A Guide to Biodiversity Net Gain and Dog Field Planning Applications

A Guide to Biodiversity Net Gain and Dog Field Planning Applications

Blimey I have read some tripe about Biodiversity Net Gain in recent months!

You’d have thought the dust would have settled by now but there seems to be more confusing information circulating than ever so our planning team got together to do some myth-busting on the topic of Biodiversity Net Gain, relating specifically to dog fields.

By the end of this article, our hope is that you better understand the process and purpose of the Biodiversity Net Gain assessments (and also understand why you might feel like you’re being robbed of thousands of pounds to agree to plant a few trees).

Biodiversity Net Gain in Plain English

What you’re going to read here is going to be free from planning jargon, eco-babble and language generally used in an effort to confuse the average person trying to navigate the planning system.

What is Biodiversity Net Gain?

In layman’s terms, a Biodiversity Net Gain is simply this:

The difference in ecological value of any site before and after biodiversity enhancements, expressed as a percentage.

People are using the term biodiversity net gain [BNG from now on] to refer to the process of assessment that has been introduced to ensure the development improves the ecological value of that site by at least 10%.

In short, as of April 2024 the Government requires EVERY development to be subject to a new legal requirement to provide a metric that demonstrates a purposeful increase in the biodiversity value of the site by at least 10%. This is a mandatory part of every planning application regardless of size, development type and location.

Exemptions: Exemptions are very few – the chances of your dog field exercising a legitimate loophole and not making bonkers compromises to the development are very rare. The exemptions are:

  • If your planning application was made before 12th February 2024 (2nd April for smaller sites)
  • If you are seeking to vary or amend an existing planning permission
  • You do not impact a priority habitat and impacts less than 25sqm of on-site habitat (this includes grass) and/or less than 5m of hedgerows (it is extremely difficult to do this and design a good dog field)

Wales, Scotland and Northern Ireland: You guys don’t have to do any of this yet, but there is a growing emphasis across the UK to improve biodiversity on all sites, whether this be through a metric or otherwise

How Do You ‘Do’ a Biodiversity Net Gain Assessment?

This depends on the size of the development:



Why Does BNG Apply to Dog Fields?

Because it applies to all planning applications. There’s no arguing it away if you’re not in on of the exempt categories so don’t waste any energy or time even thinking about it.

Is it unreasonable? Maybe. Is it the addition of more layers of bureaucracy to be added to an already complex situation? Yes. Is it something you should/can fight? No. Will it go away should there be a change of Government? Highly unlikely as Labour are also committed to BNG.

The only way to consider BNG in the context of dog fields is to look at the ‘bigger picture’. 

When Do You Have to Do a Biodiversity Net Gain Assessment?

A BNG assessment needs to be conducted prior to submitting a planning application. It must be submitted with your planning application or it will not pass the validation process which is where the council confirm you have submitted all the required documentation to allow them to properly consider your application.

Do You Need to Have an Ecological Survey and Assessment Done First?

If your development is over 1ha, yes. If you have a survey and assessment that is relevant and has the BNG Habitats Conditions sheet completed that is less than 12-18 months old, you can use this in most circumstances.

If you are proposing a development of under 1ha, then a site visit is sufficient and in some circumstances, this can be done remotely as a desk-based exercise.

How Much Does a Biodiveristy Net Gain Assessment Cost?

It’s the wild west out there in BNG-land and there has been an explosion in ecological consultancy organisations offering BNG services.

I think our total of BNG quotes now tops 27 and they range from £1,500 to £8,000 (for the same site and development)…. I am not joking.

However, having completed several under the new rules, for a major development (>1ha), you should expect to pay from £1,800 to £5,000 depending on the scale of the site.For a small development (<1ha) you can expect to pay between £650 and £1,200. Due to the frustration of relying on outside agencies, we now have the resources to do this in-house for small sites at British Dog Fields so if you want to know more about how we could help, drop us an email.  

How Long Does a Biodiversity Net Gain Assessment Take?

As always the answer is that it depends. However, for a full BNG for a major site 5-6 weeks is typical. Ecological agencies are drowning in requests and struggling to meet demand.

For the smaller site assessments, these can be turned around in 1-2 weeks if all the relevant information is made available at the start. This includes existing and proposed site and location plans, any relevant design information and administrative information about the land owner and applicant.

My Busting about Biodiversity Net Gain and Dog Fields

Biodiversity Net Gain does not apply to retrospective applications

You cannot escape BNG just because you are making a retrospective application – as far as the authorities are concerned, your development is unlawful until it has planning permission and therefore, all the same rules apply as if it wasn’t there at all.

In a retrospective scenario the Biodiversity baseline value would be taken at a date prior to the dog field opening or the official baseline date – i.e. not the current condition of the site.

One exemption is if you hold a Certificate of Lawful Use (after 10 years of continuous uncontested use without any enforcement action). If this applies to you, you need to chat to your planning expert to find out more in relation to your personal circumstance.

I’m sensible, I’ll fill the forms in myself.

The saying that time is money can be applied to this – if you have oodles of time on your hands and you are only doing a small development, you may be able to take this on yourself but honestly, I don’t think it’s worth to faff.

Agencies are cashing in due to high demand and confusion

Biodiversity net gain doesn’t apply to me because ….

Have you heard …? “So and so said they didn’t have to do it….”

There are some limited exemptions (see above) and the likelihood is that ‘so and so’ made an application prior to the implementation date, had a Council who operated a rare period of leniency whilst they got their own house in order, or had some other anomaly (e.g. 0% habitat impact) in their application. These are very rare.

I’ll just plant a couple of trees and I’ll be fine…

Your site may already be quite biodiverse, if so that’s not a golden ticket. BNG requires everyone on every site to demonstrate a 10% enhancement in the value of the site as a result of the development when compared to the existing condition. This is about providing improved habitats appropriate to your site and to the benefit of local ecosystems and wildlife.

What this means is that if you’re developing a woodland, you have significantly more work to do than if you are developing an area of degraded arable land.

If I cut down trees and clear the site of vegetation before making my application this will make it easier to demonstrate an increase in BNG

Not at all. For a whole host of legal, environmental, and moral reasons you should be very careful if you want to clear vast swathes of existing vegetation and habitats on site before making a planning application. We would strongly advise against it. Councils and other consultees such as Natural England and the Wildlife Trust are much more savvy than you realise and will know that the site has been cleared. It doesn’t put you in the best light and it might lead to some unintended consequences.

Key Things to Watch Out for When Considering BNG

  • Rouge traders – make sure your BNG Assessment provider is properly qualified to do so
  • Planners who don’t understand how BNG applies to dog fields
  • Ecological agencies who won’t work with you to produce an appropriate scheme
  • Planners who don’t know how to minimise the costs for you or don’t know the details of how BNG can actually work in your favour to support a dog field application
  • People who will tell you there are loop holes
  • Making a small site to save money (this can be a short term saving that might not represent the best strategy for a dog field in your area)


Is Biodiversity Net Gain Ridiculous?

Yes and no.

Anything that makes people think more about their dog fields is a bonus – all too many poor-quality facilities are being developed. All the dog fields we have designed for and with dog field owners have created a BNG far over the 10% requirement and we haven’t changed what we do, we’ve already been doing that forever!

But BNG does create an additional expense, raises the barrier to entry, and for those of us doing the work anyway, it feels like a completely unnecessary cost and the addition of more red tape and bureaucracy.

There are also some little-considered upsides of BNG in relation to dog fields, particularly for farmers and land owners implementing a variety of diversifications in terms of ‘eco points’ (credit for enhancement measures) and we’re happy to discuss those with anyone wanting to navigate that process through the opportunity of a dog field.

Closing Thoughts on BNG

The reality is this legislation wasn’t really targeting dog field operators – it was for people who could damage biodiversity in the process of their development, less so people who improve biodiversity by a significant measure as a consequence of their development.

Hey ho.

If You Need More Help

Because of this kerfuffle and the challenges associated with navigating this system, we’ve developed a close working relationship with a trusted and select few ecological partners who can help with BNG and ecological surveys and assessments, particularly for larger sites.

In house, we have the expertise to develop BNG for smaller sites so if you don’t know how BNG will affect your plans, or you’re trying to figure out how to incorporate your BNG obligations into a dog field design, get in touch and we’ll point you in the right direction – whether that’s putting you directly in touch with our planning partners at Evolve or helping you work out your next steps.

If you’re considering building a dog field business, you can find out more about our support services by clicking here.

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