IEMA's Policy and Engagement Lead (Biodiversity and Natural Capital) Lesley Wilson comments on this week's Defra consultation on Biodiversity Net Gain Regulations and Implementation.


The ambitious Defra Consultation on Biodiversity Net Gain Regulations and Implementation opened 11 January and closed 5 April 2022. IEMA held two insightful and informative workshops to consult with members in March, and hosted a webinar with Defra and Natural England in February to create a robust response.

Key to the success of the implementation of biodiversity net gain (BNG) in the planning system is effective monitoring and enforcement. Just as essential are the relevant resources to do this. Upskilling, particularly for Local Authorities, will probably be needed and this should be provided too where necessary.

The consultation offered a number of options for percentage net gain in different circumstances, the exclusion of different sites, and different transition periods. For effective implementation, and to avoid confusion and promote consistency and effective take up, complexity should be kept to a minimum, for example, at least 10% BNG should be required for most types of developments.

Annex B of the consultation included a draft template for a Biodiversity Net Gain Plan to be submitted by developers. This could be strengthened by including vital sections such as: how any plans fit with Local Nature Recovery Strategies; a named individual who will carry out the Plan and their competency to do so; the inclusion of assumptions and limitations (currently optional); and robust guidance for users of the Plan including an example Plan.

Research has shown that on-site biodiversity gain has failed in the past due to lack of monitoring. Having a register, the same as that proposed for off-site and biodiversity units (to be used in habitat banks), would allow for both assurance that biodiversity gain is being delivered but also strategic oversight across biodiversity gain activities.

Broadly, Defra’s BNG Plan is welcomed but as always the devil is in the detail, and the output and outcome of this consultation, and the resulting legislation and guidance is keenly awaited. Defra should work with businesses to ‘stress test’ the final proposals after publication and fix any issues to ensure support and good take up.

IEMA's written evidence can be found here.

Photo of Lesley
Lesley Wilson

Policy and Engagement Lead

Lesley is Policy and Engagement Lead at IEMA with a focus on biodiversity and natural capital. Lesley also supports IEMA’s role as Secretariat to the UK Business and Biodiversity Forum, working with businesses to raise the profile of, mainstream, and share good practice in, biodiversity. Lesley joined IEMA in December 2021 after 11 years delivering projects, programmes and solutions for business in the field of environmental sustainability for the British Standards Institution (BSI), including ground breaking standards in biodiversity net gain and natural capital. Lesley has a qualification in business management (MBA) and climate change management, and mentors environmental students at the University of Westminster.