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Scottish Biodiversity Metric Consultation

Scottish Biodiversity Metric Consultation

Josh Woollard & Katherine Bannister 23 Oct 2026
The current version of Scotland’s National Planning Framework (NPF4) sought to reshape the planning system to allow climate change and nature recovery to be considered in all plans and decisions, supporting development that benefits biodiversity. Policy 3 sets out that all national or major developments, or those subject to an Environmental Impact Assessment (EIA), will only be supported where it can be demonstrated that significant biodiversity enhancements are provided in the proposal.
The absence of an established Scottish quantitative approach to assessment of biodiversity value has resulted in the use of an array of methods to calculate biodiversity enhancement (also referred to here as Biodiversity Net Gain (BNG)), including variations of the English statutory biodiversity metric. This has created discrepancies in BNG calculations, causing confusion and inconsistency within the planning system.
To address this, NatureScot announced a public consultation on the introduction of a Scottish Planning Biodiversity Metric (SPBM), starting on 31st August 2026 and ending on 30th November 2026. The SPBM draws upon the English statutory biodiversity metric, adapting it to better complement Scottish Policy and the diverse range of environments and landscapes it encompasses, and seeks to provide a consistent and transparent approach to calculating changes in biodiversity at a project level, in terms of habitat loss, compensation and enhancement in the Scottish system.

Key differences between the Scottish and English approaches

There are a number of differences between the two approaches to measuring and compensating for impacts to biodiversity, and we have highlighted some of these below.
Policy-Led vs Legislative

Whereas the English Government brought in a legal requirement for certain developments to deliver at least 10% BNG, the Scottish planning system has adopted a policy-led approach requiring certain developments to deliver “significant biodiversity enhancements” without requiring a specific numerical uplift. This allows for a more qualitative consideration of biodiversity and the SBPM includes a sheet which allows a user to add biodiversity measures, such as homes for bees, bats, bugs etc. Crucially, the SBPM doesn’t assign a value to these measures, but it does highlight a more holistic approach to delivering BNG, rather than “simply becoming ‘a numbers game’” as the User Guide suggests.
Spatial Risk

Both the English and proposed Scottish systems have introduced a mitigation hierarchy for biodiversity. These are broadly similar as they seek to:
 
  1. Avoid impact in the first place;

  2. Minimise impact;

  3. Restore or enhance on-site habitats; and

  4. Offset impacts through compensatory provision with a preference for on-site delivery over off-site delivery.

To further reinforce on-site delivery, both the proposed Scottish and English approaches apply a spatial risk multiplier.
In Scotland, the multiplier effect results in 1 Biodiversity Unit (BU) off-site being worth 0.9 BUs. The same multiplier is applied regardless of the distance from the site.
In England, the negative effect of the risk multiplier increase with distance from the development site. There is no negative impact for off-site delivery within the same Local Planning Authority (LPA) area or National Character Area (NCA). Within a neighbouring LPA or NCA, 1 BU becomes worth 0.75 BUs as compensation value. Beyond the neighbouring LPA or NCA, 1 BU is only worth 0.5 BUs as offsite compensation.[1]

Lessons learnt from the English system

Mandatory BNG has been in force in England since February 2024. Whilst there has undoubtably been a bedding-in period for the industry as understanding and training progresses, the challenges of implementing the new system are easing.
When to consider BNG?

There is no flexibility in England to factor in viability when meeting the BNG Requirement; delivering 10% BNG is a legislative requirement and cannot be reduced in any way.
It has become increasingly important to consider biodiversity at the outset, both in terms of site selection and the design process. The extent of high value habitats on site could significantly impact on developable area, particularly if the cost of mitigation, either on-site or off-site, is prohibitive.
Development of a wider BNG ecosystem

In the early period, the wider system (comprising the private market, Government guidance etc.) which now supports the implementation of mandatory BNG was in its infancy. In many cases, this caused significant delays to the planning process.
Now however, there is a functioning market for the sale of offsite BUs which facilitate developments that cannot deliver 10% BNG on-site. Many LPAs have published guidance and template legal agreements, and the Government are working to improve exemptions for England, streamline the Metric, increase flexibility for minor developments, and target specific issues such as open mosaic habitat on brownfield sites.

What opportunities does the Scottish BNG Metric present?

The main driver for, and key benefit of, the SBPM is to bring consistency to the measurement of biodiversity value in Scotland to support the delivery of NPF4, with the hope that it will improve outcomes for biodiversity improvements in Scotland.
The introduction of the SBPM also presents an opportunity for landowners, local authorities, and developers within Scotland to create their own habitat banks from which BUs can be traded. Unlike England, the Scottish spatial risk multiplier is not distance-dependent. It is logical therefore to assume the catchment within which a Scottish BU bank could serve would be wider as customers would not incur additional negative penalties.  

Questions to be answered

How will BNG be secured on a planning permission?

Through a legislative approach to delivering BNG, the English system imposes a standard planning condition to all relevant planning permissions securing mandatory BNG. With the policy-led approach in Scotland, the consultation does not consider how BNG could be secured. Whilst the SBPM will reduce inconsistency in one part of  the planning system, inconsistencies could remain around securing the delivery of biodiversity enhancements. Clarification on this would likely be welcomed.
Will a Biodiversity Gain Site Register be created?

A Biodiversity Gain Site Register, managed by Natural England, records all Biodiversity Gain sites where offsite biodiversity enhancements are planned or delivered in England. The Register, use of which is mandatory, is a key part of the BNG system in England and supports the functioning of the private market. The Scottish consultation does not indicate whether it is intended for a similar a Register to be created to enable a similar “market” for BUs in Scotland. This risks delays to the planning system if off-site BUs are not available to mitigate impacts of new developments.
 

How can Lichfields assist?

Lichfields are well versed in the implementation of mandatory BNG in England and are well placed to apply this knowledge to assist clients in drafting representations to the ongoing Scottish consultation.

 

Footnotes
 
[1] It is worth noting that the English Government are intending to move away from LPA/NCA boundaries and towards Local Nature Recovery Strategy areas which, in the main, cover much larger areas.

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Harvey Nichols and the Changing Face of Leeds City Centre
When I arrived in Leeds as a student in 2005, the city of Leeds was riding high on its reputation as one of the North’s great shopping destinations. Leeds was regularly described as the “Knightsbridge of the North”, a place where ambitious retail developments, luxury brands and new department stores helped define the city’s identity.
Shopping was a major part of what made Leeds feel different from other cities. The city had a confidence about it, with a retail offer that could compete with much larger destinations. Harvey Nichols, which had opened on Briggate in 1996, was an important part of that story: a statement of intent that Leeds belonged on the map of luxury retail.
Nearly two decades later, the news that the Harvey Nichols moniker will no longer feature over the shop door feels like the end of an era. Following its acquisition by Frasers Group in August 2026, the company has confirmed plans to convert the Leeds store into a Flannels. The building may continue to trade as a luxury fashion destination, but the Harvey Nichols brand, and everything associated with it — is set to disappear.

Harvey Nichols

For many, that will be a genuine loss. Yet, to understand what it means for Leeds, we need to look beyond one retailer and consider how dramatically the city centre has changed since I first arrived.
 
 

From the Knightsbridge of the North to a new retail landscape

 

The years around my arrival in Leeds were a period of considerable optimism for the city’s retail sector. New developments promised to strengthen its position as a regional shopping powerhouse, bringing fresh investment, more choice and a more modern shopping experience, even in the face of new, out-of-centre competition from the White Rose Shopping centre.
The opening of Trinity Leeds in 2013 was a major moment. Its arrival brought together shopping, restaurants and leisure in a prominent city-centre location, creating a new focal point for visitors. The development helped reinforce Leeds’ reputation as a place to shop, eat and spend time, rather than simply a destination for ticking items off a shopping list.
Meanwhile, the transformation of the Victoria Quarter into part of the wider Victoria Leeds offer, alongside the arrival of John Lewis at Victoria Gate in 2016, added another dimension to the city’s retail identity. The combination of historic architecture, luxury brands and a major department store gave Leeds a distinctive proposition.
At the time, it was easy to see these developments as evidence that the city’s retail future was secure. New shopping destinations were opening, major brands were investing, and Leeds seemed well placed to attract shoppers from across Yorkshire and beyond.
But retail is not a static industry. The very developments that helped Leeds flourish were being built during a period when the way people shop was beginning to change. Online retail was growing, consumer habits were evolving, and the traditional department-store model was coming under increasing pressure.
The changes that followed would challenge some of the assumptions on which that earlier confidence had been built.

The changing geography of Leeds shopping

 

One of the most interesting developments since 2005 has been the gradual shift in the centre of gravity for shopping.
When I first arrived, Briggate and the surrounding streets were central to the city's retail identity. Harvey Nichols was a major attraction, while the established shopping streets and department stores helped define the experience of visiting Leeds.
The subsequent development of Trinity and Victoria Gate helped draw attention eastwards, particularly towards the John Lewis store at Victoria Gate, which opened in 2016.

Trinity Leeds Shopping Centre

This was more than a change in the location of individual shops. It altered the way people moved through the city centre and where they chose to spend their time.
Newer developments offered modern retail environments, a carefully curated mix of brands and, in some cases, a more integrated food and leisure experience. As these destinations became established, older shopping areas faced the challenge of remaining relevant in a more competitive market.
John Lewis has become especially significant in this story. With the loss of traditional department-store names elsewhere, it will soon become the last remaining major department store in Leeds city centre. Its presence at Victoria Gate is a reminder of the city's continuing appeal as a regional retail destination, even as the wider department-store model comes under pressure.
But it also raises an important question: what happens when a city becomes increasingly reliant on a small number of major retail anchors?
The fortunes of those individual stores can have an outsized influence on the surrounding streets and businesses. A successful anchor can attract visitors and support neighbouring retailers, while its decline can leave a substantial gap in the local economy.

Evolution to re-calibration?

 

In September 2026, Leeds City Council reported that the vacancy rate across the city’s main retail area had fallen to 8.8% — its lowest level since records began in 2019. The council also reported more than 45 million pedestrian movements across eight key city-centre locations during the year to that point. These figures suggest that, despite the challenges facing traditional retail and the changing mix of occupiers, Leeds continues to attract significant footfall and demonstrates encouraging signs of resilience. A number of developments across Leeds city centre provide an insight into how its retail landscape is evolving in this context.
One of the most recent examples is the demolition of The Core Shopping Centre. Opened in 1987 as the Headrow Shopping Centre, it was once an important part of Leeds’ evolving retail offer. However, over time, it struggled to maintain its position alongside newer developments and changing consumer habits, eventually becoming largely vacant in its final years.

 

Garnet Exchange development site

Its redevelopment as the Garnet Exchange reflects a different vision for the city centre. Rather than simply replacing one shopping destination with another, the scheme signals a shift towards mixed-use development, combining commercial space with residential accommodation. Plans include ground-floor commercial units alongside hundreds of student flats above.
In effect, a building once designed primarily to accommodate shoppers is being reimagined as a place where people can live, work and spend money. This reflects a broader recognition that successful city centres need to offer more than retail alone.
Elsewhere, other developments highlight the opportunities and challenges facing Leeds’ retail offer.
Leeds Kirkgate Market remains an important city-centre destination, drawing visitors through its mix of independent traders, fresh produce and specialist retailers. The introduction of a casual food and drink offer has also helped broaden its appeal, creating a more flexible space for emerging businesses and new concepts. However, like many traditional markets, it continues to face pressures from rising operating costs and the changing economics of independent retail.
Leeds Corn Exchange demonstrates the potential of repurposing historic buildings to create distinctive retail destinations. Its architectural character and independent retail offer provide something different from the conventional shopping centre experience and undoubtedly provides a draw to visitors. Yet its occupancy has fluctuated over time, underlining the challenge of sustaining a specialist retail destination in an increasingly competitive market.

Leeds Corn Exchange

 

The Light, on The Headrow, provides another example of how a city-centre development can evolve. While retail remains part of its offer, leisure has become increasingly prominent, with restaurants, bars, a gym and a cinema helping to attract visitors beyond traditional shopping hours. Its evolution illustrates the growing importance of food, drink and recreation in encouraging people to spend time in the city centre.
The changing use of buildings is not limited to retail and leisure. The former Majestyk nightclub, close to Leeds railway station, has been transformed into high-quality office space. Although not a retail redevelopment, it highlights the wider transition taking place across the city, as buildings find new purposes in response to changing demand.
Taken together, these examples demonstrate how Leeds continues to adapt to new patterns of working, shopping and entertainment. Some buildings are being repurposed, others are diversifying their offer, and some are moving away from retail altogether. The common thread is the need to respond to how people want to use the city today, rather than relying on models that may no longer be sustainable.
Ultimately, the future of a successful city centre does not depend on preserving every former shopping centre or filling every vacant unit with another retailer. Harvey Nichols will no doubt be missed in Leeds but retail will undoubtedly remain an important part of the city’s evolving identity and economy.
A more sustainable future is likely to lie in a broader mix of uses, where shopping sits alongside residential, office, leisure, hospitality and cultural activities. By bringing more people into the city for different reasons and at different times of the day, Leeds has the opportunity to create a city centre that is not only commercially resilient but also more vibrant, accessible and appealing.

 

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Great British Grid and the Challenge of Rewiring Britain
The electricity grid is at the centre of the national economic debate. At the Labour Party Conference on 29 September, Andy Burnham identified high energy costs and grid connection delays as barriers to growth. He announced Great British Grid, a publicly owned body within Great British Energy, intended to invest alongside the private sector, increase competition and accelerate delivery. [1]
Less than three weeks earlier, the National Audit Office (NAO) had published Upgrading the electricity transmission network, examining whether the network can expand quickly enough to support Clean Power 2030, rising demand and economic growth. [2]
Together, they describe the same national challenge. Britain has made remarkable progress in renewable generation. The next phase requires networks, connections, storage and wider infrastructure to be delivered at a comparable pace as part of a coordinated infrastructure programme.
 
 

From diagnosis to delivery

 

Britain’s electricity geography has been redrawn. In 2000, generation was concentrated around a relatively small number of large power stations. In 2026, offshore wind, solar and other sources are distributed much more widely across the country (Figure 1). At the same time, electrification is expected to increase demand from homes, transport and industry.
Built largely between the 1950s and 1970s for a more centralised system, the transmission network must now carry growing volumes over longer distances and in different directions. Ofgem estimates that up to £70 billion may be required to upgrade and maintain the network by March 2031.
 

 

Figure 1: Renewable energy projects in the UK - operational or under construction

Source: DESNZ Renewable Energy Planning Database

NESO identified 80 transmission projects as necessary for Clean Power 2030. By March 2026, 12 had been completed and 12 had been absorbed into newer projects, leaving 56 ongoing. Only 17 of those were in construction; the remaining 39 were still at earlier stages of development, planning and consenting. NESO also identified eight additional projects whose acceleration could further reduce constraint costs. [2]
The NAO found that most projects were forecast to complete later than the date NESO originally considered optimal, with four expected after 2030. It concluded that delivering the required programme by 2030 will be very challenging.
 
 

Why pace matters

 

When the network cannot transport electricity from where it is generated to where it is needed, NESO must intervene to keep the system secure. This can mean paying generators in constrained areas to reduce output and asking other generators closer to demand to increase theirs. This clearly is a highly inefficient way of managing our energy network and certainly not a sustainable long term solution.
Thermal constraint costs rose from £0.6 billion in 2018/19 to £1.9 billion in 2025/26. The NAO reports that they could reach up to £7.8 billion in 2030 if network upgrades do not keep pace with new generation. NESO’s estimate for 2030 rises to as much as £12.7 billion in a scenario without any further network upgrades. [3]
The issue is not that Britain has developed too much low carbon generation. Far from it. It is that network capacity has not expanded at the same pace. Closing that gap would enable more clean electricity to reach consumers and reduce the cost of managing congestion.
 
 

What Great British Grid could change

 

Great British Grid is intended to add public capital and delivery capacity. Network operators retain their roles, Ofgem remains the regulator and NESO the system operator and planner. The new body will be able to co-invest and compete for transmission projects as competitive tendering expands. [4]
The government also intends to widen self-build connections, allowing developers and businesses to construct their own where appropriate. If designed well, this could help projects constrained by connection lead times. At Lichfields, we see a number of our energy developer clients considering options that incorporate self-build primary substations into their generation schemes.
For planning, a new delivery body does not remove the need for land, consents or environmental assessment. Self-build infrastructure may still require permission, land rights and environmental evidence. Clear strategic direction will be essential if competition is to accelerate projects rather than fragment them.
The announcement is therefore best understood as an additional delivery mechanism. Its impact will depend on its remit, funding, access to skills and the quality of coordination with the organisations already responsible for the system.
 
 

Planning remains a critical dependency

 

The NAO gave its most serious red risk rating to planning and consenting and to connections reform. It noted that nationally significant infrastructure projects (NSIP) can take more than four years to gain consent, with similar timescales in Scotland. Compulsory land rights can add between 18 months and three years. [2]
New overhead lines, substations and associated works can have landscape, ecological and community effects. Speed cannot mean treating those impacts as incidental. Nor does a prolonged and unpredictable process necessarily produce better outcomes.
The Planning and Infrastructure Act 2025 has removed the statutory pre-application consultation duties for NSIPs, although applicants must still have regard to government guidance, and proportionate engagement will remain important to effective project development. The government has also confirmed its intention to increase the distance threshold at which qualifying overhead lines enter the development consent order regime and route more projects through the Electricity Act process, although implementing legislation is still required. These changes may reduce process time, but legislation alone will not deliver the programme.
Projects need a clear strategic case, mature routeing, a credible land strategy and coordinated environmental evidence. Decision makers need the people and expertise to assess them. Communities need a clear account of why infrastructure is required, the alternatives and how local impacts will be reduced.
Andy Burnham’s proposed stronger role for mayors and local leaders could connect national energy planning with place-based priorities. The test will be whether it produces earlier alignment on routes, investment and community benefit, rather than another decision-making layer.
 
 

Networks are not the only answer

 

Transmission reinforcement is indispensable, but the most efficient system will use several tools. Suitably located storage systems can absorb electricity and discharge it later, provide rapid flexibility and stability services, and help make better use of existing network capacity. Longer duration storage, interconnection, demand response and smarter operation also have important roles.
These technologies are complements, not substitutes. Planning and connections policy should enable each to contribute where it offers greatest system value.
This is also where decentralisation matters. A future system will combine large scale generation and transmission with more locally distributed generation, storage and flexible demand. The government’s Local Power Plan, which supports local and community energy projects, reflects that direction. [5] Good spatial planning will need to consider how national and local infrastructure interact.
 
 

A strategic plan and a national effort

 

The NAO identifies the absence of an agreed spatial plan as a weakness in earlier investment decisions. The Strategic Spatial Energy Plan, expected in 2027, is intended to set out the broad location and timing of generation, storage and demand. A Centralised Strategic Network Plan will then identify the transmission investment required to support it.
These should explain what is needed, where and how projects fit together - improving investment decisions and allowing project-level consenting to focus on routeing, design, alternatives, cumulative effects and mitigation.
Skills were the most frequently reported significant project risk in the NAO’s sample, followed by supply chain constraints, planning and access to the live system. Britain is competing internationally for engineers, planners, equipment and construction capacity.
The energy transition was always going to require something close to a wartime mobilisation of capital, skills, planning and industrial capacity. The welcome change is that grid delivery is now being treated as a mainstream economic priority.
The prize remains substantial: greater energy security, reduced exposure to volatile international gas prices, lower system costs, skilled jobs and investment across the country, and the infrastructure needed to meet the UK’s climate commitments. Britain has abundant renewable resources and an established energy sector. Great British Grid, connections reform and strategic energy planning offer the ingredients of a stronger delivery model.
The next task is to make those parts work together - and to sustain the effort well beyond a single political announcement and a single Parliament.
 
Footnotes

 

[1] The Labour Party Andy Burnham’s speech to Labour Party Conference 2026, 29 September 2026

[2] National Audit Office Upgrading the electricity transmission network, 11 September 2026

[3] National Energy System Operator 2025 Annual Balancing Costs Report

[4] Department for Energy Security and Net Zero and Great British Energy Great British Grid to speed up connections and cut bills, 29 September 2026

[5] Department for Energy Security and Net Zero and Great British Energy Local Power Plan, Updated 18 February 2026

[6] HM Government Clean Power 2030 Action Plan

 

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Reflections from Scotland’s EIA Conference 2026

Reflections from Scotland’s EIA Conference 2026

Arabella Stewart-Leslie 16 Oct 2026
Lichfields was proud to sponsor and present at Scotland’s EIA Conference 2026, which brought together practitioners, regulators, and industry leaders to discuss the future of Environmental Impact Assessment (EIA).
The conference was attended by colleagues from across Lichfields, including Gayle Black, Neil Purvis, Heather Overhead and Dan Evans. Drawing on their collective insights and discussions throughout the day, this blog reflects on the key themes that will shape EIA practice in the future.

The key themes of the conference were ‘Innovation’, ‘Impact’ and ‘Insight’. Discussions covered topics including the importance of defining "the project" in EIA, reflections on the implications of the Raeshaw court ruling, and the topic of the moment: data centres and EIA.


Defining the project 


Brodies explored the legal and practical importance of defining "the project" within the EIA process, following the February 2026 Raeshaw court ruling. One of their key messages was that defining the project has always been a fundamental principle of good EIA practice, forming the basis on which environmental effects are identified, assessed and reported. It is not a new requirement. 

The speakers highlighted that the principles in the Raeshaw decision are long-established but have prompted practitioners, regulators and decision-makers to strengthen how projects are described and presented within EIA documentation. The discussion served as a timely reminder that defining the project underpins the entire assessment, ensuring that decision-makers have a clear understanding of what is being proposed. 


Handling uncertainty and proportionate assessments

Another interesting discussion focused on how EIA practitioners deal with uncertainty in a proportionate way. The session highlighted that dealing with uncertainty is an inherent part of the EIA process and one that practitioners must address through professional judgement.
A proportionate approach can be taken that focuses on likely significant effects and provides decision-makers with the information they need to reach an informed conclusion. By exercising professional judgement, long and complex assessments are not necessary. 
The discussion also touched on why the Raeshaw decision has attracted so much attention across the profession. The case highlights the need to assess aspects of a development where there may not yet be complete certainty, such as the delivery of a grid connection or other associated infrastructure. Such uncertainties are quite normal and the expectation remains that any likely significant environmental effects are identified and assessed in a proportionate manner. 
 

Assessment guidance and best practice

A further key theme of the conference was the importance of maintaining best practice in EIA assessment. The afternoon session focused on forthcoming guidance from the Institute of Sustainability and Environmental Professionals (ISEP) on interaction effects and cumulative effects. A commonly agreed and replicable approach to assessing these effects would be welcomed across the profession.
Additional guidance is also expected from ISEP next year on Climate Change Resilience and Adaptation for professionals coordinating EIA’s or supporting assessments. As the impacts of climate change are increasingly felt in our daily lives, this new guidance is especially timely and will also help to ensure consistency and best practice is maintained in EIA. 
 

EIA for Data Centres

Lichfields and Pulsant presented the final session of the day, exploring the growing role of data centres as critical infrastructure. Pulsant explained what data centres are and noted that, although they have recently attracted significant attention, smaller-scale facilities are already well established across the UK. Often located in business or industrial areas, these facilities form a critical part of the country's digital infrastructure. However, growing demand for cloud computing, artificial intelligence and data storage is driving the development of increasingly large "hyperscale" data centres. This rapid expansion requires planners, environmental practitioners and decision-makers to develop their understanding of the sector's environmental effects and technical requirements.
Lichfields discussed the implications of the Scottish Government's Direction of 17 September 2026, which requires data centre developments exceeding 50MW to be treated as EIA development. Developers may need to engage a broader technical team earlier in the EIA scoping process to agree the environmental topics requiring detailed assessment in the EIA Report. These may include landscape and visual impacts, transport, ecology, noise, carbon emissions, air quality and socio-economics. Early collaboration between planning, environmental and technical specialists will help identify potential effects from the outset and support efficient progress through an increasingly complex consenting environment.
 

Concluding thoughts

Scotland’s EIA Conference 2026 highlighted a profession that continues to adapt to an increasingly complex environmental and regulatory landscape. There was a clear sense of optimism about the role EIA can play in supporting sustainable development even if challenges remain around climate change, uncertainty and the delivery of proportionate assessments.
The shared commitment across the sector to improving the quality, accessibility and effectiveness of environmental assessment was particularly encouraging.  EIA remains a vital tool in ensuring that environmental considerations are embedded in decision-making and development outcomes.
If you would like more information, the slide decks from the conference can be viewed here.
 

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