Biodiversity Net Gain Consultation The Government’s 25 Year Environment Plan published last year promised that any development taking place would provide an environmental net gain in order to try and address the loss of wildlife in England. To proceed towards this aim, the government recently consulted on applying biodiversity net gain to the planning process. The Government states in the consultation that: An effective net gain policy could enable us to build the houses, commercial premises and local infrastructure we need and at the same time improve our environment by more than compensating for biodiversity loss where it cannot be avoided or mitigated. In theory, this looks like it could be a really great policy, but in practise there are a number of issues that we have concerns about. Firstly, some habitats are just irreplaceable because of their complexity, the length of time taken to establish or due to changed climatic conditions. This group of habitats includes ancient woodland, limestone pavement, sand dunes and heathland. We are concerned that developers will be able to develop these sites using net gain as a convenient excuse to do so. Secondly, habitats sit within a specific place in the landscape because of the underlying conditions geology, soil, rainfall and aspect provide. Habitats need to be understood within their landscape context, where they are part of the landscape fabric which helps local ecosystems to function and species to move through it. Net gain appears to forget this fact, and the consultation talks about biodiversity “units” or “credits” as if it were possible to just move an area of habitat from one place to another with no ill effects. Thirdly, there is a grave concern that there won’t be adequate resources provided to local authorities and Natural England to oversee any scheme. With no oversight of the scheme, developers won’t be held to account, and species will be lost and habitats will be replaced with inferior, less biodiverse wildlife. Fourthly, we are very surprised that the Government is only supporting biodiversity net grain rather than environmental net gain such as enhancing tranquillity, reducing flood risk, carbon sequestration, and access improvements. We consider that this is a missed opportunity on the basis that enhancing biodiversity in many cases also works towards other net gains, such as tree planting increasing carbon sequestration, and reinstating water meadows helping with flood risk reduction. We, along with a number of other organisations (including CPRE) have provided detailed responses to this consultation. You can read ours here.