Biodiversity Net Gain

We have been getting our first Biodiversity Enhancement Management Plans (BEMPs) to quote for habitat improvement recently. As far as I understand this is not a mandatory requirement for developers until later this year but by the looks of it some developers are already using the framework. This is one of the EU-exit policies in order to halt UK biodiversity loss by 2030 and achieve  biodiversity net gain (BNG) by 2050. It applies to all developers, in that they need to deliver a 10% net biodiversity gain in new developments (housing and industry). This is managed by using Natural England's Biodiversity metric HERE and implemented by following the recommendations in a BEMP. 

We often work from consultant reports to quote for green space management works including tree reports, arboriculture assessments and environmental impact assessments so presumably BEMPs will be a regular additional management document in the future for us. We work with consultants rather than do the consultancy reports ourselves. I dislike writing red tape (although I've written more than my fair share in the form of neighbourhood plans, local policies , H&S documents and feedback of public consultations/legal cases etc) and much prefer working with more inspiring/more popular report formats such as bird and wildlife reports etc- however of course I have utmost respect for good consultants and 'red tape' report writers - it would be my worst nightmare spending my life writing those things so thank God that some people enjoy it!. I enjoy reading them in the same I enjoying eating fancy food but not preparing it :-)   

From our perspective we would like to see our clients having more budget for spending on habitat improvements rather than red tape so we aim to create efficiency between mandatory/recommended reporting and habitat improvement implementation.  A lot of the time, where reporting is not mandatory,  the knowledge of an experienced ecological-minded horticulturist/arborist can save clients a lot of money as there are general designs and approaches to green space management that will lead to biodiversity net gain without the use of complex metrics, setting baselines and reporting. A lot of reporting is 'bulking out' and unnecessary mapping and details which is designed with a profit motive to support a management consultancy class (jobs for the boys and girls) but essential information and data can often be found for free by extraction from Google Earth (tree location mapping, habitat mapping etc) and biodiversity monitoring and identification through free apps (Ebird, Irecord, Merlin, Plant Net etc). In fact as far as we are concerned the ultimate biodiversity monitoring and management plans are generated from a combination of methodology used by professionals (e.g. CBC, BBS, Phase One Habitat surveys etc) and by activities/behaviour/methodology used by amateur naturalists- birding, moth trapping etc.  We created reports for Beddington Farmlands that unified all the data from these approaches e.g HERE which created a high resolution image of the ecology at Beddington Farmlands. This 'ultimate' kind of reporting is also good to use as an accountability tool to keep an eye on dodgy ecological consultants and create scientifically robust counter narratives to the professional ecologist who often needs to create cover-up stories for the developer. 

 In terms of monitoring and implementation of habitat management we also believe that this is best achieved with the use of professionals and amateurs and furthermore believe that the distinction between professional and amateur should be narrowed by the incentivisation of what is currently done by amateurs by renumeration or credits i.e. amateurs should be paid and professionals should be paid less for bulking out and un-necessary red tape. There is a niche in the market for this that we use to create efficiency in our projects but one that we also offer to clients (essential only reporting and green space management plans and work schedules that utilise volunteers/free apps). At the end of the day if money is being wasted on red tape and not being spent on actual habitat improvement then ecological consultancy is a scam. We encourage our clients to circum-navigate any scams and meet their mandatory requirements as efficiently as possible, manage risks and certainly avoid expensive consultancy if they can. We want our clients to spend the money on plants, trees and habitat improvements and not reports. 

Back to the subject of BNG our first experiences of dealing with our first BEMPs has revealed some interesting observations. One BEMP was created by using a baseline by carrying out an ecological survey in January (when biodiversity is at a visible minimum )which is a standard method used by dodgy ecological consultants in order to set low baselines. We have had consultants in the past deliberately leaving out the presence of Viviparous Lizards from a site's EIA (which if found require expensive mitigation measures), over-stating the territories of Lapwings (in order to sex up an annual ecological report). under-reporting CBC bird territories in order to set low baselines, completely leaving out the presence of breeding Yellow Wagtails and Corn Buntings in an EIA despite how vociferous and obvious and numerous these species were etc etc. Basically like everything in this world there are good and bad ecological consultants and needless to say it is the bad ecological consultants that are involved in long term managed decline and exploitation strategies used by certain corporations/developers. In fact there is a commercial advantage of being 'bad' in many cases- the more dodgy you are the more companies want to hire you so you can get away with murder (ecocide) and maximise short term profits.

So as always we aim to see through all the bullshit and cut through the fat and the noise and get to the meat and bone that can be used to generate real and measurable ecological improvements. We also enjoy 'vampire hunting', exposing dodgy ecologists and dodgy corporations. Ultimately nature conservation is about stopping the bad guys destroying nature and encouraging the good guys to protect it. The enemy within nature conservation (the bad ecologists) are the single greatest threat to nature conservation as a nature destroying corporation use them to cover up their destruction. Without the dodgy ecologist there is no dodgy nature destroying corporation/developer.

So it's a bit too early to see yet how dodgy consultants are using BNG but our first experience looks like the metric can be used to set a low baseline and end up with this almost arbitrary value that can easily be manipulated to show a 10% increase. Also we have no idea at the moment how any of this is going to be enforced (enforcement has always been a problem in ecology with current mitigation measures rarely being enforced so that is surely going to get worse if there is more mandatory reporting without a corresponding increase in enforcement officers). Anyway time will tell, we should in time be able to establish some genuine values for gardens and urban green spaces which can be used for comparative purposes. Like ever and always this new policy can be used as a weapon to fight for nature but it will also be used by some to keep destroying it or even escalate it's destruction. No laws or policies will ever mitigate for evil , but they can certainly be used for novel new ways of 'vampire hunting' and new ways of achieving good outcomes too and there are fewer fun things to do in this world than creating exciting new projects and hunting down the bad guys and the EU-exit new ecological policies are best seen as new power-ups in the game- that can be used on both sides- to protect or destroy nature.  As they are new power-ups in the game there is an advantage to either side on who can master them the fastest.  

Here's the ChatGPT version of this (below highlighted). Not as fun but probably better for me to use ChatGPT in future to edit my conscious streams- which is what I use this blog for. I tend to brain dump on here and if I have to write something that will be published I edit it from here. I find moving from brain dump to final edit a lengthy process which isn't worth it on a blog. I work on the assumption that nobody but me is going to read a poorly structured conscious stream and I often use this blog to look back on my thought streams for reference to track ideological consistency and drift- as a wannabee rationalist I would like to think I criss-cross the centrist line. However with an AI assistant now it seems to make sense to use it to edit thought streams for blog posts too.   

We have recently started receiving requests to quote for habitat improvement through Biodiversity Enhancement Management Plans (BEMPs). Although it is not mandatory for developers until later this year, some developers have already embraced this framework. The BEMP is part of the UK's EU-exit policies, aiming to halt biodiversity loss by 2030 and achieve biodiversity net gain (BNG) by 2050. It requires all developers to deliver a 10% net biodiversity gain in new developments, such as housing and industry, using Natural England's Biodiversity metric.

As a company, we often rely on consultant reports for quoting green space management works, including tree reports, arboriculture assessments, and environmental impact assessments. In the future, BEMPs are likely to become a regular additional management document for us. While we prefer more inspiring formats like bird and wildlife reports, we respect the work of consultants and understand the importance of regulatory documentation. However, we believe that finding a balance between mandatory reporting and habitat improvement implementation is crucial. In many cases, an experienced ecological-minded horticulturist/arborist can save clients money by implementing general green space management approaches that lead to biodiversity net gain without the need for complex metrics and excessive reporting.

We have found that some reports tend to be bloated with unnecessary details and mapping, which can be obtained freely through tools like Google Earth and biodiversity monitoring apps. We believe that the ultimate biodiversity monitoring and management plans combine professional methodologies (e.g., CBC, BBS, Phase One Habitat surveys) with activities carried out by amateur naturalists, such as birding and moth trapping. By unifying these approaches, we created comprehensive reports for Beddington Farmlands, providing a high-resolution image of the ecology in that area. Such reporting not only serves as an accountability tool but also helps identify discrepancies in the work of ecological consultants and allows for scientifically robust counter-narratives when necessary.

Regarding habitat management and monitoring, we believe that a combination of professionals and amateurs is ideal. We envision narrowing the distinction between professional and amateur by incentivizing the activities currently undertaken by amateurs through payment or credits. This approach allows us to create efficiency in our projects and offer clients essential reporting, green space management plans, and work schedules that incorporate the use of volunteers and free apps. Our goal is to ensure that our clients allocate more of their budget to habitat improvements rather than excessive reporting.

In terms of BNG, our initial experiences with BEMPs have revealed some interesting observations. One BEMP used a baseline established through an ecological survey conducted in January, which is a method often used by unscrupulous ecological consultants to set low baselines. Unfortunately, there are both reputable and questionable ecological consultants in the field. The latter may engage in long-term managed decline and exploitation strategies on behalf of certain corporations or developers. It is essential to identify and expose these bad actors, as they pose a significant threat to nature conservation. Without their involvement, nature-destroying corporations and developers would struggle to cover up their destructive actions.

It is still too early to fully understand how BNG and BEMPs will be manipulated by unscrupulous consultants. The metric could potentially be exploited to set artificially low baselines and easily manipulated values to showcase a 10% increase. Additionally, the enforcement of these policies remains a challenge, as current mitigation measures are often poorly enforced. However, time will tell, and we hope to establish genuine values for gardens and urban green spaces that can be used for comparison purposes. While these new policies can be used to protect or destroy nature, we see them as powerful tools that can be utilized in the fight for nature conservation. Our focus is on harnessing these tools for positive outcomes and using them as "power-ups" to hunt down the bad actors and promote ecological well-being.