The Office for Environmental Protection (OEP) has written to the Secretary of State (SoS) for Environment, Food and Rural Affairs Steve Reed responding to his department’s consultation on improving the implementation of Biodiversity Net Gain (BNG) for minor, medium and brownfield development.
The OEP’s letter to the SoS recognises Defra’s overall aim to improve the implementation of BNG whilst noting that Defra should approach such reforms with caution and that biodiversity net gain is still in its early days.
Dame Glenys Stacey, Chair of the OEP, said: “Biodiversity Net Gain is an important programme for the environment in England.
“As we stated in our 2022 advice, we support its core ambition to ensure that habitats for wildlife are overall left in a better state than prior to development.
“In our view, any changes should aim to ensure that BNG contributes more to wider approaches to improving nature, aligns with the forthcoming revision of the Environmental Improvement Plan, and enhances prospects for meeting legally-binding targets for nature.”
The OEP’s response also highlights areas of concern across the series of proposals.
In its response, the OEP expressed concerned that the proposal to exempt minor development will significantly narrow the scope of biodiversity net gain and is likely to lead to habitat loss across small-site developments. The OEP also highlights that the proposals to exempt minor development may adversely affect the nascent biodiversity unit market.
Dame Glenys said: “The consultation includes proposals for significant design and methodological changes to BNG to address apparent challenges in its implementation. However, it does not present detailed evidence about the challenges that the proposals are intended to address.
"We also note that while this consultation includes a variety of proposals, it does not include any assessment of the anticipated impact of the proposed reforms. This lack of evidence is perhaps understandable, given the short time that BNG has been in operation."
However, the OEP chair added: “We are concerned that, in the absence of sufficient evidence, the proposed changes may have negative unintended consequences.”
The OEP’s response includes a number of other recommendations. Read the submission in full by pressing the blue button at the side of this page.
