BTF Comments – 14 June 2025

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or compensate for, a harm caused by that project, ordinarily that measure could not rationally be described as a benefit. So, for example, where a development would result in a loss of biodiversity, the provision of additional biodiversity on the same site or on other land nearby in order to completely offset that loss, so that in overall terms there is no net reduction in biodiversity attributable to the development, is not a benefit. It is simply the development "consuming its own smoke" [paragraph 152].

This means that the applicant must be able to demonstrate that the development will achieve more than just ‘no net reduction in biodiversity’; they must show that the development will ‘secure measurable net gains for biodiversity.’ The only way this can be done is by using the Statutory Biodiversity Metric calculation tool.6 Despite their reliance on the exemption, the applicant must still provide evidence to show that they have complied with the obligations imposed by the NPPF.

Loss of Individual trees habitat

Although we are unable to comment on the baseline value of all the habitats on the site, we do have the advantage of seeing the applicant’s arboricultural evidence7 and so can comment on the loss of the Individual trees habitat on the site.

We calculate that there are (excluding the offsite trees, T12 & T17) 20 trees on the site, six of which are in tree group G16. Four of these trees are to be removed as part of the development – trees T08 - T11.

The baseline habitat area of the Individual trees habitat is 0.1384 hectares. There is a loss of 0.0163 hectares, leaving 0.1221 hectares being retained. On the assumption that this habitat is in moderate condition and in an area of low strategic significance, these trees have a baseline value of 1.11 habitat units, of which 0.13 habitat units will be lost.

To make good the loss of this medium distinctiveness habitat, 11 replacement trees - which will achieve moderate condition after 27 years and are planted in an area of low strategic significance within the LPA - will have to be planted.

6 https://www.gov.uk/government/publications/statutory-biodiversity-metric-tools-and-guides. 7 25_12454_H-ARBORICULTURAL_SURVEY_REPORT-3950900.