LNRS & Strategic Significance Multiplier Transition

Defra provided guidance to support local planning authorities (LPAs) in the transition to publication of a Local Nature Recovery Strategy (LNRS) in their area in November 2024. 

Prior to the publication of the LNRS, LPAs should publicly communicate which strategy or plan is to be used to determine the strategic significance multiplier in the metric for baseline and post-development habitats.

LPAs should also publicly communicate proposed LNRS consultation draft and publication dates so applicants are prepared for any metric reassessments of the strategic significance multiplier for live applications or for discharge of the pre-commencement condition.

Pre-development baseline values submitted prior to the published LNRS should remain unchanged. If the LNRS is published during a live application or prior to discharge of the pre-commencement condition, then the initial post-development value may need to be updated 

The statutory biodiversity metric tool includes a strategic significance (SS) multiplier to incentivise targeted habitat creation and enhancement in areas identified as “mapped measures”, within a local nature recovery strategy (LNRS). 

There are implications as to how the SS multiplier is applied within the metric to baseline and post intervention on and off-site biodiversity habitats before and after the publication of a LNRS and for live applications within the planning portal at the time a LNRS is formally published. 

Prior to the publication of an LNRS, LPAs should be clearly referencing which strategies and plans are to be used to inform the value applied to the strategic significance multiplier for baseline and post development habitats. Further information on LNRS is detailed in the LNRS guidance.

Local Planning Authorities should consider:

• Build in flexibility within the legal agreements that secure the post development biodiversity unit values delivered on and off-site as calculated by the metric (before an LNRS is published) as the SS multiplier has the potential to change the biodiversity unit value, and clauses should be put in place to account for arising variations.
• Ahead of publication of a draft LNRS publicly communicate which strategy or plan is to be used to determine the strategic significance multiplier for baseline and post development habitats.
• Publicly communicate proposed LNRS consultation draft and publication dates. Clearly communicate the implications for applicants so that they are prepared for any reassessments of the SS multiplier that might be required when the application is live, or to discharge pre-commencement biodiversity gain condition.
• Decide whether or how to use the information in a LNRS consultation draft to inform SS multipliers in the transition period to formal publication.
• On publication of LNRS, contact applicants of all non-exempt live planning applications, to make them aware of the need to reassess the SS multiplier for post-development biodiversity metric values.

If an LNRS has already been published, then new, non-exempt applications submitted following publication must:

• Mark the strategic significance multiplier as ‘Low’ for all on and off-site baseline habitats.
• Mark the significance multiplier as ‘High’ for post-development habitats that meet the criteria within Table 7, page 28 of the Biodiversity Metric User Guide (habitats are to be marked 'Low' if they do not meet the criteria).  

The ‘Medium’ multiplier category is not to be used if there is a published LNRS.

Schedule 7A (part 1, paragraph 5) of the Town and Country Planning Act (1990) (TCPA) defines a site’s pre-development biodiversity value as the biodiversity value of the onsite habitat on the ‘relevant date’ – this in the case of planning permission, which is granted on application, will usually be the date of application. 

Although, habitat surveys from earlier than the date of application can be utilised, if the biodiversity value has not changed. As such, if an LNRS is published after the ‘relevant date’, the pre-development biodiversity value of a site can not to be re-assessed, given that the value is date stamped on the ‘relevant date’. 

For example, a planning application is submitted on the 21st of September 2024, and there is no published LNRS for the strategy area on the date the application is submitted. The pre-development biodiversity unit metric value has been calculated using the statutory metric details on page 27 and 29 and within Table 8 of the user guide (Figure 1) are followed to assign the appropriate strategic significance multiplier. If the LNRS for the strategy area is published after the date the application is submitted, the baseline biodiversity unit value remains unchanged as it relates to the ‘relevant date’ when it was calculated i.e. the 21st of September or the date of the habitat survey.

For baselines already secured through a legal obligation, Defra anticipates these agreements will likely contain clauses that will set out what happens for such cases. The note highlights pages 27, 28 and Table 8 of the Statutory Biodiversity Metric User Guide and states that guidance within these parts should still be followed if the LPA has not published an LNRS to date.  

This additional guidance provides further clarification on other stages of the planning process and what LPAs should consider when securing existing or future mandatory BNG. Once an LNRS is published, proposals which match those identified in the LNRS mapped measures will receive the unit uplift from the SS multiplier. This is to incentivise sites in delivering the best measures for local nature recovery. 

Schedule 7A (part 1, paragraph 8), of the TCPA defines the post-development biodiversity value of a site’s onsite habitat as the projected value of the onsite habitat as at the time the development is completed. If the publication of an LNRS while a planning application is live alters the SS multiplier value in the initial post-development metric calculation, the SS multiplier to be updated in the metric calculations to reflect the site’s overall new post-development biodiversity value. 

Where an LNRS is published after grant of planning permission and before the submission of the Biodiversity Gain Plan to discharge the pre-commencement condition. The calculations for the site’s post-development biodiversity value are to be reassessed using the correct SS multiplier for the on and off-site biodiversity units reflected by measures identified in the areas LNRS.

For example, consider a development which submitted a planning application on the 21st of September 2024, in a strategy area with no published LNRS on the submission date, and planning permission is granted on 11th December 2024. The applicant is about to submit their Biodiversity Gain Plan to discharge the pre-commencement statutory biodiversity gain condition on 27th February 2025 and the LNRS for the strategy area was published on 2nd February 2025. 

The submitted Biodiversity Gain Plan, if prepared before the LNRS was published will need to update the post-development biodiversity metric unit value to reflect any change in the SS significance multiplier of both proposed post-development on and off-site habitats. This is to capture whether the proposed habitat interventions are consistent with mapped measured identified within the published LNRS. An updated metric calculation tool is also to be submitted. Where details of the post-development biodiversity unit values have been secured at the application stage through legal agreement, we anticipate these agreements are likely to contain clauses that set out what happens in such cases.

This guidance on LNRS and Strategic Significance multiplier transition is from November 2024. It has been reviewed by the Defra Legal Team and has substantial weight.

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