Defra has issued guidance to to clarify how the process of submitting a planning application should work in regards to biodiversity net gain and the introduction of a Local Nature Recovery Strategy (LNRS).

It primarily tackles the question of what happens when a LNRS is introduced during the process of submitting applications, especially after a planning application is accepted but before the Biodiversity Gain Plain is submitted and how much it retrospectively affects the former and the writing of the latter.

The introduction of a LNRS after the application was first submitted would not affect pre-development biodiversity values so long as they were accurate when the planning application was first submitted.

Defra says that if a local nature recovery strategy (LNRS) is published before a biodiversity gain plan is submitted, then the post-development strategic significance multiplier should be re-evaluated.  

Currently, without an LNRS in place, working out the multiplier for post-development relies on any previous documentation that suggests the site in question is ecologically important for it to receive a high multiplier. 

The guidance states that if a LNRS is not in place then a planning authority should specify documents to help assign strategic significance and argue for a high multiplier. 

Examples of the kinds of documents this could include are: Draft Local Nature Recovery Strategies, Local and Neighbourhood Plans and Biodiversity Action Plans among others. 

If a planning authority has not recommended any documents, then a high multiplier cannot be achieved. A case will have to be made to achieve a medium rating, through arguing how a habitat is ecologically important within a specific location and and how it could ecologically link to other significant areas. 

If this is unable to be done, then a development will receive a low multiplier. 

Now, even were there to be a LNRS published after planning permission is granted, but before the biodiversity gain plan is submitted, then the post-development assessments will have to be evaluated with the LNRS in mind.

A high multiplier, in this instance, can be applied when the proposed interventions are consistently in line with the priorities of the LNRS, if this cannot be achieved then a low multiplier will be received.