Unintended Consequences

It is not only developers who are struggling with the problems posed by BNG, but there are several unforeseen, and highly significant implications for LPAs as a result of this. 

Each LPA has a government target to create ‘X’ number of new homes – This target will inevitably be missed, thus increasing pressure on Councils to agree to schemes they would prefer to reject.

Many local government ecologists have not understood that a pragmatic approach is necessary when deciding whether to agree or dispute the BNG arrangements for a given site. Many are still adhering to the concept that the first consideration is for BNG to provide onsite and struggle to move past this position. 

This lack of flexibility has several serious implications:-

• LPAs must have a viable five-year land supply – if sites are not going to be able to generate the number of homes based on the previously housing density, there are going to be serious repercussions as five-year land supplies are challenged at appeal / hearings by developers.
• If any given site is now unable to provide as many houses as previously supposed because of the ‘onsite’ BNG expectations, even more areas of development land are going to be necessary. Do we really want even greater urban sprawl? Surely it makes more sense to maximise each site. It ensures adequate facilities / infrastructure can be provided rather than creating isolated settlements.
• Financial viability can also be a major factor in deciding which sites to develop or even to ‘build out’ once planning has been granted.
• Onsite BNG in the vast majority of cases is simply tokenism – a tick box exercise intended to provide the illusion of compliance.

Solutions – Short Term

LPA ecologists need to understand that onsite BNG particularly on small sites is simply not achievable.

Adhering strictly to the BNG Hierarchy does nothing for BNG, reduces the number of potential units that can be built, undermines financial viability (reducing affordable homes provision) and causes greater urban spread.

Permitting developers to move swiftly to purchasing offsite units will help with the above.

Solutions – Long Term

The government needs to carefully think through how BNG is applied to very small sites and either exempt them entirely, or have a BNG levy that permits development without the onsite BNG requirements.

What they must not do is undermine the integrity of the BNG vision / market for restoring English wildlife. 

They must not continue to make stupid ill-conceived statements off the top of their head.

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