1. When is the Local Planning Authority planning to introduce Biodiversity Net Gain as a mandatory requirement for all small development projects in the LPA’s jurisdiction? Please provide a specific date and a short definition of what the LPA classes as a ‘small development project’.
Wokingham Borough Council is currently preparing a new Local Plan, which will set out the long term development strategy for the borough, and include planning policies to guide decision taking on planning applications. Consultation on a Draft Local Plan was undertaken in spring 2020: https://www.wokingham.gov.uk/planning-policy/planning-policy-information/local-plan-update/. Draft Policy NE1: Biodiversity and Nature Conservation set out how development proposals of all sizes should achieve a minimum 10% net gain for biodiversity.

The introduction of biodiversity net gain as a mandatory requirement will depend on the progress of the Environment Bill and the emerging Local Plan Update. The latest release of the Defra metric (3.0, released 7/7/21 http://publications.naturalengland.org.uk/publication/6049804846366720) was published alongside a small sites metric (see: http://publications.naturalengland.org.uk/publication/6047259574927360). Natural England define small sites as:

“The Small Sites Metric is a simplified version of the Biodiversity Metric 3.0. It has been specifically designed for use on small development sites where the project chooses to do so. Such sites are defined (for the purposes of this Small Sites Metric) as small sites where BOTH of the following criteria are met:

1) Development sites where;
- For residential developments the number of dwellings to be provided is between one and nine inclusive on a site having an area of less than one hectare
- Where the number of dwellings to be provided is not known the site area is less than 0.5 hectares
- For all other development types where the site area is less than 0.5hectares or less than 5000 metres squared#

2) Where there is no priority habitat present within the development area (excluding hedgerows and arable margins)

It is not appropriate to use the Small Sites Metric to calculate offsite losses and gains”

2. If a specific date has not yet been decided, does your Local Planning Authority intend to introduce a requirement for planning applications to include localised Biodiversity Net Gain plans for small development project within the 24 months following the passing of the Environment Bill? (Please define ‘Biodiversity Gain Plan’ as any document that is analogous to the type of document specified in the Environment Bill).
Core Strategy Policy CP7, and Managing Development Delivery Policy TB23 seek to conserve and enhance nature conservation sites, whilst also ensuring development proposals provide opportunities to incorporate new biodiversity features, or enhance existing features, through design, landscaping and layout.

The emerging Local Plan will also consider this aspect of BNG. Nevertheless, the NPPF (2021) states:

“174. Planning policies and decisions should contribute to and enhance the natural and local environment by:
d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;” and
“180. When determining planning applications, local planning authorities should apply the following principles:

a) if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;”

Wording set out in the NPPF has been used by the Local Planning Authority to argued that it is appropriate to use a calculator/metric to consider whether there is a loss/gain. For smaller sites, the first consideration has been whether the proposal is likely to lead to a change in broad habitat type coverage, and therefore whether it is reasonable to request this approach.

3. Is there any material that sets out what criteria a Biodiversity Gain Plan needs to meet in order to be accepted by the authority for a small development project? If such material exists please can it be attached to your response. If such material does not exist, please provide a brief description of what criteria a Biodiversity Gain Plan needs to meet within your LPA. (Again, please define ‘Biodiversity Gain Plan’ as any document that is analogous to the type of document specified in the Environment Bill).
There is no specific material published, but an SPD is being considered. There is no universal requirement for a BNG plan to be submitted for small sites, and as such it is not a matter considered by the validation team when applications are submitted. Submission of a DEFRA metric calculator may be recommended through the planning application process as part of demonstrating that the proposal meets the criteria set out in the NPPG. On other occasions, it is reasonable to consider specific enhancements as being proportionate and relevant to the development proposal to demonstrate BNG. A bespoke strategy, either set out separately or within an Ecological Impact Assessment, that relates back to the Wokingham Biodiversity Action Plan, can be a clear way to consider BNG.

4. Who is the official at your Local Planning Authority that is tasked with ensuring that Biodiversity Net Gain is implemented for the LPA?
There is no one official. It would in part be the responsibility of planning officers considering applications, and elected Members determining planning applications (to include BNG in the planning balance). Advice on the detail of a submitted BNG plan, would be the responsibility of the ecology specialist consultee.

5. Does the LPA’s approach to Net Gain require all ‘Biodiversity Gain Plans’ to be produced by an accredited ecologist?
No.