Introduction

Welcome!

Biodiversity Net Gain is development that leaves biodiversity in a better state than before. In 2016, IEMA, CIRIA, and CIEEM with support from Balfour Beatty, published Good Practice Principles to help address this challenge. These Principles were developed from a series of consultations and now sit at the core of achieving Biodiversity Net Gain. The Principles are available HERE and, earlier this year, practical guidance to support their implementation was published, which is available HERE.

Please make sure you have a copy of the Biodiversity Net Gain principles when you start this survey, as the questions refer to specific principles

As our experience of Biodiversity Net Gain has developed, we think it is time we reviewed the Principles to ensure that they remain appropriately aspirational yet achievable. Our aim remains to support the delivery of high-quality Biodiversity Net Gain by clearly defining the underpinning principles of good practice. We are seeking views on how the Principles are working to shape Biodiversity Net Gain delivery and how they potentially may be improved. (NB: We are working on the social aspects of BNG, which relate to Principle 3. Please look out for a separate consultation on this).

We hosted a webinar in September 2019 to gather initial feedback on the Principles and will be seeking further practitioner feedback via focus groups and this survey. This survey builds on the webinar and all responses will be reviewed by a technical working group, with the aim to publish any revision to the Principles in early 2020.

Thank you for your time to complete this survey, we greatly appreciate your inputs.

Confidentiality and consent

All survey responses are confidential and will be anonymised in any publications. All information collected will be accessible only to the team hosting this survey (listed below) and will be stored securely and processed in accordance with the UK Data Protection Act.

Please note that participation in this survey is voluntary and there is no obligation to complete it. You may ask for your contributions to be withdrawn from the survey at any time before 16th December 2019, by emailing enquiries@cieem.net

The team hosting this consultation are: Nick Blyth and Spencer Clubb (IEMA), Sally Hayns (CIEEM), Owen Jenkins and Emma Fryer (CIRIA), and Julia Baker (Balfour Beatty). If you have any questions about the consultation, please email enquiries@cieem.net

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* 1. Your name (optional)

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* 2. About You

What best describes your professional organisation?

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* 3. Approximately how many years of professional experience do you have?

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* 4. Have you worked on, or been involved with, Biodiversity Net Gain for development projects?

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* 5. Principle 1 is to apply the mitigation hierarchy. The principle states that compensation for losses only happens where losses cannot be avoided. Feedback affirms that good design can achieve BNG without offsetting.  Although the principle is consistent with this, there is potential to more explicitly explain and encourage the ‘maximising of gain’ at all levels in the hierarchy.  Should Principle 1 be updated to reflect this?

Should Principle 1:

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* 6. Are there other improvements to Principle 1 that you could suggest?

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* 7. Principle 2 is to “avoid losing biodiversity that cannot be offset by gains elsewhere”. It then only refers to irreplaceable biodiversity. We have received feedback that Principle 2 should also refer to statutory designated sites. Acknowledging that the Principles are UK-wide, should Principle 2 be updated to also refer to statutory designated sites?

Should Principle 2:

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* 8. Are there other improvements to Principle 2 that you could suggest?

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* 9. Principle 4 is to “address risks” and includes mitigating difficulty, uncertainty and other risks to achieving BNG. But it does not mention the first step of avoiding risks. A possible update is that Principle 4 refers to first avoiding and minimising risks, and then mitigating risks to BNG.

Should Principle 4:

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* 10. Principle 4 includes adding contingency to compensate for the time between losses of biodiversity occurring and the gains becoming fully realised. However, before compensation, good practice is to avoid and then reduce such time-lags as far as possible (rather than simply compensate for time-lags that do occur). A possible update is that Principle 4 refers to first avoiding and minimising time-lags and then compensating for time-lags to achieving BNG.

Should Principle 4:

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* 11. Principle 4 includes adding contingency to biodiversity metric calculations so that, in practice, more biodiversity is created in order to account for risks that BNG activities will fail. It was written at a time when people were using the Defra biodiversity metric in different ways and some people were using different metrics, so Principle 4 was not specific to a particular metric but reflected good practice to add contingency. The advantage is flexibility to ensure the principle applied no matter what metric was used. However, the disadvantage is that the phrase “apply well-accepted ways” can be interpreted differently.

The recently published Biodiversity Metric V2 (and updates thereafter) is anticipated to be widely adopted, so a consideration is whether Principle 4 refers to the Defra metric as an example on how contingency is calculated. However, whether the Defra metric will be applied UK-wide is uncertain. So perhaps Principle 4 should not refer to a specific metric but the wording on contingency could be revised to be clearer.

Should Principle 4:

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* 12. Are there other improvements to Principle 4 you could suggest?

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* 13. Principle 5 is to achieve a measurable overall gain for biodiversity and the services ecosystem provide. We have received feedback that Principle 5 should only regard net gains in biodiversity and omit ecosystem services on the basis that ecosystem services should be included in Principle 9, as part of optimising sustainability. However, some consider that biodiversity and ecosystem services are inherently linked and both should be included in Principle 5. This question was included in the consultation webinar and, as we received many comments about it, we are including it here. Please note that the next question regards Principle 9 and ecosystem services.

Should Principle 5:

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* 14. Are there other improvements to Principle 5 that you could suggest?

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* 15. Principle 9 is to prioritise BNG and then optimise the wider environmental benefits for a sustainable society and economy. Since the principles were published, the concept of environmental net gains has gained traction in some parts of the UK. However, as yet there is no government or industry accepted definition of what environmental net gains actually are. Also, the concept of environmental net gains is different from the broader concept of sustainability, which currently underpins Principle 9. Finally, and following the previous question, should Principle 9 refer to ecosystem services?

Should Principle 9:

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* 16. Are there other improvements to Principle 9 that you could suggest?

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* 17. Principle 6 is about using evidence and local knowledge when making decisions to generate the best outcomes for biodiversity. It was phrased to set out the key decisions to make (which are the bullet points) whilst enabling flexibility so that site-specific decisions can be made. The first two bullet points reflect concepts of ecological equivalency and out-of-kind offsets. Central to these is the concept of ‘trading up’ where low-value habitats are offset with gains in the same broad type of habitat but of higher ecological value. Since 2016, the phrase ‘trading up’ has become more common-place. Also the Biodiversity Metric V2 includes suggested actions to address habitat loss, which reflect ‘trading up’ principles. Given these advancements, Principle 6 could set out good practice on ‘trading up’. However there are concerns that the phrase ‘trading up’ encourages biodiversity to be viewed as a simple commodity that can easily be traded.

Should Principle 6:

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* 18. Principle 6 refers to locating BNG measures where they achieve BNG locally to the development and contribute towards wider priorities. It was written with the aim to set the outcome to achieve, while giving flexibility for site-specific decisions on whether BNG is within the development footprint, just outside, further away or a mixture.

Defra has proposed a spatial hierarchy for BNG. This prioritises the delivery of BNG on-site. If on-site delivery is not possible, then BNG should be delivered locally according to a local plan or strategy. Where this is not possible, investment in national conservation priorities may take place.

Defra’s spatial hierarchy  received wide support in the 2019 consultation, although this covered England-only. But as there was strong support, there is a consideration as to whether Principle 6 should reflect the hierarchy. This question was included in the webinar and, because it represents a shift in Principle 6 from being flexible to being prescriptive, we are including it here.

Should Principle 6:

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* 19. Are there other improvements to Principle 6 that you could suggest?

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* 20. Principle 7 is for BNG outcomes to demonstrably exceed existing obligations, which is the principle of additionality. Additionality is fundamental to achieving BNG, but without clarity on what good practice is, there is a risk that additionality will not be implemented in practice.

The IUCN Policy on Biodiversity Offsets (2016) identifies three components of additionality: 1) providing a new contribution to conservation that is 2) additional to that which would have occurred without the offset taking place and 3) does not displace or reduce other existing or future public sector funding. This reflects ecological additionality where BNG is a new contribution to conservation, and public funding where BNG is not funded by existing or (as far as known) future public funding. This definition might improve our implementation of additionality, so there is a consideration as to whether Principle 7 should adopt the components or refer to them as an example.

Should Principle 7:

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* 21. Are there other improvements to Principle 7 that you could suggest?

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* 22. The Principles were published on the basis that projects would follow industry best practice for ecological assessments of development, including CIEEM’s guidance. This includes establishing a baseline of ecological conditions before the development, so the Principles did not mention baselines because baselines were covered by other industry guidance.

Many BNG assessment use a ‘static’ baseline of a site’s biodiversity value at one point in time, before the development commences. Then qualitative and quantitative information should be used to predict the biodiversity outcomes of the development at some point in the future. For example, the Defra metric shows that the development site generates 50 biodiversity units before works commence. By following the mitigation hierarchy, the development is predicted to achieve 55 biodiversity units after 30 years, which is a 10% increase.

International good practice is to compare a development’s predicted biodiversity outcomes against the scenario whereby no development occurred. In other words, what would happen to biodiversity if the development did not proceed (which is called the dynamic baseline). For example on the site described above, in the absence of the development, biodiversity is expected to decline by 10% over a 30-year period. So when we consider this dynamic baseline, the development is preventing this 10% loss rather than achieving a 10% gain. Another example is a wildlife reserve where biodiversity in already improving in the absence of BNG measures. With a dynamic baseline, BNG would be based on the existing predicted improvement and then add to these for actual gains. Note that these are only examples.

In practice, estimating dynamic baselines is difficult, especially to quantify what future declines or increase in biodiversity might be. So while international good practice is to account for dynamic baselines, for us here in the UK, is it practical and will it improve the delivery of BNG?

Please note that this questions closely relates to additionality, as verifying that BNG outcomes are additional can involve a comparison to what would have occurred without the development.

Should the Principles:

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* 23. Principle 8 refers to “in perpetuity”. It then describes sustaining BNG over the longest possible timeframe, with the expectation that this is at least the lifetime of the development (e.g. often 25-30 years) with the objective of Net Gain management continuing in the future.

We have had feedback that “in perpetuity” is difficult in practice and including this phrase is setting unrealistic expectations.  However, we have also received feedback that the principles should set ambitions to aspire to, and that not including “in perpetuity” weakens the principles.

Should Principle 8:

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* 24. Are there other improvements to Principle 8 that you could suggest?

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* 25. Principle 10 regards transparency. The practical guide on BNG refers to communicating the full break-down of biodiversity metrics such as details of habitat condition assessments. As metrics are often a discussion point with regards to BNG, should Principle 10 refer explicitly to communicating biodiversity metric calculations in full?

Should Principle 10:

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* 26. Are there other improvements to Principle 10 that you could suggest?

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* 27. Do you have any other comments or suggestions on improving the Principles?

0 of 27 answered
 

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