Roundtable discussion on the development of a Biodiversity Planning Metric

1 May 2024 – online

The roundtable was jointly organised by the Scottish Government’s Planning, Architecture and Regeneration Division, NatureScot and CIEEM to take place during the initial consultation stage of the development of a Scottish biodiversity planning metric. The roundtable discussion was an opportunity to discuss the proposed scope and approach to this work, highlight existing experience in Scotland and to discuss priorities, opportunities and challenges.

The roundtable was chaired by CIEEM and facilitated by NatureScot. The questions given below were designed to prompt discussion. However, all comments and topics were welcomed. 

Overarching Messages

• Several stakeholders present at the meeting have experience of using England’s biodiversity metric tool (often referred to as the ‘Defra metric’ or England’s statutory biodiversity metric), or adaptations of that metric, in a Scottish context and would be keen to share this knowledge to help develop a metric for Scotland.
• The overall aim should be good outcomes for nature, and it will be important to ensure ecologically beneficial decisions are not penalised (avoiding perverse outcomes).
• Development of a Scottish metric provides an opportunity to adopt a consistent approach that can be applied across Scotland which supports the objectives of NPF4.
• There is a clear need and huge appetite for upskilling of all stakeholder groups applying the metric.
• Clear guidance to support the metric will be required.
• Scotland’s metric should integrate woodland assessment (including individual trees) into its design.

What experience and expertise already exists in Scotland?

• A number of stakeholders present at the meeting have experience of using England’s biodiversity metric and would be keen to share this knowledge to help develop a metric for Scotland.  This experience applies across multiple sectors.
• Certain stakeholders and sectors (e.g. renewables, electricity transmission, Network Rail) already have experience of applying a biodiversity metric approach in Scotland, on a wide variety of projects at differing scales. Applying a metric approach to date has either required stakeholders to use England’s biodiversity metric on Scottish developments or adapt that metric for a Scottish context.  SSEN for example have been using their own metric since around 2020.

What lessons can we learn from England and elsewhere?

• Link biodiversity enhancement to regional green infrastructure strategies and land use strategies.
• Opportunity to address some of the issues that have been raised with England’s metric at the outset, but also identify issues for Scotland that England may not have experienced.
• The overall aim should be good outcomes for nature; to achieve this it will be important to consider the connections between planning and other sectors including forestry and agriculture.  
• Impact of enhancement should be positive, ensuring that any biodiversity measures work in ecological terms, and it doesn’t become a tick-box exercise/number exercise.
• It will be important to get the metric’s trading rules right, to ensure ecologically beneficial decisions are not penalised and avoid perverse outcomes.
• This metric should be considered in the wider context of other requirements placed on landowners, to ensure landowners are not overwhelmed. Ownership of assets can be a significant challenge. 
• An area of improvement would be how individual trees are measured and valued based on species. The value of veteran trees/ancient woodland cannot be replaced by hectares of woodland creation.
• It was noted that other biodiversity metrics are being developed. It will be important to consider how these emerging initiatives can inform and complement this work. The Scottish Government noted that it is developing a metrics framework to guide the selection of metrics.

Are there established groups or fora we should be engaging with?

Attendees suggested a number of established groups or fora that it was thought would be beneficial to engage with, including:

• Natural England – lessons they’ve learned from development of England’s metric.
• English Local Planning Authorities (LPAs) – particular those that adopted the metric at an early stage (e.g. Warwickshire CC, Buckinghamshire CC).
• England’s Planning Advisory Service (PAS) – have produced lots of guidance on applying BNG for LPAs in England.
• Linear Infrastructure Environmental Management Group
• Landscape Institute
• Arboricultural Association
• Peterhead Developers Forum – Voluntary, industry led grouping of developers promoting energy developments in and around Peterhead, particularly in relation to onshore grid connections for offshore wind farms.

What are the challenges and opportunities for a Scottish Planning metric?

Opportunities:

• Will enable a consistent approach to be applied across Scotland that supports the objectives of NPF4. Time is available to help build awareness amongst all stakeholders.
• Good opportunity to introduce all stakeholders to the process of developing a Scottish metric at an early stage and start to build awareness and capacity in the planning community (it was highlighted that although the BNG approach is now mandatory in England, capacity building is still required).
• Opportunity to link biodiversity enhancement on a site to green infrastructure and national land use strategies.
• Renewable developments could present an opportunity for increased peatland restoration (which is currently disincentivised by the English metric).
• Improve upon on how veteran trees/ancient woodlands are valued by England’s metric. It was also pointed out that veteran trees/ancient woodlands are classed as irreplaceable habitats in the English metric and therefore are outside the BNG calculations.
• View that protected sites (e.g. SSSIs, SPAs, SACs) could be incorporated into metric, to enable enhancement efforts to be used to improve unfavourable sites to favourable condition. However, the principle of ‘additionality’ would need to be considered in the Scottish context.
• Upskilling has been achieved in England within a relatively short timeframe, including establishment of training for the UK Habitat (UKHab) classification system. But there is still a need for more capacity building.

Challenges: 

• Some difficulties with England’s metric include how data is recorded on site - versus what needs to be entered into the metric - the habitats which can be entered into the metric do not fully align to UKHab types. Some habitats are captured through secondary codes, so can get lost when translating polygons into the metric.
• There will be different challenges of developing a metric in Scotland when compared to England (for example to take account of different development types e.g. onshore wind farms).
• Maintaining a metric in the long-term to ensure it remains fit for purpose (and which body will be responsible for leading on this).
• Clusters of developments for just transition is a huge opportunity to create joined-up networks.  Challenge in that those projects are now quite far down the line. Difficult to get cohesion amongst developments. So, if there is some way in the metric to consider other developments nearby that would be helpful. 
• Delivering a strategic approach that fits with other goals. Some see benefits in delivering strategic interventions, others noted concern with disconnecting enhancement from a development’s impacts.
• Ensure that double counting of habitat data does not occur with metric approach.
• Potential land ownership challenges – i.e. some stakeholders will own the land where their assets lie, in some sectors it is common to have assets on 3^rd party land (e.g. wayleaves for electricity transmission).
• Land availability is a huge issue for some developers, particularly when securing land for enhancement.
• A lot of Local Biodiversity Action Plans are out of date.
• Consideration of how phased residential developments will meet enhancement requirements. What information will be required at the Masterplan stage?
• Concerns with the treatment of woodland, including the approach for ancient and veteran trees. And how tensions between respecting very high distinctiveness habitats such as heathland and woodland are resolved.
• The treatment of irreplaceable habitats (within or outwith the metric), and protected areas (while addressing ‘additionality’) requires consideration.
• Ensuring good delivery in practice on the ground.
• View expressed there is an opportunity to link with investment in natural capital, but this may be challenging.
• Learn from England’s experience – only 2 in 10 planners feel confident applying the metric, and lack of capacity and skills is a concern in England and Scotland. This is only one of several additional tasks for planners.  Similar concerns with ecologists and consultancies.
• There is a clear need and appetite for upskilling for all stakeholders in the planning process, including developers, regulators and ecological/environmental specialists. This could be addressed in many formats, including training courses on the use of the metric, webinars and conferences.
• Scottish planning authorities will need to be able to assess applications without being dependent on rigid numbers that might not fully encapsulate the ecological situation on the ground.
• Across Scottish planning authorities there are differing levels of environmental expertise available to assist planners with decision-making.  Many planning authorities have lost their environmental specialists, and the requirement to enhance biodiversity will add to the existing demands on planners. It was suggested that ‘hubs’ of environmental specialists could be set-up that all planning authorities can access. However, this could also lead to fewer people expected to do more, with less localised knowledge.
• Practical challenge from a planning authority perspective would be in relation to access to relevant datasets, which may be beyond the planning authority boundary when considering off-site solutions.
• Lack of botanical knowledge and habitat ID skills in ecologist community, particularly in newer generation of ecologists. Suggestion to work with academia on higher education courses to address this.
• Other professions could also benefit from upskilling (e.g. designers, architects, landscape architects and engineers).
• When considering enhancement this is over a long-term period - could cover multiple Local Development Plan periods - there needs to be a high-level direction that such sites are to be protected in some way.

How / will these differ for different development types?

• Large site boundaries associated with onshore wind farms could be problematic with England’s metric. There is also a need to consider how the metric will work for applications for wind farm repowering, where for example the proposed footprint may affect previously enhanced areas.
• The metric’s risk factors for peatland may disincentivise action for peatland habitat.
• Issues around development red line boundaries (e.g. onshore wind farms), including the need to address micro-siting of development components. As well as wind farms, there could also be issues with Planning in Principle applications and linear developments.

Do you agree with the priorities that NatureScot have set out in their consultation paper, or do you think there are other priorities that should be considered? 

• Why isn’t woodland included alongside peatland as a priority for identification and treatment of habitats?
• Think about approach to offsite offsetting and how it will be delivered, alongside the other priorities.
• Consideration of multi-phase developments (including phased residential development), and developments consented with limits of deviation such as under the Electricity Act.  May be able to describe likely impacts but final calculation is at micro siting stage.

For your industry/sector specifically do you have any other issues or comments you would like to make?

• Ecologists working in Scotland should be familiar with the Scottish Biodiversity List priority habitats and are likely to have some familiarity with the UKHab classification system. Priority habitats on the Scottish Biodiversity List fit within Level 4 UKHab classifications.
• Consider the potential use of species diversity indices (e.g. Simpson’s and Shannon-Weiner), that may provide a better comparison of outcomes.
• The metric will be a decision-support tool. Clear guidance will therefore need to be developed to support the metric tool and ensure consistent implementation.
• Consideration of other information as part of a planning application alongside outputs from the metric. The guidance could offer support on how to secure, manage, monitor and enforce biodiversity enhancement. Guidance will be required to support this and could include standard template documents for submissions to make it easier for planning authorities to review and process applications. [Noted that England only clarified certain application requirements at a relatively late stage.]
• View that some form of publicly available biodiversity gain register (spatial dataset) should be produced to identify where off-site offsetting has been secured so that future developments are avoided on these sites. Potential opportunity for linking sites used for enhancement into Nature Networks and OECMs at a later date.
• There is a need to consider how to secure, manage, monitor and enforce off-site offsetting / enhancement. How will this be managed in Scotland?  What information needs to be submitted to the planning authority?
• Some stakeholders expressed an appetite to establish a target uplift in Scotland, like the 10% BNG in England.  Some Scottish planning authorities are currently recommending a minimum of 10% enhancement. This also benefits decision makers who are processing high volumes of planning applications. Some developers have also adopted a corporate 10% enhancement approach for all projects in both England and Scotland. However, would having a set target sometimes produce perverse outcomes?
• Pre-emptive clearing of sites – how to tackle potential issue of a site being purposefully degraded before baseline condition surveys are completed, to intentionally reduce the biodiversity enhancement/creation required?
• View that approach to off-site biodiversity offsets needs to be considered in tandem with the metric and before the metric is adopted.  (Scottish Government noted this was the subject of a separate roundtable discussion in May 2023 which was used to inform the Draft Guidance