BNG for Local Planning Authorities

The LPA role in BNG

Local Planning Authorities are the primary gatekeepers and enforcers of BNG in England. Since February 2024, LPAs have been responsible for ensuring that most new developments deliver the mandatory 10% biodiversity net gain — a significant expansion of the planning function that goes well beyond traditional development management.

LPA responsibilities span the entire BNG lifecycle: from assessing biodiversity information at application stage, through approving Biodiversity Gain Plans as a pre-commencement condition, to long-term monitoring and enforcement of habitat management over 30 years.

Core LPA responsibilities

1. At application stage

When a planning application is submitted, the LPA must assess whether BNG is capable of being delivered. At this stage, a full Biodiversity Gain Plan is not required — but the application should include sufficient information to demonstrate that the 10% uplift is achievable.

The LPA should check:

• Has the applicant provided pre-development biodiversity value using the statutory metric?
• Has a plan been submitted showing on-site habitats (existing and proposed)?
• Has the applicant described steps to minimise adverse biodiversity effects?
• Is the proposed BNG strategy credible — can the 10% uplift be delivered through the proposed combination of on-site, off-site, and/or credits?
• Are there any irreplaceable habitats on the site requiring bespoke compensation?

There is no statutory requirement to consult specific bodies on BNG at application stage — the normal consultation arrangements apply.

2. Decision-making and conditions

Prior to determination, the LPA should discuss with the applicant whether any Section 106 planning obligations are needed to secure on-site or off-site gains. The LPA then grants permission with a BNG condition attached — requiring approval of a full Biodiversity Gain Plan before development commences.

3. Approving the Biodiversity Gain Plan

This is the most critical and resource-intensive LPA function. The gain plan is a pre-commencement condition — the LPA must approve it before development can lawfully begin. The plan must demonstrate:

• At least 10% net gain in biodiversity value (baseline vs post-development)
• That the mitigation hierarchy has been followed
• That any off-site gains are allocated from registered gain sites on the national register
• That any statutory credits are supported by proof of purchase
• That a Habitat Management and Monitoring Plan is in place for significant on-site gains

4. Statutory credits confirmation

When a developer proposes using statutory credits, the LPA has a specific role:

• Confirm by email that the developer can proceed with credits
• Advise the applicant that credits can only be purchased after fulfilling non-BNG pre-commencement conditions
• Provide a valid decision notice — Natural England will not process a credit purchase without one
• Advise the applicant to use the metric's unit shortfall summary tab when purchasing credits
• Note that bespoke compensation cannot be replaced by statutory credits

5. Long-term monitoring and enforcement

For gains secured via S106, the LPA is responsible for monitoring habitat delivery over the 30-year period. This includes:

• Reviewing habitat management reports at agreed intervals
• Assessing whether target conditions are being met
• Taking enforcement action if obligations are not being fulfilled
• Charging monitoring fees to cover the cost of this function

For gains secured via conservation covenants, monitoring is handled by the designated responsible body — reducing the LPA's monitoring burden.

Developing your local BNG market

Implementing BNG well goes beyond development management. LPAs have a strategic role in supporting the development of a functioning local off-site biodiversity market.

Understanding your local supply position

A critical first step is understanding whether your LPA area has adequate off-site unit supply. As of early 2026, 202 of 309 LPAs have no registered habitat banks — meaning developers in those areas must look to adjacent NCAs or resort to statutory credits.

Key questions to assess your local market:

• How many registered gain sites exist in your LPA area?
• What habitat types are available? Do they match likely developer demand?
• Is there supply in adjacent NCAs that could serve your developers?
• Are there landowners in your area who could be encouraged to create habitat banks?
• Would an LPA-operated habitat bank be viable and appropriate?

Becoming a responsible body

LPAs can apply to DEFRA to become designated responsible bodies for conservation covenants. This allows the LPA to enter into covenant agreements with landowners directly, rather than relying on third-party responsible bodies. Benefits include greater control over local BNG delivery and an additional revenue stream from covenant fees. However, it also requires dedicated resource for monitoring and enforcement over 30-year timeframes.

Connecting with Local Nature Recovery Strategies

Over half of all LNRSs have now been adopted, with the remainder expected in 2026. LPAs should ensure their BNG approach is aligned with LNRS priorities — habitats created in LNRS-identified areas receive a higher strategic significance multiplier in the metric, incentivising habitat creation where it delivers the most ecological value.

Proposed NPPF changes would give greater weight to LNRSs in plan-making and decision-making, further strengthening the link between BNG delivery and strategic nature recovery.

Consistency and pragmatism

The LGA/PAS BNG guidance emphasises the importance of consistency and pragmatism in BNG implementation. BNG is a new system and approaches vary significantly between authorities. Key principles include:

• Be pragmatic about the metric. The statutory metric is a blunt tool — it measures habitat quantity and quality but doesn't capture every ecological nuance. LPAs should use professional ecological judgement alongside the metric, not treat it as infallible.
• Don't let perfect be the enemy of good. Some BNG delivery is better than none. If a developer's gain plan achieves 10% net gain through a reasonable combination of routes, approve it — even if the on-site design isn't ecologically optimal.
• Maintain consistency across applications. Developers and ecology consultancies working across multiple LPAs frequently cite inconsistency as a major frustration. Develop clear local guidance and stick to it.
• Communicate proactively. Pre-application discussions about BNG can prevent delays and disputes. Make your BNG expectations clear before applications arrive.
• Share good practice. The LGA/PAS BNG Forum provides a peer network for LPA officers — use it to share what works and learn from others.

2026 reforms: what LPAs should prepare for

Key resources for LPAs

• LGA/PAS BNG Hub: local.gov.uk/pas — BNG for LPAs — the primary support resource including guidance, webinars, and the BNG Forum
• Planning Practice Guidance: GOV.UK BNG PPG — the statutory planning practice guidance on BNG
• Statutory credits guidance: LGA/PAS statutory credits guidance for LPAs
• Responsible bodies guidance: LGA/PAS responsible bodies and conservation covenants
• BNG enquiries: biodiversitynetgainenquiries@naturalengland.org.uk