The Nature Recovery Podcast
The Nature Recovery Podcast looks at some of the major challenges we face to global biodiversity. It takes a look at the various ways we are trying to halt the decline in biodiversity and the challenges inherent in these approaches. We also talk to a number of leading figures in the field of Nature Recovery and find out more about their work.
The Nature Recovery Podcast
A Developer, an Ecologist and a Social Scientist Walk into a Habitat Bank…
Guests
- Natalie Duffus (DPhil student, Dept. of Biology)
https://naturerecovery.ox.ac.uk/people/natalie-duffus/ - Matti Troiano (Research Assistant, School of Geography and the Environment)
https://naturerecovery.ox.ac.uk/people/mattia-troiano/ - Host: Stephen Thomas (Centre Manager, Leverhulme Centre for Nature Recovery)
In this illuminating episode, we tackle the increasingly tangled web of Biodiversity Net Gain (BNG) and get an update on what is happening with its current implementation. We also look at the Nature Restoration Fund — two major pieces of England’s ecological compensation puzzle.
Our guests Natalie and Matti break down what these policies are, how they affect developers, landowners, and communities — and why even good intentions may go sawry when market logic meets under-resourced local authorities.
The Leverhulme Centre for Nature Recovery is interested in promoting a wide variety of views and opinions on nature recovery from researchers and practitioners.
The views, opinions and positions expressed within this podcast are those of the speakers alone, they do not purport to reflect the opinions or views of the Leverhulme Centre for Nature Recovery, or its researchers.
The work of the Leverhulme Centre for Nature Recovery is made possible thanks to the support of the Leverhulme Trust.
Welcome to the Nature Recovery Podcast. We're gonna take a closer look at some of the solutions to counter biodiversity decline, and we'll find out more about the people behind these ideas. Hello and welcome to the Nature Recovery Podcast. I'm delighted that my guest today are Natalie Duffys, who recently featured in the Ends Power List as an unsung hero of biodiversity. I'm Mattis Ana, and we are going to be talking about biodiversity net gain. Again, we're gonna get an update on what's been happening since this implementation and what changes are coming down. The way. Um, but we'll also be talking about the nature restoration fund and what that might mean as part of the planning and infrastructure bill. It's more exciting than it sounds as a bill. It has big impacts, but we'll be looking at the ecological side of things, but also the social side of things. What will this do to the society around us and what types of people will get to have a say? That's enough from me over to them. Uh, so my name is Nat Duffus and I'm a DL student in the Department of Biology. Um, my research looks at the ecological outcomes of biodiversity net gain, which is a comp ecological compensation policy in England. Hi, I'm Matt, Matt Triano. Um, I'm a research assistant at the School of Geography and the environment, specifically on the global biodiversity framework. Currently looking at the social dynamics, um, within biodiversity net gain, uh, in England. And I'm Steven Thomas, uh, center Manager for the Leaving Human Center for Nature Recovery. And I don't do any research, but I'm here to find out and ask the questions that people hopefully want to know. So Nat, I think I spoke to you. It was in 2023 around March, and we were talking about Biodiversity Net Gate, which was just on the cusp of sort of really being implemented. I think most people have heard about it now. Something's good, something's bad. Um, so you can, can you maybe pick up the story and tell us a bit about what's happened with BBNG and actually what's happening right now with BNG? So BNG is now mandatory in England. It has been since February, 2024 for major developments and April, 2024 for minor developments. So we've had mandatory net gain for, for development for just over a year. So we're starting to see some of the outcomes of the policy trickle through. And at the present moment, the government is having a consultation on some potential changes to biodiversity net gain for. Specifically minor developments. So that's sites that are less than a hectare up to 10 houses. And importantly, the government is also having a consultation on applying BNG to nationally significant infrastructure projects. So that's large rail renewable energy projects, um, yet very, very large projects. Okay. And I think there were some mixed uh, responses to BNG. As I recall. From your opinion, the, the overall, um, aim of BNG seems really positive to account for biodiversity loss, but certainly from your kind of work and your research, there were some issues about, well, actually, as the metric does it actually. Mean biodiversity gain. And also I could see as a, as a sort of a cynical commercial person, how you could potentially, if you were an ethical game, the system. Um, so with these kind of changes, I dunno. And these are, are they, I mean, is that an improvement or do you still have concerns fundamentally? Uh, you know, just rolling it out I guess is quite complicated. So, so what's your sort of view of what's been happening from, just, from your opinion? My view up, up until now has been. The rollout of BNG has been incredibly successful to have a, uh, mandatory 10% biodiversity net gain requirement on development. Uh, up and running I think is, uh, a huge success. And although we have highlighted areas where we think there's room for improvement, uh, such as the metric, we, we, we still would consider this to be a, a real bit of progress on, on environmental policy. Which is why I find it slightly frustrating the direction that the current consultation is taking. Um, for those, those minor developments, for example, proposing to exempt minor sites from BNG entirely. So sites less than a hectare up to 10 houses won't have to have to do BNG anymore. Um, and there are also proposed changes to the small sites metric. And expanding its remit. So this is a, a spinoff of the metric, which is used for sites, uh, up to 10 houses, but would now be potentially be used for sites up to 50 houses and less than a hectare. And the proposed changes to the metric are relaxing or removing the trading rules. So when you damage a particular habitat, you don't need to compensate for, uh, a similar or equivalent habitat anymore. They are reviewing the habitat definitions so that they can easily be identified by a non ecologist. And yeah, a, a host of frustrating changes that I think would really reduce the ecological rigor of the small sites metric. And an important thing is that these changes the exemption to small sites and the fiddling with the metric. Could substantially reduce the demand for offsite biodiversity units. So in the first 16 months of the policy, we've seen a whole, uh, a whole range of, of activity on the offsite BNG market. So lots of landowners creating and enhancing habitats on their land, registering it on the, the BNG Gainsight Register, ready to sell those units to developments we've seen. Approximately 3000 hectares of, of land, uh, go on that register in the first 16 months. And these changes could substantially reduce the demand to, to purchase, uh, those units. Okay. So, so if I understand that correctly, you know, in terms of the market. Mechanisms. There's been a bunch of environmental practitioners hoping to rely on BNG to fund some of the stuff. So they've sort of set up these land banks waiting for the BNG money to come. And then there's been a bit of a, a bit of a rug pull in terms of all this money from small sites doesn't need now to go off site. And also with my cynical developer hat on and just. Any developers out there? I know not all of you're cynical, but I, it's just me. Like if you can get a 10, 10 house small site metric, I'm immediately thinking, right. My 60 house development, I'm gonna slice that into six smaller independent developments of, of, you know, uh, 10 houses each. And then I don't have to do any kind of b and g rigmarole. I mean, I'm sure someone will. So tell me that's not allowed, but it does also sound like getting non ecologists in there and speeding it up and the whole combs not new thing is to me, giving an indication that, you know, if you want to get around this, there probably is a way and no one's gonna stop you. That's, that's opinion and not the official, uh, standpoint of the Lehe Center for Nature Recovery. By the way, uh, I, I dunno, does that. Does, does that paraphrase what you're saying in an edu uneducated manner? I think you're, you're right on the money with the, the breaking up of large developments into smaller ones. Um, we have seen some, some evidence that potentially some developers have done that in the past. Uh, I would hope a very small minority. Um, so, so that is a potential outcome of this. And in terms of the changes, they come from a place of. Small developers feeling that achieving BNG is very hard or very expensive. Um, so exempting the small developments and fiddling with the metric to make it easier to achieve onsite. BNG is the, the government's proposed, uh, solution to this, but our work has shown that 70% of developments. Purchasing offsite units are small developments, and they constitute around 38% of the demand for offsite units. So we're talking about quite a large fraction of demand potentially being, uh, taken out. And I, I believe that there are steps to be taken to make it easier for minor developments to, to achieve net gain so that they don't face. Challenges, uh, specific to their nature of being small, small developments. But I think those are about upskilling and helping them access the offsite, uh, the offsite units rather than reducing the amount of compensation that they have to do, because that's a bad outcome for nature. And that's interesting. And I thought developers might like BNGA bit more, and obviously some of them do. Also, the fact that you can do onsite and you can sell excess onsite units is, is interesting. Um, but that, I guess, I guess the bigger. Challenge that that does is it probably creates a lot of uncertainty at the moment in, you know, nature markets where, you know, farmers, land openers, nature groups are, uh, relying on B and g. And I think your sort of research and other research by sort of Isabel Hawkins and various people in your group has kind of shown that actually over the years since we've been talking about this, the money that we thought was in BNG probably is a lot. Smaller than, than people thought. Actually, you know what, what actually goes to these kind of offsite developments? It, it kind of trickles down. You know, people might try and avoid doing it, first of all. Then if they need to do it, they'll try and do it onsite.'cause it's just cheaper to manage it onsite. And then, so finally, if you have to pay someone else, that's probably your last resort. Just on a capitalist financial thing, not, not judging any developers at all. I don't want to pay money for, for stuff if I don't have to. I, I think that's a really interesting. Point is the, the size of this market at the moment. So I, I said that there's nearly 3000 hectares of land registered for sale in the first 16, 16 months of the policy. Less than 2% of that land has been sold. So the demand is currently, we would say, quite low. And the, any decision that the government takes at this moment, uh, about small sites, about the metric. Has the potential to, to really influence the, the demand. And I think I have hope that, that things will scale up. For example, bringing uh, nationally significant infrastructure projects into BNG could massively increase the demand for offsite units. Um, but I think it's, it's important that small sites are, are still required to achieve BNG and access those offsite units.'cause they do make up a large part of the demand at the moment. Yeah. And, and one thing I've heard from esteemed colleagues is actually from the financial na, nature, markets are no different from other markets in, in one regard. And people like market certainty. And if you're kind of tinkering on changing the rules and providing exemptions, um, it makes it a less attractive market to invest in sort of long term. And so if there's returns aren't there, and you're suddenly potentially doing things that could change demand either in a small or a big way. Then that can have an impact, which actually leads me on to this thing called the Nature Restoration Fund, which seems to have popped up again since we last chat. So this is another thing, nature Compensation Scheme. I'm gonna be honest and say that I don't actually know that much about it other than it's been launched. Could you just give me a bit of an overview of what the Nature Restoration Fund is and, and how does it relate to, to BNG, or, or does it even relate to BNG? So the Nature Restoration Fund comes from part three of the planning and infrastructure bill, which is a bill intended to speed up planning, uh, unlock, uh, land for housing targets, things like that. And Part three pertains to this, this thing called the Nature Restoration Fund. And the way that it works is for a particular environmental harm, for example, we'll use the example of impacts on bats because they're so, uh, yeah. Such a popular one to talk about at the moment. I mean, that, that bat, bat tunnel, there's more press than, than the centers. Well, but with the example of, of bats than the, the Bat tunnel. Currently, if you're a developer and you have bats on your site, you will be required to. Do some mitigation, um, try and compensate for, for damages to those bats. For example, building a bat tunnel, putting up bat boxes. And this has been viewed as a, a blocker to development. There's no evidence to, to demonstrate that it is, but it's kind of widely been discussed that these species based, uh, mitigation measures may be making development unviable or holding it up. So with, within the. Part three of the planning and infrastructure bill, you choose a particular environmental harm such as bats and an environmental delivery plan is created. And what this does is it sets a levy for, uh, impacts to that particular feature. So in this case, bats, it would be some kind of bat tax. And this is set by Natural England and Natural England get this tax and they spend it, uh, on measures that will, um, help bats. But something that is concerning is the, the language within this bill. So the bill refers to something called the overall improvement test, and basically the Secretary of State signs off on these environmental delivery plans if there is a. Uh, likelihood that the measures within the environmental delivery plan are likely sufficient to outweigh the harms of development. There's a lot of likes thrown all over the place. Um, so there, there is concern that it's not robust enough to actually compensate for these, these harms. And the rate which the levy is set at has to be at a rate that wouldn't make development, uh, unviable. And so we're concerned that it will be set at quite a low, low amount, uh, potentially not enough to, to compensate for the harms. And another thing that that is frustrating about this is that the levy paid by the developer will not be proportionate to the impact that they're having on that feature because the bill, the bill's intent is to move away from measuring and compensating for impacts on a site level. So. This le will potentially be set at a, a flat rate for developments. And this completely disconnects it from the mitigation hierarchy because if you are on a site where you've got a lot of bats and you know you need to pay a lot of bat tax, then maybe you'll think about putting your houses somewhere with less bats. So overall, um, a lot of ecologists are very frustrated with this bill. Uh, with this, uh. Proposed nature restoration Fund. I think in, in theory, it's a, a very good idea. Having the strategic approach to species mitigation, pooling the resources, um, but potentially delivery is, is not ideal. And in terms of how it interacts with biodiversity net gain, we're not sure. The, the government have said that it won't replace or, uh, supersede biodiversity net gain, but the language of the bill means that it can, an environmental delivery plan can be created for any environmental harm, um, that, that the government wants to. So it could be species, it could be protected sites, it could be nutrient pollution. And there has been concern that in the future it could be BNG, but that doesn't seem to be the plan Right now. It seems that BNG will remain as is and. The Nature Restoration Fund will perhaps tackle species based mitigation and, uh, things like nutrient pollution. Okay. That's really interesting. I'm just gonna ask a couple of clarifying questions to make sure I get it. So, if I won the Euro millions and I suddenly decide that I want to tackle the nation's, uh, housing crisis, which is very real and, and built some affordable housing in kind of my area. Uh, and there's a nice green field, uh, down the road and it's full of ptro bats and it's actually like a major breeding ground for pepper straw bats. Uh, I'm gonna, I have to, I'm gonna use half the site. So I've still gotta do my BNG calculations and I'm gonna do, put a, I don't know, put a lake in there and some wildflower meadows or whatever the cheapest, probably improved brass land.'cause I think that's the cheapest one to do. But then I gotta cut down these trees and I gotta kill these bats. Um, I don't know, do I have to measure how many bats there are and I just play like a fat, like it's not in law yet, but I will just have to play a a a a flat. Back tax, uh, like, you know, 20 quid a bat. But it would, it could be a potentially additionally, but then actually that sounds like there's some murky stuff that actually maybe they just might be, I just pay the back tax and I don't have to worry about b and g or, or is it more we don't know. And the classic, it's a bit more complicated than that and more research is needed. Where, where are we? So the, because it's not, uh, in law yet, we don't really know what it, what it will look like. A lot of this is based on, uh, expert legal interpretation of the bill. Um, but most of the interpretations of the bill that I have seen suggest that there won't be any measurement of impact. Uh, the tax might be set, for example, per hectare, uh, rather than per bat. Um, and, and that is, that is a frustrating, uh, part of all of this is I think. Mitigating strategically and putting money into, into a pot so that the bat Conservation trust can do some bat mitigation is a good idea. But I think measuring the impact so that you pay proportional to that, uh, is important. And something that we've also, uh, come across from housing developers is this idea of, of social acceptance. So once you've won the Euro Millions, if all the, uh, local residents see you chopping down these. Trees full of bats. Um, it's, it's not a particularly good look for the, for the housing developer. Um, so that's another interesting kind of part of this is how people will perceive this and also how reputationally, how developers feel about it. Because many developers have taken great strides in the last few years to, um, really integrate biodiversity into their process and embrace biodiversity net gain and. Even they disagree with this, this proposed approach. Interesting. Yeah. And, and again, there's some, like, you've showed me some examples of really amazing credible, uh, developers doing amazing things. You know, improving nature on site, working with brand put you, you'd only have to go online. Um, but I'm just aware that as things move at pace, uh, and, and this government does wanna move at pace, which again, you know, we, we do need housing, uh, but things. Errors can be made when you move quickly. I, I think on that social acceptance, it might be a great time to bring in and Matty, and maybe Matti, you wanna just have some reflections about, you know, BNG, the Nature Restoration Fund, kind of what you think is sort of good or bad, or just actually your particular insights around some of this, this work. Super. Thanks for the floor. Yeah. Um, maybe it's good to remind ourselves that something that is, um, good and perceived socially speaking by someone or by a set of actors might be. Seen as good from, from someone else. And I think the interface between the Nature Restoration fund and biodiversity net gain kind of highlights this. Um, and I think strictly speaking for biodiversity net gain, what's interesting is, um, what we've been finding in our conversations with, uh, practitioners, but also people. Engaged in the policy development of biodiversity net gain. Uh, what everyone seems to kind of agree on, um, is really the way that biodiversity net gain has, um, put society from a planning system perspective to think about biodiversity impact, um, of our development. So, um, from the small scale developer up to, uh, nationally significant infrastructure plans, uh, we all kind of wondering now what's the impact of our infrastructure development and, um. Planning permission's been been given, uh, around for housing and more. Um, the pitfall of, of the way this regulation has then, um, played out is that it's basically brought in a very formal relationship between, um, local authorities, um, and, and developers. So that kind of informal conversations that was, um, somewhat allowed before, um, in. Uh, what a developer could do more, could have done more for a planning permission to be granted from a planning office. Uh, now comes to a mandatory relationship of a 10%, uh, net gain to be, to be met and proved, uh, for basically the planning permissions to go, um, to go ahead. Um, so these kind of reshuffling of the type of negotiation and Levi, the local planning authorities have, um, in conversations with developers and why the. Um, you know, ecological consultancy supporting developers in complying with the regulation, um, has changed Dr. Dramatically. And we have examples of, um, particularly in terms of small scale sites and developments, which is, uh, something not, and, and you, in the conversation we're touching upon quite a lot is that scaled developers now see. Um, land valuable from a, from a double metrics perspective. So you have the land value on the one end, but also the potential biodiversity value on the other hand. So all the land that they could deploy and give a con, uh, conservation in a much more philanthropic way, um, has become so valuable to them, uh, in the long term, uh, business that they have as developers. Um. Basically any philanthropic, uh, nature restoration action has come down in the, in the need to retain land for, uh, complying with to biodiversity net gain for future development. So I think that's one of the, uh, biggest under underlooked, uh, pitfall of, of biodiversity net gain, uh, deployed in a mandatory way as we know it nowadays. Um, and I think the second pitfalls in terms of social accountability in relation to. Is this notion of social acceptance. Um, and so understanding that the way the biodiversity net gain has been, uh, deployed has, has led to the emergence of a range of actors. Um, and some of these actors are much more publicly present, uh, and accountable to the local communities or local populations where the development, but also the offset or uplift. Of that development occurs. Um, meanwhile, some other actors that work and tend to work at the national level, um, are ever more or less accountable to the public. Um, so you have these tension between the two ways that biodiversity net gain in terms of offsite uh, gain could work out. Um, and that really determines different visibility exposures and then social accountability on what's. Recovered and, uh, and how so from an ecological perspective, but also where the money that is being generated from biodiversity and again, as a market, so that kind of financial surplus, uh, is then being, um, redeployed. Uh, and you know, in the two key models that we seeing today is there's a model, the working, a for profit logic where basically that income, that surplus income becomes, um, you know, it's a necessary basically to repay. Um, an internal rate of, of return. So an investment for investors that have made, um, the business of habited banking possible in the first place. Um, and then you have a not-for-profit way of implementing biodiversity net gain, where the revenue generated from, uh, the sales of those units to developers is then directly reinvested for, um, strategically and more. Um, yeah, socially liberated nature recovery of the like, of, um, the local nature recovery strategy. So I think it, it's really interesting to look at biodiversity net gain as a range of actors that has come, um, into the conservation, into the conservation sector, but also to very different models for, uh, accounting and social license, licensing, nature, the nature of restoration that we fund through these, um, these market. Thanks, Matt. So, so if I've got that right, uh, what you are kind of saying is actually historically. And I guess part, part of the challenge is things were a lot slower in terms of development, but there used to be more of an ongoing con consultation between, uh, local authorities, developers, and the community about, okay, what's right for this area? What do people want? And there was more leeway about what could be done. And also there was more of a. Philanthropic edge of like, well, we are gonna, we're gonna put a lake in some trees here because we like ducks and the people like ducks. And that's just a good thing to do. That's now shifted to this sort of more market based thing where you have different actors appearing, some of which are going, uh, we're gonna do biodiversity at gain off site, we're gonna get the money in, but we're gonna reinvest that into, you know, community liaison and, and, and, and putting the ducks that people want. And then there's another. Sort of growth of this other type of hidden developer or hidden land banker that is just, you know, looking at the numbers and playing the metrics to kind of say, well, actually improved grassland is, is whether or not people want it. This is what will get the best market return. Or in terms of development, this is all I need to do and I don't, I can, I can be pushed through fairly quickly and I don't need to do all the, the social accountability stuff. Uh, 'cause actually, uh, it's not legally. Uh, uh, a legal necessity is that is, I mean, am I broadly paraphrasing? There was, there was a lot more in there. Is that kind of aligning with what you are thinking and seeing or? Yeah. No, that is a very, um, accurate summary and I think maybe the missing element there in explaining why one model might be seen as less socially accountable than, than the other is because, um, some habited bank providers that work in a for for profit logic tend to work more. With for profit responsible bodies. Um, so instead of entering into a legal agreement with the local planning authorities where they plan on having habit, establishing habited banks, uh, they can take parcel, parcel of plans, um, and enter into Conservation Covenant. So the kind of local planning authority, uh, as a role of the core implementer of biodiversity net gain, uh, but also as a. Institution trying to redirect nature restoration that is strategic for the place where it happens. Uh, then kind of comes down, um, in one of the two possible implementing models of, of biodiversity net gain. So when working with a responsible body. For profited bank providers tend to have a less of a conversation with the planning authorities where they do nature restoration and therefore, uh, there's a whole set of conversation that comes down, uh, in terms of missing conversation about strategic, um, habitat, strategic nature restoration, the local nature recovery strategy, uh, which is much more democratically assessed and what. Um, you know, an environmental consultancy in itself could decide, uh, in terms of what nation needs to be recovered and where. A a lot of this reminds me of the project management triangle of, uh, you know, fast, good, and cheap. You know, pick two and we're definitely going for fast. Um, so na, I wonder if you've got any thoughts or any questions for, for Matty about this and also how we balance the ecological with the social and the need for housing.'cause it seems all very complex, but I'll hand it over to you now. I just wanted to, to briefly touch on one of the changes in the consultation, which I think is, is very interesting and I would love to, to get Matt's take on, and is one of the proposed mechanisms for enabling small developments to achieve BNG more easily in a more affordable way, uh, is to relax the spatial risk multiplier and the way that the spatial risk multiplier works currently. As a development, if you purchase units within the same local planning authority or national character area, they're worth, uh, they're worth whatever they're worth. But if you purchase them in an adjacent local planning authority or national character area, you get a 25% discount. So you need 25% more units. And if they're in a non-adjacent local planning authority or national character area, then you get a 50% discount and you need to buy double the amount of units to, to meet BNG and. Many local planning authorities and national character areas, but specifically local planning. Authorities currently don't have habitat banks operating within their boundaries. Um, there's 84 Habitat banks currently operational. There's more than 300 local planning authorities. So your probability of a, as a developer of being somewhere where there aren't many habitat banks nearby is quite high. So one proposal is to loosen that for small, small developments so that they can purchase their units from anywhere in the country and not be penalized, um, for that so that they can access them more easily. And this, this is something that we are supportive of. We think it's a, a sensible measure to help small developers who are more likely to need offsite units. But there obviously is a potential social tension there because we're doing away with the principle of kind of closer, uh, is better. Um, but, but there are a few kind of caveats in that because just because the Habitat bank is in the same local planning authority doesn't mean that it's successful to the public. And yeah. So I'm just very interested to know your thoughts on that, Matty. Yeah, thanks Na, that's. It is a tricky question in the current consultation, and I think there's also, it goes back to the tension between how to balance the onsite versus offsite. So we know that the onsite is able basically to, to keep nature by where the development is happening. So it retains, um, you know, the, the social value, the social benefit of having population communities that are close to, to, um, green space and, and urban nature, uh, with all the benefits that. But we also, a more scale developer have been, um, hugely and disproportionately affected by mandatory biodiversity net gain, uh, in the sense that, um, just entering into a section one six, so a legal agreement with, um, the local planning authorities can. Can be very expensive to them. Um, as well when trying to set, set up a habited bank that is, you know, doing compensation also for a small scale developer. So they, they get trapped in a range of costs that, um, you know, biodiversity net, again, as imposed on them. And I think given the, um, allowing basically the regulation to kind of lift that multiplier, uh, and make this unit more accessible to small scale developer, effectively a. You know, and under supply of these units for them potentially within the same planning authority and national character areas, um, has potentially a great impact in terms of facilitating the way that works for them and reducing or mitigating these set of disproportionate, um, um, kind of impacts on small scale developers, but also bank providers, uh, on. Careful about, um, on that, on that side is maybe, um, enforcing and, and this really speaks to the kind of capacity or governance gaps that, uh, you know, we often in times talk about when, when thinking of these market-based instruments for conservation, right? The problem might not be the, the tool that we use, IEA market, uh, that is kind of more, a bit more independent and less centralized, like the nature restoration fund will, will do in the future. But, um, at the same time, there's a, there's also a lack of understanding of the people where the development is happening and the way they can endorse, uh, anything in, in this process or not. So for a small scale developer to go and buy units farther away, um, basically means to reduce nature, accessibility to nature for the locals in the place where the development is happening. I think that there must be a, a sensitive intervention point there in the policy or in the consultation process for that specific development for local people to feedback on what exactly what the social trade off of that loss of, of green or hydrogen nature might be to them, and therefore a bit more of a flexible and, and compensation that speaks to the community and can kind of make the community or leave the community happy even if biodiversity cannot be. Fully retained, um, on site if, if that makes sense. So sometimes it's interesting to think of these mechanisms when it comes to the side of social accountability and licensing at least of the market. Not really from a regulatory perspective, but what can we use, how can we use these, um, regulation that is somewhat flexible in the way that it's written?'cause it's really left society the way to find the way through the regulation to comply. All the different stakeholders is then assessing. Okay. Well we, we haven't realized from the very beginning that communities might play a role.'cause one way or another they are affected even if they don't play a key role in implementing or achieving biodiversity in a gain from an ecological perspective. Um, and I think regaining the awareness that communities might have a role to play even more, it's more scale developments where they can actually have a say on where nature. Um, can be compensated. And if not in formal ecological nature, then that could be something else that the community could, could be compensated for and with, um, I think could be a game changer in also the way that BNG will be developed or even more the Nature Restoration fund will be developed.'cause um, you know, there's a lot that could be said there in terms of social accountability and what the role of a centralized fund. Dispersing money than on the ground could do or can do with, um, and in harmony with communities. It's very interesting. Our, our kind of take on it is that potentially doing away with the spatial risk multiplier for the time being for small developments is a good idea, but that developers and local planning authorities need to keep in mind kind of best practice for, um, you know, access to green space, uh, with within that planning. I was just wondering if. In your work, you've come across anything on the likely accessibility of habitat banks to local communities, because I think that there's kind of this assumption that if the units are bought within the same area, that that maintains accessibility to green space. But realistically, if many of these habitat banks are. Fields owned by a given landowner within the middle of their estate. How accessible are they to, to the public? But I don't know if that's something that you've come across or thought about, but I'm very interested to, to know your thoughts. That that's another, another interesting question. When we think around, um, the role of accessibility and accessibility in these regulation, the way we've been looking at it, um, from the very beginning is, uh, is kind of a tension. There's a tension between the accessibility of these. Tend not to be in fact, accessible. So, um, let's not confuse, um, you know, a habited bank in the countryside as an amazing country park that is now established for the public to use. Um, no, as a matter fact, that remains very much privately owned. You know, land is a passive land simply managed in an in, in another way, uh, for a landowner or habit bank provider to be able to supply these units. And actually, I would argue that in the way, or at least in, in, in the Oxfordshire case studies where we've been talking to people. Um, there's a, because the landowner becomes legally liable to the leave of those units, so that achieved nature restoration for them to monetize the units and therefore make money through the market. Um, that kind of pressure and legal liability also imposes and, you know, results in the landowner wanting to maintain, um, the parcel of land pretty much enclosed or as protected as possible to mitigate any possible harm to the habitat that is. Restore basically, and recreated on site. So, um, there's, there's that kind of tension between the accessibility to the market from an individual perspective of these landowners. But then, um, the accessibility of the landowner, the landowners to the market, uh, into the market might result in less accessibility or less. Accessible land to the wider public and the community, especially the urban communities where, um, this kind of nature restoration might, might kind of come from in the first place as offsite restoration of urban developments. Um, and I think what's interesting, what's interesting here is also in terms of the role the local funding authorities might have or not have in this instance. And I'm glad you, you guys are mentioning in the, in your response to the consultation that. You know, local planning authorities should really keep in mind best practice for accessible land and, and keeping nation nearby. When, um, when giving these exemption, um, to, to small scale developers, on the other hand is, is really important. And this came up as a yes, striking these differential or different elements that determines how biodiversity net gains then, um, kind of turns out, um, socially speaking or what it leads in terms of social outcomes. Um, but local planning authorities are different offices, so they rely on very different resources and, um, knowledge and expertise and experience of processes that they've been piloting and refining over time. Um, and I think a key challenge in biodiversity net gain is that. The core of the regulation relies upon local planning authorities' capacity or ability to enforce the regulation, maintain sound, ecological vigor on the one hand, but also maintain social safeguards on the others. And I think, uh, because of the capacity gap and because local planning authorities might live through different, very different resource access, um, not all planning authorities will have the same capacity to enforce. Those safeguards. Um, so I'm thinking within, uh, Oxford ship, we have great examples, great examples of that. So there were local planning authorities that had been piloting biodiversity metrics for the last decade. Um, and they had processes in place and biodiversity and that gained offices in place to kind of open negotiations with developers on the one side and habited bank providers, uh, whether there were organizations or individual landowner on the one hand. But then we also witnessed all the local planning authorities that are actually still after one year from mandatory implementation, still trying to catch up on creating those processes, right? Having a process for monitoring and enforceability in place, um, is still a luxury I've learned, uh, during a data collection. So it is really important to remind how different planning authorities might be or not be able to enforce these different safeguards. So, um, ideally something that. Level up. The capacity among local planning authorities is a key game changer in the way that biodiversity net game could play out at the national level in the future. I think that's a, a really important point in all of this is we're aiming to speed up development to meet house building targets, and we don't have any evidence that nature is a blocker on development, but we do have evidence that local planning authorities are under-resourced and. There are some delays in certain projects resulting from that. So I think that's a message from all of this is to increase resourcing of local planning authorities if we really want to, uh, speed up the planning process. And I mean, we've been saying that for a long time. People before, you know, we even started doing our research on BNG. People have been saying this, so, but yeah, I think it's something important to bear in mind throughout all of this that it is. An action that could be taken that would work to speed up planning. So, so if I win my euro in millions, I should be funding, uh, ecologists and, and planners in local authority. But again, there's no, the classic line of like, there's no money and what I've loved hearing you talk about it just really shows the complexity. It almost becomes philosophical in that, okay, I have one day you're in millions. I wanna build houses, uh, that are gonna be great for people and I might do some good stuff for nature on it. I kill the bats, I pay the bat tax. Uh, but that actually makes the, some bat people in Norfolk happy 'cause they can build this, you know, extend the habitat. Uh, then I do the houses and actually it's a small development. Um, so I'm gonna do it offsite and I'm basically gonna compensate it by, you know, expanding a peabo in Scotland. And that's great for the, the pea bog is, you know, from an ecological perspective, it's like a really rare habitat. And it's fascinating. This num moss now blossoming. Uh, but for the 15 families that live around that green space, they've now lost a, a bit of green space that they used to walk their kids on every day that they saw the birds they had access to. They're now, you know, horrified by that. But then also, you know, five miles down the road, I've got a family living in some terrible private, single room, awful landlord where there's mold on the walls. They can now move into one of my ethical social rent houses, and that family can have a whole new life. And so nature wind up north, but there's a. Fragmented community that, and I think all of this has, you know, social and political impacts. And I think there is a way through, but properly the way through is, you know, deep consultation and understanding and kind of proper resourcing. And I, I don't think we have that. And I think that, you know, we have, you know, the, the, the messages we need to move fast. Um, but I think there's gonna be some dynamics with that. I think it could, it sounds to me like it can work, but it relies on everyone being a good actor. And everyone being a bit altruistic and, and not only looking after themselves and their profit line, but trying to look after the community and trying to be responsible. Of which there are many people in the world that are like that. Uh, but sadly I think there's a few others that aren't. Yeah. Maybe just jumping in 'cause you said something really smart in terms of we wish everyone did the, the right thing. And I think in this case we, we tend to forget that, where we lose nature. Uh, so those 15 households that are about to lose a green space, as you were mentioning. Might be really sad about it, but there's a winner on the other hand, which is families that might move and leave a very old house, poorly insulated house into a new build. Now the question is whether everyone in that lot or around that green space managed actually to ever say on the type of development. Um, because I think that's how we could balance out these two things, and that's where the. Kind of sweet spot between the ecological and social trade-offs within these regulation because there's a, there's an embedded trade off, uh, when thinking about bio diversity, net gain there, uh, can be mitigated. So what type of development we are prioritizing and what kind of development, everyone is happy to kind of let happen within the neighborhood or area, or even in a green space that is socially value, valuable and valued. But there might be another social value IE accessible to affordable housing. Very much insulated housing for, for other families. So it is really about valuing the assets between the gray, from the gray to the green assets that we have around, um, and make the decision that makes the most people happy, but making sure that everyone did have a say, uh, on that. And that goes back to, as much as local planning authorities have differences in their capacity, we have to realize that communities can differently voice themselves based on resource success as much as local funding authority. Uh, do so There's always, um, attention that we kept in mind when we do consult also with communities on the kind of development, um, that they would like to see in the local area. I'm, I'm loving that Matty. Sometimes though, I think you need to read the auction mail comments or come and come and see where development's been planned.'cause trust me, people that I see sometimes. You know, do they care what the development looks like? They just do not want that development. And that's just a, a fraction of society by the, it's quite a vocal, you know, one, and, and, and, you know, they feel absolutely justified and, and may well be justified, you know, as well. It's, it's like, it's a real tragic loss. It real feels like a ripping out. Um, it's very visceral. Yeah. I, I just wanted to, to emphasize that, you know, we are. Pro housing and we want the, you know, we want everyone's housing need to be met. And I'm not opposed to changes to the way that the planning system treats nature to get there, but it has to be evidence-based and nature can't lose out. And I think that's my current frustration with this is that it's not evidence-based. We don't know that, that these, that nature is delaying planning and that these changes will fix any potential delay. Also the changes from the changes nature will, will lose out. Um, and we do need nature, we need healthy ecosystems. Um, so yeah, not just to, to kind of set, set the scene that we are, you know, pro making the planning system work, but it has to be evidence-based and it has to also work for nature is my take on it. I agree with all that. It's a great point. And I guess Matt, I wonder. Would you agree with that from the social perspective as well? You know, we want housing, but it has to be, you know, uh, socially acceptable as well. We don't, people don't necessarily want a certain style of, of housing that they don't feel they've had any kind of say over. I think there's definitely space for housing and nature. Uh, at the same time, I think biodiversity. All of the planning infrastructure, um, was supported by, um, a bit more or a reflexive, consultative process rather than an informative one. So bringing people in, um, where we develop, um, both infrastructure and nature or we plan around nature, um, can really make, uh, a huge difference in the way that bio will play out, um, within the next years, but also any other conservation policy reconcile. Um, and. Amazing. I just wanna thank you both for your research, for your insights, and for your time today. Uh, it's really complex. Again, you know, we, we are very aware we need more housing. We don't wanna lose nature, and we want people to be happy with any kind of development that goes in there. It's not a challenge, thankfully, that I have to deal with directly, but I'm really glad that there are people like yourselves looking at the evidence and hopefully trying to inform policy and nudge it a bit more in the right direction. Uh, but we'll see. So yeah, just thank you both for your time. Thank you. It was great to, great to talk with you. Thanks so much, Steven. You've been listening to the Nature Recovery Podcast. 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