BNG for Commercial, Industrial and Logistics Developments

Biodiversity net gain for commercial and industrial development

Commercial development BNG presents a particular challenge. Warehouses, distribution centres, manufacturing units, trade parks and data centres typically cover most of their site with buildings, service yards, HGV turning areas, parking and hardstanding. Since 12 February 2024, major commercial applications in England have needed to show at least a 10% biodiversity net gain, and smaller non-residential schemes have been included since 2 April 2024.

On a typical big box logistics scheme, the space left for habitat after the operational requirements are met is small. As a result, warehouse logistics biodiversity net gain strategies nearly always combine careful on-site design with the purchase of off-site biodiversity units. Planning for this early protects both the programme and the development appraisal.

Why on-site gain is so difficult on industrial sites

Industrial site BNG is shaped by the baseline. Many logistics sites are greenfield arable or grassland at the edge of towns, near motorway junctions. Converting most of that land into buildings and yards removes almost all of the baseline habitat value, so the scheme starts with a large deficit before any gains are counted.

The remaining land is typically perimeter landscaping, drainage basins and visibility areas. These can provide valuable habitat, but there is rarely enough of it to replace the lost units and add 10%. Brownfield commercial sites can be different: an ex-industrial site with open mosaic habitat can have a surprisingly high baseline, and such habitat is a priority habitat that may need to be retained or compensated for.

Making the most of on-site habitat

Although on-site gains rarely meet the full requirement, they still matter. The mitigation hierarchy expects developers to avoid and minimise impacts and to deliver on-site gains where reasonable, before turning to off-site units. On-site measures also reduce the number of off-site units that need to be bought. Effective measures on commercial schemes include:

• retaining boundary hedgerows and trees where access and visibility allow
• designing attenuation basins and swales as wetland and wet grassland habitats rather than lined, mown features
• creating species rich grassland and native scrub in perimeter landscape bands
• planting native hedgerows along boundaries to address hedgerow unit requirements
• installing biodiverse or sedum green roofs, or green walls, on offices, gatehouses and suitable roof areas, where structure allows

Each habitat must be realistic. A wildflower meadow beside an HGV yard that is regularly sprayed, mown or used for snow storage will not reach its target condition, and the local planning authority may challenge it.

Buying off-site biodiversity units

For most logistics and industrial schemes, the residual deficit is met through off-site biodiversity units. These are allocated from habitat banks on the biodiversity gain sites register. The spatial risk multiplier means units bought within the same local planning authority or national character area count in full, while units further away are discounted, so more must be bought. The habitat trading rules also apply: losses of medium or higher distinctiveness habitat must be replaced with like for like or better.

Statutory biodiversity credits sold by the government are a last resort, available only where suitable on-site and off-site options are not available, and they are deliberately priced well above typical market units. For large commercial developers with several sites, a portfolio approach to buying units, or creating a habitat bank on surplus land, can reduce costs. See our guides to BNG units and habitat banking.

Legal agreements and the biodiversity gain plan

Where significant on-site gains are relied upon, they must be secured for at least 30 years through a section 106 agreement or conservation covenant, with a habitat management and monitoring plan. Off-site units are secured on the habitat bank through its own agreement. Before development begins, the developer submits a biodiversity gain plan showing the final metric and the allocated off-site units. On speculative commercial schemes, the long term management of on-site habitats is often transferred to the eventual occupier or an estate management company, so it must be written into leases and service charges.

Timing and programme

Commercial developers often work to tight programmes driven by occupier deadlines. Because off-site units must be allocated before the biodiversity gain plan is approved, and the plan must be approved before work starts, BNG can become a critical path item. Securing a reservation for suitable units during the planning stage, and agreeing the legal approach early with the local planning authority, avoids a gap between permission and start on site.

Data centres, trade parks and mixed commercial schemes

Data centres often sit on large plots with generous security buffers, which can offer more space for on-site habitat than a typical warehouse. Wide landscape bands, attenuation wetlands and woodland screening can deliver meaningful gains if security and fire access requirements are designed in from the start. Trade parks and roadside retail schemes usually have high parking ratios, so tree planting in car parks, rain gardens and native hedges are the main on-site options. Mixed commercial schemes with offices, hotels or leisure uses can combine green roofs, courtyard planting and SuDS habitats to raise the on-site score.

Extensions and redevelopment of existing industrial sites

Extensions to existing factories and warehouses are also subject to BNG where the new development falls within the scope of the regulations and no exemption applies. On a previously developed site, the baseline may be low, which makes gains easier to achieve on site. However, older industrial land can support open mosaic habitat, ruderal vegetation and scrub that score higher than expected and attract invertebrates and reptiles. A survey before any site clearance is essential, because vegetation cleared after 30 January 2020 without permission may still need to be recorded at its earlier value.

Getting the cost right

For commercial developers, the biggest BNG costs are usually the off-site units and 30 years of on-site management. An accurate early metric, a design that maximises on-site gains and a competitive approach to buying local units keep those costs under control.

How Collington Winter supports commercial developers

Collington Winter works with commercial developers, logistics operators and their consultants throughout England. We carry out baseline habitat surveys, statutory metric assessments, design reviews that maximise on-site gains around operational requirements, and habitat management and monitoring plans. We also help source compliant off-site units and prepare the biodiversity gain plan for discharge. Speak to our BNG consultant team or get a quote for your commercial site.