Lack of ambition on Biodiversity Net Gain leaves scheme missing the mark for nature one year on

6 February 2025

CORRECTION: Please note that our original research stated that the BNG Register contained 609ha of offsite BNG habitat creation or enhancement via Local Authorities or 984ha offsite (if including ecology companies). Since our data was collected in December 2024 and January 2025, this has slightly increased to 680ha for Local Authority off-site BNG habitat or 1220ha (when including ecology companies) as of 6th February 2025. We have acknowledged and changed these figures.

This does not substantially change the results, still showing a notable shortfall for BNG habitat delivery compared to Defra impact assessment estimates. When combined with the best available data for onsite BNG habitat creation/enhancement of 93ha* the updated figures show a shortfall of BNG habitat delivery of around 86% (if looking at Local Authority data only) or 78% if including ecology companies, when compared to Defra median estimates.

*NB we acknowledge that the 93ha reported by Local Authorities via FOIs is a likely under-reporting. But with no official monitoring of onsite gains by Government this is the best data available. This likely under-reporting shows that Local Authorities are not collating this data in any meaningful way identifying a major monitoring gap. This has repercussions for enforcement and delivery, and the ability of the Government to accurately assess the scheme's success.

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• Just 680 hectares of land has been secured for offsite habitat creation and enhancement under the flagship Biodiversity Net Gain scheme according to official figures, with a further 93 hectares of onsite habitat reported by Local Authorities under FOI requests.
• This combined 773 hectares has dramatically missed the Government’s BNG delivery expectations, achieving just half the minimum amount of annual habitat creation expected.
• Environmental groups are calling for the BNG scheme to be strengthened and for the upcoming Planning and Infrastructure Bill to implement key planning reforms that will benefit nature alongside moves to speed up the system.
  

New research from Wildlife and Countryside Link, as part of its Wilder By Design nature-friendly planning reform campaign, has found that just 680 hectares of land offsite and 93 ha on-site has been reported by Local Authorities under the BNG scheme, since the policy's introduction[1]. This is just a fraction (less than 13%) of the 5,428 hectares of habitat Defra estimated was likely to be generated annually by BNG and is less than half the minimum amount of habitat expected to be delivered per year. [2]

BNG was developed as part of the Environment Act and came into force on 12 February last year. The policy requires developers to create or enhance habitat to compensate for any harm to nature from new developments and deliver at least 10% “biodiversity net gain” (measured by the quality, extent, significance and type of habitats created). Developers are able to undertake nature recovery work on-site, or by purchasing credits for off-site habitat enhancements [3].

Based on Freedom of Information requests sent to the 317 local authorities in England, and analysis of the offsite Biodiversity Net Gain register, the new findings also show that [4]:

• In the offsite BNG register Local Authorities reported 680 hectares off-site have been set aside for nature recovery measures under BNG to date. This is an area similar in size to the Glastonbury festival.[5]
• In FOI responses Local Authorities reported a further 93 hectares of habitat gains on-site within developments (an area slightly bigger than London’s Clapham Common) that was created or enhanced for nature under BNG. The full extent of on-site gains is unknown. This reflects the lack of a requirement to report or monitor onsite BNG gains.
• An additional 786 hectares of land have been proposed by Local Authorities as potential offsite habitat banks, but have yet to be approved.
  
• Local Authorities are legally allowed to set requirements for gain above 10%. However, guidance from the last Government said that Local Authorities should not set requirements above the legally required 10% for BNG except in narrowly defined conditions. Only 4 Local Authorities in England (1.2%) have so far implemented more ambitious 20% BNG requirements. [6]
  
• Positively, 30 Local Authorities have upcoming policies which, if adopted, will require more than the minimum mandatory 10% net gain. 11 of these were not identified as doing so in research on BNG ambition in 2024. [7] However, even if all these policies are put in place, only 1 in 10 Local Authorities will have schemes requiring over 10% BNG.
• Since January 2024, 2 authorities have decreased their ambitions (Birmingham City Council has reduced proposals for BNG on all developments from 20% to 10% and the London Borough of Richmond reduced proposals for 20% on specified types of development to 10%).
  

Richard Benwell, CEO of Wildlife and Countryside Link said: “BNG is full of potential, but it’s also full of holes. Holes in ambition, which remains limited to just about offsetting harm to habitats. Holes in implementation, with huge numbers of planning applications falling through the gaps. And holes in enforcement, with no way to check that many of the promised gains for nature ever happen. Nature recovery and development can go hand in hand, but only if rules to protect wildlife are effective. Ecosystems are Critical Natural Infrastructure and it’s vital that the planning system plays its part by dedicating enough space for nature to thrive. Fixing the holes in BNG is just the starting point. This year’s planning reforms must ensure that at least 30% of England is protected for nature and that every new development is wilder by design.”

Beccy Speight, RSPB chief executive, said: “BNG was meant to help restore nature but with ambition set so low from the very start there was little hope of it delivering for nature or communities. One year on, it’s clear this scheme is a huge missed opportunity that’s currently failing on all counts. There is widespread support for ensuring most new developments create or restore more habitat for nature than they destroy but for that to happen we need to give Local Authorities the right tools and resources to support nature recovery. We also need to set out where nature needs to be protected at scale through a national spatial plan, and build nature-friendly design into our new homes and communities. That way we can get the win-win intended for nature and for development."

Sarah Fowler CEO of WWT, said: ““These findings show that the Biodiversity Net Gain scheme is not being prioritised enough by this government. If these trends continue then nature, once again, risks becoming an afterthought in favour of fast-tracking development. We can’t afford to wait until 2029 to review this scheme. If the Government wants to get nature restoration back on track, then delivering new habitats from wetlands to woodlands will be key. Giving communities more access to these habitats through BNG will also be a huge boost to health and wellbeing, with even a short amount of time spent exploring wetlands shown to boost our mood."

Kit Stoner, CEO of Bat Conservation Trust, said: “Fixing Biodiversity Net Gain could help towards the Government’s manifesto promise to ‘ensure development benefits communities and nature’. Our 18 British bat species have suffered historical declines, and many are now reliant on human structures for their very survival. New development needn’t come at the expense of wildlife but in order to achieve this, nature and wildlife cannot remain a postscript in planning policy, it must be written into our planning approach at all levels of Government and in upcoming planning laws.”

Wildlife and Countryside Link continues to support the principle that developers should pay to restore nature when harm cannot be avoided. However, they say that the BNG scheme is not yet delivering its potential because of broad exemptions, limited resourcing for Local Authorities and lacklustre monitoring and enforcement meaning that developers can avoid BNG requirements entirely.

Official guidance from the previous Government also set low ambitions for Local Authorities, discouraging them from setting local requirements above the 10% BNG legal minimum. Natural England has admitted publicly and in Defra’s impact assessment that the 10% BNG target is likely to only balance out nature loss not secure nature gain, meaning that higher ambition is needed to secure any notable increase in nature recovery.

The new report comes ahead of the Government’s expected overhaul of the planning system through the proposed Planning and Infrastructure Bill. In December environmental groups including the RSPB, WWT, The Wildlife Trusts, Woodland Trust and CPRE, joined forces in the ‘Wilder by Design’ campaign urging Ministers to ensure that planning reforms deliver a planning system that works to restore nature, not just mitigate harm. 

Ahead of the first anniversary of the introduction of BNG, environment groups are calling on the Government to take key steps in its planning reforms, to ensure the system works to protect and restore nature alongside speeding up the planning process:

• Increase the effectiveness of BNG by enhancing monitoring and enforcement, reducing exemptions and setting ambitious BNG targets for infrastructure and marine development.
• Guarantee that proposed planning reforms,that aim to speed up planning through an off-site nature fund, do not weaken protections for protected wildlife and (where harm cannot be avoided) will deliver off-site nature compensation far more effectively than BNG has to-date.
• Deliver crucial legal reforms in the Planning and Infrastructure Bill which:
  • Boost nature - including by enhancing the size and condition of protected nature sites, increasing nature powers and resources for National Parks and National Landscape Authorities, and banning damaging fishing and industrial activity in Marine Protected Areas
  • Require developers to ensure appropriate nature-friendly features like swift bricks, bat and bee boxes and native planting are used and ensure irreplaceable nature isn’t harmed
  • Identify the most appropriate sites at scale for nature and development through a National Spatial Plan
    

ENDS

Notes to Editors:

The Wilder by Design campaign is supported by 21 environment organisations including RSPB, The Wildlife Trusts, Friends of the Earth, Woodland Trust, Bat Conservation Trust, Campaign for National Parks, Wildlife Gardening Forum, IFM, British Mountaineering Council, Open Spaces Society, Earthwatch, Rivers Trust, Cornwall Seal Research Trust, ARC Trust, Mammal Society, CPRE (The Countryside Charity), Butterfly Conservation, Whale and Dolphin Conservation Trust, Earth Trust and Froglife.

1. The figure represents total secured land for onsite and offsite habitat banks as of February 2025.
2. Natural England calculated Biodiversity Net Gain cost-benefit scenarios in its BNG impact assessment including the annual amount of habitat creation expected (see p53). This ranged from a low estimate of 1,551ha of habitat, to a mid (likely) estimate of 5,428 ha of habitat and an ambitious estimate of 17,060 ha per year. The 680 ha of habitat creation onsite and 93 ha onsite that Local Authorities reported on via BNG in the last year represents only 49.8% of the lowest estimate, 13% of the mid-estimate and 0.05% of the ambitious estimate - leaving a major shortfall on expectations.* *Please note our research compared only Local Authority data from our FOI and the BNG register to these figures. In addition to this in the Biodiversity Net Gain register, two companies have also registered habitat banks. RSK Biocensus Limited, an ecology consultancy, secured a total of 432.68ha of land for net gain and Harry Ferguson Holdings have secured 32.55ha across 4 sites. But even if that figure is combined with those from Local Authorities this equates to 1217ha (equivalent to just 78% of the minimum estimate from Natural England)
3. BNG was developed as part of the Environment Act 2021 and originally set to come into force in November 2023, however, the introduction was delayed to February 2024 for large sites and April 2024 for small sites. Since February 2024 it has been mandatory for all local planning authorities in England to require at least 10% BNG on all planning applications that meet the criteria which Defra has set.
4. A Freedom of Information request was submitted to all 317 local authorities in England in October 2024, asking:
   1. any policies for BNG made since February 2024
   2. how many hectares of land for BNG has been secured onsite and offsite
   3. Responses to the FOI were not provided by 28 councils. In these cases, information was supplemented by independent research and is true and accurate to our knowledge. Further complementary analysis on habitat creation using the BNG register was also conducted. Read the full research summary (including full methodology and lists of local authorities considering policies of more than 10% net gain) here.
5. The Glastonbury Festival is hosted on 1500 acres of land - around 610 hectares. Clapham Common is over 85 hectares in size.
6. 4 local authorities (Guildford Borough Council, Maidstone Borough Council, Mole Valley Council & Worthing Borough Council) have adopted policies that require 20% Biodiversity Net Gain (Worthing requires this only for previously developed sites).
7. Ahead of the launch of BNG in February 2024, Wildlife and Countryside Link published its report into what percentage of BNG Councils in England were required for developments in their local plans or would be seeking in their local plan reviews. The report can be found here.