18 COMMENT
on smaller or brownfi eld sites, where opportunities for onsite mitigation are limited. et the costs of the alternative – securing offsite units – can be prohibitive, threatening the viability of schemes in areas where housing need is most acute. Even when onsite measures are technically possible, they may not deliver the best ecological outcomes. Developers can end up installing green roofs or pocket habitats that achieve compliance under the metric, but contribute little to wider ecological networks. This risks creating a patchwork of isolated interventions rather than meaningful landscape scale restoration.
STRATEGIC OFFSITE SOLUTIONS The solution is not to reduce BNG, but to refi ne how it is applied. ffsite solutions – whether through habitat banks, landowner partnerships or strategic conservation projects – often deliver greater ecological value. They allow resources to be pooled, creating larger, more connected habitats that genuinely support nature recovery. art of the problem, however, is that such sites are not always readily available. ur analysis highlights signifi cant regional disparity in the availability of offsite units. The east and south east of England are relatively well supplied, while other regions are facing shortages. For housebuilders working on brownfi eld and infi ll sites, limited offsite options raise serious viability questions, especially for affordable housing. If local planning authorities begin
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to insist that BNG must be delivered strictly within their own boundaries, the pressure on costs will intensify. A national framework is needed to avoid BNG becoming a postcode lottery.
AN EVOLVING MARKET
The policy is already shaping new markets. Investment in habitat banks has risen sharply, and, according to Business Green, by 2035 as many as 91,000 biodiversity units could be in circulation. ocal Nature Recovery Strategies, once published, will further in uence values and direct investment toward priority areas. In parallel, the extension of BNG requirements to Nationally Signifi cant Infrastructure rojects from ay 2026 will increase competition for units. For housebuilders, the challenge is to navigate this emerging market while keeping schemes viable and housing supply on track.
This evolution reinforces the importance of a exible framework. Developers need confi dence that offsite options will be available and affordable, and landowners need to better understand demand so that they can invest in habitat creation. Without this coordination, delivery of both housing and biodiversity gains risks falling short.
BALANCING AMBITION WITH PRACTICALITY
The Government’s stated aim is to halt nature’s decline and enhance ecological connectivity. Few would disagree with that ambition. But the route to delivery
matters. A rigid insistence on onsite mitigation risks undermining both housing supply and biodiversity outcomes. What is needed is a more balanced approach onsite delivery where it adds genuine ecological and community value, complemented by robust offsite markets that can deliver at scale. This requires clear national guidance, consistent application across local planning authorities, and a recognition that land is fi nite and must serve multiple purposes – from food production to housing, energy, and nature recovery.
A CALL FOR RECALIBRATION BNG is still in its infancy and is currently being reviewed by DEFRA. Naturally there are challenges to work through and potentially some changes on the horion. ur research will help to inform future change, providing the evidence that helps the industry to understand demand and opportunity. The current review is an opportunity for the Government to reconsider the bias toward onsite mitigation and ensure that the framework re ects practical realities. Adjusted sensibly, BNG can underpin – not obstruct – the delivery of the new homes this country urgently needs. If the policy can evolve in this way, BNG has the potential to be genuinely world leading, delivering measurable biodiversity improvements while supporting, not stalling, the delivery of new homes.
Katy Davis is planning & development partner at Carter Jonas (London)
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