Local nature recovery strategies in planning decisions

A local nature recovery strategy planning question comes up in two places on a development scheme, and they are easy to confuse. The strategy affects the value of biodiversity units through a multiplier in the statutory metric, and it is a material consideration in its own right when an authority decides where habitat should go. The first is arithmetic. The second is judgement.

Strategies were introduced by the Environment Act 2021, which requires them to be prepared for the whole of England by designated responsible authorities. They are not development plan documents, so they do not carry development plan weight, and treating them as policy is a mistake in both directions.

What a local nature recovery strategy contains

Each strategy has two parts, and the second is the one that affects applications.

The first is a statement of biodiversity priorities for the area: a description of the area, its existing habitats and species, the opportunities for recovery, and the priorities and proposed measures for achieving them.

The second is a local habitat map. It identifies areas of particular importance for biodiversity, which generally means existing habitat of value, and areas that could become of particular importance if habitat were created or improved there. That second category is the practical innovation, because it tells you where new habitat is wanted rather than only where existing habitat is.

The map is spatial and reasonably granular, though the resolution varies between strategies. It is not a designation. Land identified on it acquires no protected status, and a proposal on it is not thereby unacceptable.

Who prepares it and over what area

Responsible authorities were designated to prepare the strategies, and the areas follow upper tier geography: county councils, unitary authorities, National Park authorities, combined authorities and the Greater London Authority between them cover England in 48 strategy areas.

The practical consequence for a developer is that the relevant strategy is usually not produced by the authority determining your application. On a two tier area the district decides the application and the county prepared the strategy, which means two organisations have views about the same map and they are not always aligned.

Preparation involves the responsible authority working with supporting authorities, Natural England and local partners, under procedural regulations made in 2023. Most strategies have now been published. Check the position for your area rather than assuming, because publication dates differed and some are already into review cycles.

How strategic significance affects the metric

The statutory biodiversity metric applies a strategic significance multiplier to habitat units. Habitat in a location identified in a relevant local strategy attracts a higher multiplier than habitat in a location that is not, so the same habitat type in the same condition produces more units inside an identified area than outside it.

That has three consequences worth planning around.

1. On-site habitat creation inside an identified area goes further towards the 10 per cent requirement than the same creation outside one.
2. Off-site units bought from a habitat bank inside an identified area are worth more per hectare of habitat, which affects what you should be willing to pay.
3. The baseline is affected too, because existing habitat inside an identified area carries the higher multiplier, which makes its loss more costly in unit terms.

The multiplier values sit in the metric itself and have changed between versions, so take them from the current published metric rather than from a remembered figure. The metric must be completed by a competent person in any event, which is the point at which these decisions get made properly. A Biodiversity Net Gain Assessment that does not state which strategic significance category each parcel was assigned, and why, cannot be checked by the authority's ecologist.

Using the habitat map in site selection

The habitat map is most useful before a site is bought, and almost nobody looks at it then.

Two readings are worth doing. Where the site sits inside an area identified as of particular importance for existing biodiversity, expect the ecological constraints to be real and the authority's ecologist to be engaged early. Where the site sits inside an area identified as having potential if habitat were created, the scheme has an opportunity: habitat creation there is worth more in the metric and aligns with what the strategy asks for, which is a genuine benefit to put in the planning balance.

For larger schemes the map also helps with layout. Positioning the green infrastructure to connect with habitat identified on the map, rather than placing it wherever the engineering leaves room, produces better metric outcomes and a stronger narrative. A Green Infrastructure Plan that shows the connection explicitly is doing something an officer can rely on in a report.

The companion piece of work is still the ecology survey. A Preliminary Ecological Appraisal tells you what is actually on the site, and the map tells you what the area wants. They answer different questions and neither substitutes for the other.

Weight in decision making

Public authorities are under a strengthened duty to consider what they can do to conserve and enhance biodiversity, and to have regard to relevant local nature recovery strategies when doing so. That makes a strategy a material consideration in development management.

How much weight it carries depends on what the local plan says. Where a plan policy refers to the strategy, or requires schemes to contribute to the priorities in it, the strategy is being applied through development plan policy and carries weight accordingly. Where the plan predates the strategy and says nothing about it, the strategy is a material consideration that the decision maker must have regard to but can weigh as they see fit.

Do not overstate it in a submission. Claiming that a proposal conflicts with or complies with a strategy as though the strategy were policy invites an officer to correct the point, which weakens everything around it. The accurate framing is that the scheme delivers habitat of a type and in a location the strategy identifies as a priority, with the map reference given.

Where strategies are not yet reflected in local plans

Most adopted local plans were examined before the strategies existed, so there is a gap, and it will take a round of plan-making to close.

In that gap three things happen. Authorities use the strategy through general biodiversity and green infrastructure policies, which works but produces inconsistent application. Emerging plans embed the strategy directly, which means a scheme caught by an emerging plan at a late stage may face requirements the adopted plan does not contain. And some authorities produce supplementary guidance on how they will apply the strategy, which is worth asking for by name rather than hunting for.

Neighbourhood plans add a further layer, since a made neighbourhood plan is part of the development plan and some now include local habitat policies that sit alongside the strategy. Checking whether a neighbourhood plan covers your site is the quickest way to find out whether that applies.

Checking the position for your site

A short sequence settles it before the design is fixed.

Identify the responsible authority for your area and find the published strategy and its habitat map. Establish whether the site, or any proposed off-site receptor land, falls within either category of identified area, and record the reference so the metric can be completed on a defensible basis. Read the adopted local plan's biodiversity and green infrastructure policies to see whether they refer to the strategy. Check whether an emerging plan or supplementary guidance applies it more specifically. Then brief the ecologist on all of it before the metric is run, because retrofitting strategic significance decisions to a completed metric is how baselines end up being revised at the gain plan stage.

Where the site contains or adjoins habitat identified as of particular importance, raise it at pre-application. The authority's ecologist will have views, and those views are easier to design around than to argue with after submission.

You can see which reports a scheme with ecological constraints is likely to need and draft the planning documents from your own site details, then have the ecology work and the metric completed by a competent person.

Biodiversity net gain assessment requires a competent person under the Environment Act 2021 regime, and a draft is a starting point for that professional rather than a substitute. For specialist technical reports, qualified professional input may be required. This is general guidance, not legal advice, so check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.