New draft British Standard for Biodiversity Net Gain – Aspect Ecology submits our response to the consultation
Simon Boulter (Aspect Ecology Director) is on the Biodiversity Management committee for the British Standards Institute and sat in on the drafting panel for a new draft British Standard – BS 8683 “Process for designing and implementing Biodiversity Net Gain”. He provides his thoughts on the draft document below.
The draft Standard, “Biodiversity Net Gain (BNG) is an approach to development and land management that leaves biodiversity in a measurably better state than before, after first avoiding and minimizing harm”. Appropriately, consistent themes throughout the Standard are the need to measure and quantify the aspirational ‘gain’, plus the need to rigorously apply the mitigation hierarchy throughout the project lifecycle.
Importantly, the draft Standard sets out the process for designing and implementing BNG that is based on good practice. It does not cover the delivery of BNG; it provides a framework to demonstrate that a project has followed a process. As such, it does not stipulate what the end result has to look like, but details the methodical steps which need to be followed, and what needs to be recorded/evidenced at each step, to demonstrate compliance with the Standard. The Standard has been designed and worded to be applicable to a broad range of projects, covering both development projects and land management activities. Similarly, options and examples are provided for projects affecting biodiversity, plus those having no effect, which want to demonstrate BNG aspirations.
The Standard emphasizes the need to think about BNG at the start of any project. Accordingly, the Standard demonstrates how BNG can be considered, and aspirations documented, at various stages in the project lifecycle. Sections in the Standard demonstrate how BNG can be considered at the feasibility stage of a project, design stage and implementation stage (used instead of ‘construction’ to acknowledge those projects which are more concerned with land management and conservation projects). Consideration is also given as to what should be documented at the subsequent management, maintenance and monitoring stage, with the content of a BNG Management and Monitoring Plan.
The draft Standard includes statements on irreplaceable habitats and those habitats for which BNG cannot be achieved. There is also a strong social element included, with emphasis provided that BNG aspirations should not adversely affect people. As they are integral to BNG, the use of proxy measures and metrics are discussed in the draft. However, the use of a particular metric is not stipulated, just that whatever metric is used follows transparent reasoning, is applied consistently and any changes to the method/calculation are documented and justified.
Proportionality, Additionality, Transparency and Consistency themes run through the document. The Standard clearly sets out a process which, if followed correctly throughout the lifecycle of a project, will allow the proponent to document and demonstrate their application of the mitigation hierarchy and aspirations to achieve BNG. In this sense, the Standard is “acting not only to protect biodiversity, but also to ensure that it is thriving”.
BNG will become mandatory as the Environment Bill receives Royal Ascent, which is currently expected in 2020. At that point in time all development sites will need to provide a 10% net gain for biodiversity.