The Housing Forum has responded to DEFRA’s consultation into changes to the biodiversity net gain system for smaller sites.
We raise concerns that there are a number of sites – and smaller sites in particular – where the costs and difficulties of meeting BNG requirements have rendered housing plans unviable. There are already a large number of factors that have hit the housebuilding sector in recent years – rising construction costs, higher borrowing costs, and weakening housing market, and costs associated with meeting new building safety requirements. On top of this the Government wishes to prioritise social rented housing, maximising what can be delivered via S106 agreements, yet the funding available to cross-subsidise the social rented homes is directly related to the other calls on development.
We therefore urge the government to take a proportionate approach to dealing with the very small impact of new housing on biodiversity, compared with the much larger impact of farming methods and other factors. The current Government has made very public commitments to prioritising growth and the delivery of new homes, and should ensure that improvements to biodiversity are not constraining this unnecessarily.
We are therefore pleased to see this consultation on modifications to the BNG system. We are broadly supportive of the changes proposed, but would like to see the thresholds for when BNG applies, and when the simpler Small Site Metric is used based on the size of the site (and other factors) rather than the number of new homes proposed. The value of a site in terms of biodiversity is related to its size, but is not related to the number of new homes proposed for it. This is important to avoid creating perverse incentives to under-deliver new homes on sites with the potential for more new homes, in order to avoid BNG requirements.
You can read our response in full Consultation on BNG for small sites and brownfield – response from The Housing Forum
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