The SUDG and its members have repeatedly stated support for the development of biodiversity net gain (BNG) policies in our coastal and marine environment that would allow them to deliver meaningful biodiversity gains with minimal regulatory bureaucracy and process. However, the SUDG still has significant concerns about the application of the BNG intertidal metric tool and the excessive costs of the UK Government’s statutory BNG credits, and how this will affect any emerging intertidal BNG markets. We expect to see a slow down in development at the coast as a direct result of this policy, the increased costs to developers and the added uncertainty it brings.
There has been a general consensus amongst all stakeholders that for net gain to be successful in the coastal and marine environment, it must be delivered strategically, avoiding a piecemeal approach. The current BNG policy and intertidal BNG metric calculation tool do not encourage or support a strategic approach within our coastal environments, and with development slowing down, potential BNG gains that could have been delivered by industry will be reduced.
Through industry testing we have found several ‘flaws’ with the intertidal BNG metric calculation tool and have serious questions about whether the metric drives the best outcomes for sustainable development and economic growth in the coastal context. The metric is excessive, often arbitrary and has become increasingly complex at every stage of its development. Furthermore, the introduction of excessively priced BNG statutory credits will compound the difficulties that developers will face, removing any legitimate option of last resort (as the costs are prohibitively high).
We urge government to put in place a moratorium on the biodiversity metric for intertidal habitats, until a more realistic alternative can be developed.
Should implementation go ahead as planned in February 2024, we are asking for an opportunity to meet with government in the first quarter of 2024, to reflect on the implementation of BNG in the intertidal zone and to give marine industries an opportunity to provide further feedback and discuss additional industry evidence of the real-world impact of the BNG policy. We are also asking for a clear timeline from government for review of this policy in the intertidal, with transparent mechanisms for how industry concerns and impacts have been considered and acted upon as appropriate.
There is huge potential to achieve so much through the successful implementation of a proportionate and straightforward policy for marine and coastal net gain, and SUDG industries are keen to continue to work with government to ensure that these opportunities are maximised.
