver a 10% increase in biodiversity. Developers measure what’s on a site before they build — using a government metric calculation which converts various habitat types into ‘biodiversity units’ —  and then show how they’ll deliver at least 10% more biodiversity than was there before they started.

They can do this in three ways: improve habitat on the site itself; pay for habitat to be created somewhere else; or — as a last resort — buy statutory credits from the Government. Before building can start, the Council must approve the developer’s gain plan showing how the minimum 10% BNG will be achieved.

Each gain plan is a precise record (backed by a metric calculation) of what a development will achieve. Bristol has approved a number of these so far but the Report tells you almost nothing about what’s in them.

What Bristol actually published

Here’s everything the Council’s published about its approved gain plans, as listed in the Report:

Table from Bristol City Council's Biodiversity Duty Report summarising its seven approved biodiversity gain plans. On-site only: 3 plans, 2.56 units post-intervention, average net gain 275 per cent. Off-site only: 1 plan, 2.09 units. Combination of on-site and off-site: 3 plans, 3.56 units. Credits: none. No baseline figure is given for any row.

Look at the column headed ‘No. of Units post-intervention’. These are the biodiversity units expected after a development is completed. There’s no column for the value of the habitats that were there before (called the baseline). Without a baseline, we can’t know what the net gain percentage is. In the row labelled ‘On-site BNG only’ there’s a reported 275% average % net gain but the other rows are left blank, so it appears not to be an average across the seven plans reported. Three small schemes with very little habitat to begin with can easily produce a number like this: if a site starts with almost nothing, almost any new habitat can produce a large percentage increase. Published on its own, without the baseline values that would put it in proportion, it reads as a triumph but is meaningless because it lacks essential information.

What the gain plans we’ve examined say

Bristol Tree Forum has been collecting biodiversity gain plans from councils across England — 301 of them so far, from 34 authorities. We’ve found 18 for Bristol, 16 of which record a figure for the change in area habitat units on the development site. Twelve of the 16 lose habitat on site. Added together, the 18 Bristol plans show a net loss of 10.9 area habitat units within the red lines of the sites themselves. The four that gain contribute 0.24 units between them. One scheme, at Broomhill Road, records the loss of every unit on the site — 100%.

To be fair to the Council, most of those plans were approved during 2026 and so fall outside the period the Biodiversity Duty Report covers. However, six of them are dated on or before 31 December 2025 and belong squarely inside it; all of these six lose habitat on site, by 4.68 units between them.

Now, an on-site loss is not by itself a breach of anything. That’s exactly what the off-site habitat unit purchase option is for: where a site cannot accommodate the lost habitat on site, the developer is allowed to buy habitat units elsewhere to meet the 10% plus obligation. Nine of Bristol’s 18 plans deliver through a combination of on-site and off-site compensation, and four go entirely off-site. So, on paper, the obligation is met.

But a resident reading the Council’s report would have no idea that any of this was happening. The published table doesn’t state what the baseline habitat was or distinguish between gains and losses. It doesn’t say where the off-site habitat is. And it doesn’t name a single application, so there is no way to look one up.

Where does Bristol’s biodiversity go?

The report does contain one sentence that deserves more attention than it’s had. There’s no registered biodiversity gain site anywhere within the Bristol boundary. The Council’s own candidate sites ‘remain unregistered while a viable solution to procuring a legal agreement is worked towards’, and are still at scoping stage. As far as we’re aware, no Biodiversity Gain Site has yet been registered for the city.

That means every off-site unit bought to offset a Bristol development creates habitat outside the city. Thirteen of our 18 plans use off-site delivery in whole or in part. The habitat lost is in Bristol; the habitat created to compensate for it is not. So far, that compensation amounts to 14.60 units allocated to sites outside the city — 14.55 area units, 0.01 hedgerow units and 0.04 watercourse units. To see them, open https://bgs.bristoltrees.space/bgs-bodies, select LPA Allocation Maps and click on City of Bristol LPA on the map.

Other councils can manage it

Publishing a schedule of all the approved BGP approvals is not difficult. Other authorities are already doing it. For example, Cotswold District Council has published an appendix listing all 24 of its approved gain plans — application reference, date, delivery route, and the units and percentage change for habitats, watercourses and hedgerows on each one. Bolton publishes the same for its four, including the name of the habitat bank each one bought into. 

County Durham has not published a schedule of all its approved applications, but it has published the full Government reporting tables, which show, without flinching, that on-site habitat units across its 16 approved plans fell by an average of 30.85%.

Durham’s report is uncomfortable reading for Durham, but it is for that reason worth something; a report that cannot embarrass its author is not really a report.

What we’d like to see

Bristol has met the letter of its duty but it could have gone further and produced a meaningful schedule that would have made sense to the ordinary reader and been used to help inform a proper debate about how the city is (or is not) benefiting from the BNG regime. On our analysis, it’s not.

Three changes would fix this, and none of them requires new data — the Council already holds all of it:

  1. Publish the baseline alongside the post-development figure, so a net change can be worked out.
  2. List the approved gain plans individually, with the application reference, so anyone can find the application and check it.
  3. Say where the off-site units are, and how many have left the city.

There’s some urgency to this. The reporting cycle is five years, by which time a new Local Plan will probably have been adopted. If we have the information now, this might be used in the development of any new Local Plan so that it provides a real benefit to Bristolians. Unless Bristol chooses to publish an update voluntarily, the next time it’s legally required to tell us anything about biodiversity net gain will be 2031 — by which point seven years of development will have been permitted, built and largely finished, on the strength of a table that serves no practical purpose.

Bristol City Council’s Biodiversity Duty Report 2020–2025 is published at bristol.gov.uk. The figures attributed to gain plans in this article are drawn from Bristol Tree Forum’s own collection of biodiversity gain plans obtained from planning registers and freedom of information requests, and are ours rather than the Council’s. We’d be glad to be corrected on any of them.

The cover image above is extracted from the Council’s Biodiversity Duty Report.

Biodiversity Net Gain – what the biodiversity gain plans approved actually show

Since February 2024 biodiversity net gain has been mandatory for major development in England – and for small sites since April of that year. Two and a half years on, there’s still no publicly available national dataset of the gains that developers promised and say they’re delivering.

While the Biodiversity Gain Sites Register records off-site allocations, these are a small element of the whole BNG regime. The required biodiversity gain plans themselves — the information and documents that state, scheme by scheme, what the baseline biodiversity was and what biodiversity gain the development will deliver — sit dispersed across individual planning portals. Each portal is managed by each of over 300 planning authorities and the information is not nationally collated.

So far, we’ve collected 263 of these biodiversity gain plans from 31 Local planning authorities (about 10% of authorities). We’ve audited them field by field against the published source documents. This is what they show.

How we created the dataset

Every gain plan here was found on a local planning authority’s portal as an approved application, with a published Biodiversity Gain Plan. To date, the earliest is dated 2022; 27 are from 2024, 129 from 2025 and 91 from 2026. The authorities range from Bristol, BaNES and East Suffolk, with 18 or 19 gain plans each, down to several with just one. Site areas, where a statutory metric calculation is published and the baseline habitat area can be read from it, run from a few hundred square metres to several hectares, with a median of 0.225 ha across the 133 gain plans that we have been able to locate so far.

The sample is not representative, and depended on our being able to locate gain plans on planning portals using a variety of search approaches. These searches did not always succeed and we have probably failed to identify all the approved gain plan applications on the portals we were able to interrogate.

How we found the documents

Collecting these 263 plans was harder than analysing them. Once the right application is found, the documents are usually easy to identify: they are labelled ‘Biodiversity Gain Plan’, ‘Net Gain’, ‘metric’ or something equally simple, and the labelling is broadly consistent between planning authorities. The real challenge is finding the application on the authority’s planning portal in the first place.

A gain plan must be submitted to discharge the statutory ‘deemed’ planning condition required under the BNG regime, so it sits within a related discharge application rather than within the original permission. Finding it means knowing which discharge application to look for, and under which application type (assuming there is one). Save for the regulations, there is no guidance on how the biodiversity gain condition should be discharged or what should be published when, so every authority has settled the question differently. A minority have a dedicated application type — e.g. ‘Approval of Details – BNG’ — and one search usually returns everything, but not always : on some planning portals this search returns nothing.

For example, the Bristol City Council planning portal Advanced search option returns no decided results when the ‘Discharge Deemed BNG Condition’ Application Type is used. Only two pending applications are found, but on closer examination, even though one contains the required Biodiversity Gain Plan document, there is no required statutory metric calculation, while the other one relates to an application that predates the BNG regime.

In all other cases the only method is to guess using search terms like ‘biodiversity’, ‘BNG’, ‘gain plan’, ‘net gain’, and hope this produces results. At one authority a search for ‘biodiversity’ returned 16 results, but fewer than half were gain plan applications. At another, three search terms yielded three plans, and we still don’t know whether that’s all of them.

The problem is not that the documents are concealed; it’s that there’s no reliable way to find them, and therefore no way to distinguish an authority with few gain plans from an authority whose search term we’ve not guessed correctly. We recently submitted 41 Freedom of Information requests asking for a list of biodiversity gain plan applications, but so far only one authority has given us the information we requested (Greenwich Borough Council). The others that have replied so far, such as North Somerset Council, have refused our request on the basis that ‘The information you have requested can be found on our Planning Portal’. We have asked for an Internal Review of these refusals.

There are two further obstacles: some plans are published as scans carrying no text layer, so they cannot be searched even once located, and in four decided cases from one authority the metric is published while the gain plan is not. This is not unusual.

The practical consequence is that a member of the public who wants to know how biodiversity net gain is being delivered, say on a development near them — and even when they know the original application reference — will in many cases still not find the answer. The regime may be ‘transparent’ as a matter of law but it is unsearchable as a matter of practice.

How developers deliver the gain plan

Question 4.6 of each gain plan asks the developer how it will reach the target percentage . Across the 263 gain plans we found these answers:

4.6 answerGain Plans
On-site142
Both on and off site69
Off-site43
Both boxes ticked (contradictory)2
Unanswered7
Total263

So 112 gain plans — 43% — state that all or some part of the BNG required will be delivered away from the development site. That is a much higher rate of off-site reliance than the Biodiversity Gain Sites Register alone would suggest, because a development that delivers everything on site never appears on the register . The register can tell you where off-site provision is delivered, but not how often off-site provision is used, so it systematically understates it.

Is all the BNG required delivered?

The statutory requirement requires a minimum 10% BNG increase in area, hedgerows and watercourses habitats (it applies separately to each of these habitat modules). A scheme that adds, say, 30% of area units but fails to achieve at least a 10% increase in hedgerow units has not met the BNG requirement.

Taking area habitats, where 224 gain plans state figures we can analyse, the median net gain is +15.1%. That sounds sufficient, and for most schemes it is, but we’ve found that this value is not representative of the whole dataset. Twenty-seven gain plans record an area net gain below 10% on their own figures. Another ten record a negative area net change. The largest recorded loss is −62.7%.

There is also a long tail of very small sites recording enormous percentages: 18 gain plans exceed +100% BNG and two exceed +1,000%. These are almost all sites with a baseline close to zero — say a car park or a concrete garage base — where a handful of new planters produces a percentage gain that means very little. Any analysis that averages percentages rather than pooling units will be dominated by them.

The hedgerow and watercourse modules are where the failures concentrate. Eighty-four gain plans state hedgerow figures; the median is +72.8%, but eight fall below 10%. Only 14 gain plans state watercourse figures at all — and of those 14, five fall below 10%, one of them negative. Watercourses are rare in this sample and poorly served when they appear, so it is hard to draw conclusions from this limited dataset.

Applying the test across all modules shows that 190 gain plans meet 10% everywhere, 35 do not, and 38 cannot be assessed based what the gain plan discloses.

Where do the off-site units go, and do they exist?

One hundred and four gain plans record post-intervention units at section 7.5 of the gain plan — that is, they state an off-site position in figures. Only 73 of those can be matched to an allocation on the Biodiversity Gain Sites Register, totalling 77.88 area habitat units.

The gap between those two numbers is the most consistently troubling thing in the dataset. It has several causes, and we have separated them in the register that accompanies this piece. Some gain plans record the whole habitat bank rather than the units allocated to the development, inflating the figure by a factor of ten or more. Some repeat their section 6 on-site figures in section 7, so the same units are counted twice. Some record a positive off-site uplift with no gain site reference at 7.2 and no allocation on the register at all. Twenty-seven gain plans fall into that last category — an off-site gain asserted in an approved document, with nothing on the statutory register to correspond to it. However, it may be that these sites have yet to purchase their offsite requirements.

The reverse case also occurs: 11 gain plans have units allocated on the register while the plan itself records no off-site gain.

Unit density: more habitat, no more biodiversity

Pooling the metrics we hold — 143 metrics covering 134.5 hectares of on-site area habitat — produces a finding that percentages conceal.

 BaselinePost-development
Habitat area (ha)134.53138.25
Biodiversity units424.65424.97
Units per hectare3.1573.074

This table covers on-site area habitats only and excludes hedgerows and watercourses, which are linear habitats, and off-site purchases. It also predates the most recent additions to the dataset, so treat it as indicative of the 143 metrics we hold rather than of all 263 plans.

Across these sites, habitat area rises by 2.8% while total biodiversity units are flat, and unit density falls by 2.6%. The 10% gains recorded scheme by scheme do not aggregate into a 10% gain in on-site units, because a large share of the recorded gain is bought off site rather than created on it, and because what is created on site tends to be lower in distinctiveness and condition than what was there before. Greener, but with a lower habitat value.

What the documents show

Alongside the dataset, we maintain a register of defects — matters visible in the approved document itself, without site visits or ecological judgement. As of today it records 143 defects across 104 gain plans, from 263 held: a defect rate of 40% across 28 of the 31 authorities.

These are not close calls. They include gain plans dated before the survey they rely on; mandatory fields left blank; section 6 net-change figures that contradict the section 6.3 and 6.4 values above them; post-development values entered in the pre-development box; section 7 left empty on a gain plan that states the gain will be achieved partly off site. Every entry cites the figures it rests on, so any authority that thinks an entry is wrong can check it against its own document.

A distinct category is worth separating out. In four cases from one authority, a search of decided applications returned a statutory metric calculation but no biodiversity gain plan at all. At one of those sites the metric records the development losing 32% of the baseline area units. Off-site provision could in principle make that up — but the document that would say so, the gain plan, was not published. Under paragraph 13 of Schedule 7A, approval of the gain plan is the condition on which lawful commencement rests. It is the document that matters, and it’s the one that’s missing.

That case is worth dwelling on, because it’s the visibility problem meeting the compliance problem . A metric published without a gain plan is not a filing error. Under paragraph 13 of Schedule 7A the approved gain plan is the document on which lawful commencement depends, and it is the one document a reader cannot find. Whether it exists and was not published, or was never required, or was never produced, cannot be determined.

Why the numbers have fallen in our audit

Two months ago this analysis would have reported a defect rate of 49%. It reports 40% because we audited our own dataset before publishing it, and because we corrected it again afterwards when an authority showed us we were wrong. Both times the effect was to remove findings, not to add them.

Machine transcription fails silently. A field the extraction misses looks exactly like a field the applicant left blank, and a blank on our spreadsheet had been turning into a finding against a named authority. We compared 2,409 fields against the source documents and found 58 errors — a rate of 2.4% — of which the largest group were fields recorded as blank that were in fact fully answered.

The worst of it concerns tick boxes. Question 4.6 is a tick box, and so are 4.1, 4.7, 4.13 and 5.2. None of these PDFs stores its ticks as form data: the tick is drawn on the page, and every text extractor reports a ticked box and an empty one identically. A gain plan that answered the question looked exactly like a gain plan that ignored it. We had recorded 30 gain plans as leaving 4.6 blank and had made findings against 27 of them. Re-reading every box by measuring the ink inside it showed that all but one had answered. Thirty-one register entries were withdrawn.

We mention this because anyone building a dataset from these forms by text extraction has the same problem and may not know it. If your BNG data has tick-box fields in it, they are incorrect.

The full method, what was tested, what was found and what remains unverified, is set out in the audit statement published alongside the register. It includes the things we still cannot vouch for: only 4.6 was read in full across the whole set, and 11 of the gain plans are not on the Defra template at all, so questions cannot be said to be unanswered on them.

What this evidence fails to show

Six filters sit between this dataset and the population of approved gain plans in England:

  • The authorities are self-selecting, being those whose portals expose gain plan applications in some sort of searchable form.
  • The search of each portal may not have found every application.
  • Only decided applications are included.
  • Only published documents can be tested.
  • Fewer than half the gain plans have a metric published alongside them.
  • A blank in the dataset is not proof of a blank on the form.

The figures here should therefore be read as a floor on the rate of defects among approved biodiversity gain plans, not an estimate of it. A 40% defect rate among gain plans that were found, decided, published in full and then audited downward says nothing reassuring about the gain plans that were not found.

It is worth being explicit about what the first filter does. The authorities in this dataset are here because their portals let us find gain plans. That is not a neutral criterion. An authority that publishes its BNG documents in searchable, consistently named form is, on the face of it, an authority paying attention to the regime and the obligations it imposes. If anything, this dataset over-represents the diligent.

The dataset, the register and the audit statement are published in full below. In the meantime: we’d like to know which authorities do this well? If your portal makes gain plans easily findable, please tell us. Good practice is easier to copy than to invent.

How to fix this

Two things could make work like this unnecessary:

  • National guidance from Defra and Ministry of Housing, Communities and Local Government on how the biodiversity gain condition should be discharged and what should be published — the sort of specification the LGA’s Planning Advisory Service could write if funded.
  • A pre-submission checklist, ideally endorsed by CIEEM, covering the handful of errors that account for most of what we found.

Neither of these solutions would be difficult and both would do more for biodiversity net gain than yet another round of metric revisions. They might also, perhaps, make the life of the poor, beleaguered planning officer a lot easier!

The full dataset (263 gain plans, 31 authorities), the non-compliance register, the BGP Full Data Extract spreadsheet and the audit statement are available via the link below. The register details every defect found, with the figures it rests on.

BGP non-compliance register

Correction, 21 August 2026

An earlier version of this piece reported 159 defects across 116 gain plans, a rate of 44%. Nine plans have since been withdrawn from the register because the planning applications they discharge were made before 12 February 2024, when the biodiversity gain condition took effect: the condition did not apply to them, so no requirement of it could have been breached. Following a query from one of the authorities listed (for which, our thanks), the figures above have been amended to 143 defects across 104 gain plans, 40%. Three further entries were withdrawn on the same day after the same authority checked the off-site allocations: in two cases the units are registered and our matching had failed to find them, and in the third an apparent discrepancy is an artefact of the plan reporting to one decimal place. The dataset figures elsewhere in this piece are unaffected, as they record what the plans state rather than whether a legal requirement was met.

The cover image shows the development at Baltic Wharf which was located on the Floating Harbour in Bristol — a former caravan park that has lost 78 well-established mature trees to make way for the development.

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’ve transcribed 160 BGPs from 21 LPAs into a single, comparable dataset.

What the data shows so far:

  • Just over under 60% (95 of 160) deliver their gain entirely on site. Another 34 use a mix of on-site and off-site measures, while 17 rely wholly on off-site units and 14 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, bespoke versions 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, or 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 the required BNG Metric calculation.
  • Some applications can’t be analysed because all that is produced (and approved) is the certificate of the off-site HU purchase – and sometimes not even that. As a result, we’ve been unable to include these in our analysis.

The information exists, but we can only conclude that the planning approval process makes meaningful public scrutiny far harder than it needs to be. Using the available standard Defra form and creating 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:

BGP Full Data Extract

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

#BiodiversityNetGain #BNG #BGS #Planning #Nature #Transparency

The Local Nature Recovery Strategy fails to deliver for Bristol

WEMCA’s Local Nature Recovery Strategy (LNRS) will fail to provide Bristol with the benefits promised for nature. While the new Biodiversity Net Gain (BNG) rules require most development in the city to increase biodiversity by at least 10%, unfortunately the LNRS will not apply to most potential development sites.

The West of England Mayoral Combined Authority (WECA as was) Local Nature Recovery Strategy was published to much fanfare last November. Defra’s blog, Kickstarting local nature recovery: a new strategy for the West of England, hailed it as the first in the country.

The LNRS is a locally led and evidence-based strategy which aims to target action and nature investment where it’s most needed. We’re told that the strategy will also focus on biodiversity net gain by increasing the strategic significance of specific habitats. However, it is hard to imagine how the LNRS will help to enhance biodiversity net gain in most, if not all, potential development sites in the city.

We might have been better off, at least as far as the application of biodiversity net gain to new development is concerned, by asking the LPA to specify alternative documents (such as those listed at the end of this article) for assigning strategic significance instead.

The issue

When calculating the impact of a proposed development on biodiversity, one factor taken into account is the strategic significance of any habitat found on a focus area for nature recovery site (coloured purple in the map above). If strategically significant habitats are created or enhanced, then their strategic significance is set to High in the Statutory Metric calculator tool and a 15% uplift to the calculation of its value is applied. Subject to which of the six LNRS areas is being considered, these are the strategically significant habitats in the city:

  • Ditches
  • Ecologically valuable lines of trees
  • Ecologically valuable lines of trees – associated with bank or ditch
  • Grassland – Floodplain wetland mosaic and CFGM
  • Grassland – Lowland calcareous grassland
  • Grassland – Lowland meadows
  • Heathland and shrub – Mixed scrub
  • Heathland and shrub – Willow scrub
  • Individual urban or rural trees
  • Lakes – Ponds (priority habitat)
  • Priority habitat (on the River Avon and the Riparian buffers)
  • Species-rich native hedgerow with trees – associated with bank or ditch
  • Species-rich native hedgerow with trees
  • Species-rich native hedgerows – associated with bank or ditch
  • Species-rich native hedgerows
  • Urban – Open mosaic habitats on previously developed land
  • Urban – Biodiverse green roofs
  • Woodland and forest – Lowland beech and yew woodland
  • Woodland and forest – Lowland mixed deciduous woodland
  • Woodland and forest – Other woodland; broadleaved
  • Woodland and forest – Wood-pasture and parkland

However, a detailed examination of the LNRS map reveals that not all parks and green spaces have been designated as focus area for nature recovery sites. It’s only those which are in one or both of the following:

  • a location where they can make a greater contribution to ecological networks
  • deprived areas with a lack of access to nature.

These designations were based on Bristol’s previous work on ecological networks within the city and where wildlife-friendly interventions are most likely to be feasible. This means that the existence, creation or enhancement of these special habitats outside these areas will not attract the 15% strategic significance uplift.

The BNG requirements

The now compulsory Statutory Metric Guide, used for calculating Biodiversity Net Gain (BNG), advises (at page 27) that: ‘Strategic significance is the local significance of the habitat based on its location and habitat type. You should assess each individual habitat parcel, both at baseline and at post-intervention, for on-site and off-site.’

If the LPA has adopted an LNRS then only the High or Low strategic significance multipliers can be used (High – formally identified in local strategy = 1.15. Low – area compensation not in local strategy = 1). If it has not adopted an LNRS, then the Medium strategic significance multiplier may also be used (Location ecologically desirable but not in local strategy = 1.10).

Where an LPA has adopted an LNRS, all those sites which have not been identified as a focus area for nature recovery site will be designated as having Low strategic significance and so attract no uplift, even if they’ve been identified as important habitats in the Local Plan or in another strategic document adopted by the Council. These documents (used where an LPA has not adopted an LNRS) can include:

  • Draft Local Nature Recovery Strategies
  • Local Plans and Neighbourhood Plans
  • Local Planning Authority Local Ecological Networks
  • Parks and Green Spaces Strategies
  • Tree and Woodland Strategies
  • Area of Outstanding Natural Beauty Management Plans
  • Biodiversity Action Plans
  • Species conservation and protected sites strategies
  • Green Infrastructure Strategies
  • River Basin Management Plans
  • Catchment Plans and Catchment Planning Systems
  • Shoreline management plans
  • Estuary Strategies

Baseline habitats cannot be uplifted

Despite the BNG strategic significance guidance, Defra has stated that LNRS designations only apply to the creation or enhancement of post-development biodiversity mitigation habitats. They don’t apply if these habitats – called the baseline habitats – are found on the site before development begins.

This means that the 15% strategic significance uplift can only be applied where offsite biodiversity mitigation is being delivered in a focus area for nature recovery site. If these habitats are being delivered elsewhere, the uplift may not be applied.

However, even if the baseline habitats were included, it is unlikely to make any difference This is because the focus area for nature recovery sites identified in Bristol are, for the most part, located in public parks or green spaces, on river banks, in riparian buffers or on railway margins, none of which are likely ever to be developed or, in many cases, used to offset habitat lost to development elsewhere.

So far, no announcement has been made as to whether any of Bristol’s focus area for nature recovery sites will be made available for offsite habitat mitigation and the proposed new Local Plan does not commit to using these sites for this purpose.

This, combined with the challenge of finding LNRS suitable for offsite habitat mitigation, registering them as biodiversity gain sites and then managing them, effectively, in perpetuity, suggests that few feasible LNRS sites will be found, especially as many sites are also in demand for public access for recreation.

We set out the process used to assess the strategic significance of habitats on our blog, Assessing habitat parcels: strategic significance explained.

Biodiversity gain: will urban nature become hollowed out?

In a boost for the environment, new legislation now obliges most developers to set out how they will achieve at least 10% more biodiversity than already exists on their proposed development sites.

Developers must now show how they will improve the biodiversity of their development site as a result of their works. Developers must record the (baseline) on-site habitats that exist before development starts and show how they will either enhance or replace these on site. If their proposals fail to reach the 10% threshold, the developer may provide the shortfall elsewhere. This post-development mitigation should be done as closely as possible to the development site, or at least within the Local Authority. However, if this isn’t possible, they can use approved sites anywhere in England.

This approach is called the Biodiversity Gain Hierarchy (found in Schedule 7A of the Town and Country Planning Act 1990 at section 37A). The Hierarchy says it’s a priority to avoid the ‘adverse effects’ to ‘onsite habitat with a habitat distinctiveness score … equal to or higher than four.’ If this can’t be avoided, only then is mitigation permitted. In our experience, nearly all developers ignore the requirement to avoid adverse effects and move straight on to mitigation.

Since the introduction of the Bristol Tree Replacement Standard in 2013, developers (and planners) have ignored the policy requirement to avoid tree removal where at all possible. Instead, they’ve moved straight on to providing compensation for the trees lost to the development. As a result, the money set aside for replacement tree planting was not spent (on occasion reaching nearly £1 million) and many of the lost trees were never replaced.

Under the Hierarchy, habitats that score four are designated as having medium distinctiveness. While many habitats have medium distinctiveness, many don’t. For example, managed grassed areas (called ‘modified grassland’) are often found on urban sites but have a low distinctiveness score. So, too, do many other urban habitats such as allotments and gardens. Developers are not required to avoid harming these, though losses to these habitats must still be mitigated.

There’s no definition of what an ‘adverse effect’ is or any guidance on how it is assessed. However, recent advice from the Bristol’s Chief Planner about the meaning of ‘harm’ suggests that this could be interpreted very broadly or simply ignored because some sort of mitigation will always be available.

In the last extreme, developers may purchase biodiversity credits. We wait to see how this and the offsite biodiversity mitigation market evolves, but a 2012 paper published in the Harvard Environmental Law Review suggests that such environmental markets are prisoners of their own geography because the space available is always constrained:

Markets for water quality, biodiversity, endangered species, fisheries, air quality, and aquatic resources, to name a few, must recognize that the commodities they trade exist at particular geographic scales, and set appropriate spatial limits on the redistribution of environmental quality. The size of geographic trading areas has significant implications for the economic viability of markets and the ecological quality of their offsets.

This will be a particular challenge when providing biodiversity mitigation in urban areas.

The squeeze on green spaces

Land use in Bristol is subject to intense competition by many stakeholders. This is especially true for our green and open spaces, which offer many ‘services’ beyond just habitat provision. There is very little, if any, space available for new biodiversity to be created. At best, some green spaces might be enhanced, but opportunities to do this are likely to be very limited.

For example, Bristol Tree Forum’s examination of the three proposals to develop Bedminster Green shows that, if these proposals are allowed, then nearly 400 new trees will need to be planted to compensate for the lost tree habitat – a medium distinctiveness habitat. There’s no room to plant these trees on site, so offsite provision will be needed. There are very few opportunities for doing any new tree planting (as opposed to replacing lost trees) in the surrounding wards or even across Bristol, let alone, as is usually required, within a mile of a development site.

Instead, these replacement trees will have to be planted somewhere else: ‘in some foreign field that is forever Bristol’. This will inevitably lead to a net loss of biodiversity across the city as nature is ‘hollowed out’. This is unacceptable. The whole purpose of the new biodiversity gain regime is to improve overall local biodiversity, but it seems inevitable that Bristol will instead see a steady, inexorable decline.

We are disappointed that the current draft of the new Local Plan addresses none of these issues and have said so in our responses to the latest consultation:

Bristol Tree Forum representations in relation to the Bristol Local Plan 2023 Publication Version consultation & BTF Representations on the Bristol Local Plan 2023 publication version – Addendum.

A shorter version of this article was published by 24/7 as:

‘It seems inevitable Bristol will see a steady, inexorable biodiversity decline’

Why Bristol needs a Biodiversity Net Gain SPD

The new Biodiversity Net Gain (BNG) obligations, which came into force last February, aim to improve our natural environment by requiring that all new developments have a positive impact (a net gain of at least 10%) on biodiversity.

For this reason, we believe that Bristol urgently needs to follow the lead of the other west of England councils, B&NES, South Gloucestershire and North Somerset, and adopt a Biodiversity Net Gain Supplementary Planning Document (SPD). A list of other local authorities that have adopted their own biodiversity SPDs can be seen here on the Local Government Association planning advisory service website – Biodiversity Net Gain in Local Plans and Strategic Planning.

Councils are encouraged to develop a locally specific SPD as part of their Local Plan. This would:

  • set out local priorities and strategies that require developers to deliver BNG locally
  • ensure that BNG contributes to wider nature recovery plans such as the newly launched Local Nature Recovery Strategy (LNRS) and other local objectives, and help ensure that the right habitats are provided in the right places
  • link BNG requirements to other strategic objectives and place-making policies in the Local Plan, to ensure a more holistic approach
  • set requirements for managing and maintaining habitats provided through development.

Having such a document would clarify exactly what developers need to do in terms of the BNG requirements. While these requirements have many gaps, they are now, as it were, the only game in town and we must try to make the best of them. We believe that developing a robust BNG SPD could help mitigate these problems by adding tougher conditions that developers must meet.

With the launch of the LNRS – a collaborative effort to help people and organisations within WECA and North Somerset take effective action for nature – it has become more important than ever for Bristol City Council to bring this strategy into action, especially where new development is planned.

Two factors causing us the most concern (there are others) are the exclusion of stakeholders from the BNG decision process and the lack of enforcement of BNG requirements.

Consulting stakeholders

We’ve long been concerned that the new BNG regime excludes stakeholder groups such as ours from engaging with and commenting on the approval process for Biodiversity Gain Plans (BGPs) because of the way the planning rules work.

The BGPs are a post-approval requirement (see Schedule 7A of the TCPA ’90, Part 2, section 13(1)), which means there’s no obligation for a developer to demonstrate how it will meet its BNG responsibilities during the application stage (although the Council could require this).

Under current rules, BGPs only need to be submitted for approval to the Planning Authority after an application has been approved. However, there’s no statutory requirement to consult any statutory bodies on BGPs or to publicise or consult on the submission of a BGP prior to its approval. It seems, therefore, that we (and other stakeholders who, like us, are fighting for everyday nature) will have no say in what is proposed, or even have any idea of what a BGP contains or how it could affect us.

Surely this goes against the principles of open governance and localism which councillors should be fighting to defend, especially where it’s likely to have a direct impact on the very places that we Bristolians love and value?

Improving enforcement

As a recent article in Local Government Lawyer magazine points out, there are serious issues around BNG enforcement that need to be resolved.

We’ve been trying to engage with council officers over this issue for some time, but so far without success. Maybe the time has come for the Council to seize the initiative? With the proposed new Local Plan moving towards its public hearings stage early next year and the likelihood that the plan will be adopted next April, maybe now is the time for the reconstituted Local Plan Working Group to take this in hand.

This is what the Council currently requires from developers: Biodiversity Net Gain for major development and small site planning applications. At best, this is only advisory, unlike an SPD which would be part of the Local Plan and so compel the developer’s compliance.

One of our fears is that some planning conditions, such as this one from the recent, pre 12 February 2024, Bristol Rovers Memorial Grounds application are unenforceable. In this case they only oblige the club to submit a proposed Landscape Ecological Management Plan (LEMP). They did this last June. However, the wording of the condition means that the club is not obliged to perfect this or even to carry it out.

Readers may recall that the development had been completed and the new stands occupied long before the main application was made, well before this and other conditions had been submitted or approved. In addition, as part of the eventual approval, the club agreed to plant a wood on a piece of unused land it owns to the south of the new stadium (the area shaded green below), but this has not yet been done.

As part of this agreement, the club is expected to enter into a LEMP to plant the wood and then maintain it in perpetuity. The LEMP Condition says:

Within 6 months of the date of consent, the applicant shall submit a 30-year Landscape and Ecological Management Plan (LEMP). This should address retained features of ecological interest, together with mitigation and enhancements to be provided. The LEMP should set out management compartments, objectives, and prescriptions for all new proposed soft landscaping/planting to demonstrate how all habitats will be managed to their target condition (as specified in the BNGA). It should also show how management of the site will be resourced and monitored.

In this example, all that can be enforced is a failure to submit the LEMP within six months, which, in this case, has been done. There is a S106 imposing LEMP obligations but this is toothless and, anyway, only the Council can enforce it – which it is not obliged to do.

There’s also the practical effect of the Biodiversity Gain Hierarchy – Biodiversity net gain Guidance Paragraph: 008 Reference ID: 74-008-20240214. This effectively means that the developer need not achieve any net gain on site, or even locally, but can instead deliver it anywhere in England or, as a last resort, simply buy BNG credits, though at a premium.

For example, the grant conditions – 11 (The BGP condition), 12 & 14 – in the recent, post-12 February Council application, The White Hall, Glencoyne Square, are unenforceable given their wording as there is only an obligation to submit; again, approval is not required. We assume that a s106 agreement and a Habitat Management and Monitoring Policy (HMMP) will need to be produced, but, at the moment, we still have no idea how the self-acknowledged 38.09% habitat loss will be mitigated, or where.

Given the intense competition for space in the city, it seems inevitable that, as a result of the application of the Biodiversity Gain Hierarchy, Bristol’s nature will, bit by bit, be exported to some far-off field that no one knows or cares about. In theory, a BNG SPD could at least try to ensure that habitats lost to development are replaced locally wherever possible.

It’s been suggested that new SPDs can’t be delivered until after the new Local Plan has been examined and formally adopted. Maybe, but we see no reason why we can’t at least start a conversation about this. As it is, the proposed Local Plan will need substantial redrafting to align with the new BNG rules, having been adopted by the Council before these had been finalised.

It’s also been suggested that there are neither the funds nor enough officer time available to develop this new SPD. However, since all the adjacent councils (members of WECA), and many farther afield, have developed, or are developing, their own SPDs, we can surely save time and expense by looking on these as templates from which to build our own. The examples above alone make it all the more urgent for issues such as this to be resolved with the early adoption of a BNG SPD. We urge the Council to commission officers to draft an SPD as a matter of urgency.

A shorter version of this blog was published in 24/7 as: ‘Without enforcement, Bristol’s nature will be exported bit-by-bit‘