Responsible Business Insights

From Compliance to Nature Recovery: The Biodiversity Net Gain Strategy for NHS Greater Manchester

Responsible Business was commissioned by NHS Greater Manchester to produce a clear, practical and policy-aligned Biodiversity Net Gain strategy for estates teams across all Greater Manchester NHS Trusts. The aim was to turn a complex, fast-moving compliance requirement into a usable playbook that helps project teams make decisions early, reduce programme risk and avoid last-minute cost escalation at planning stage.

The strategy sets out Greater Manchester Integrated Care Partnership expectations for applying mandatory Biodiversity Net Gain to new development across the NHS estate, with direct alignment to the Environment Act 2021 and the planning framework that now underpins net gain delivery in England. It explains what schemes must achieve, how long outcomes must be secured and what evidence is needed to satisfy planning conditions and legal agreements.

A central feature of the work is the shift from compliance as a tick-box to compliance as good project management. The strategy embeds Biodiversity Net Gain from feasibility through to long-term use, showing how requirements should be addressed progressively through the RIBA Plan of Work. This includes when to commission baseline surveys, when to refine the statutory metric, when to prepare the Biodiversity Gain Plan and when the thirty-year management period begins in practice. The intent is simple: treat biodiversity as a design input, not a late-stage add-on.

Responsible Business also translated the technical mechanics into plain, decision-ready guidance. The strategy explains how the statutory biodiversity metric converts habitat type and condition into measurable units, and how adjustment factors can materially change cost and deliverability. It clarifies why distance from the development matters, how spatial risk uplifts work across local authority boundaries and National Character Areas, and why early selection of local offset options is usually the most efficient route.

To prevent avoidable mistakes, the strategy includes a robust approach to selecting competent ecological expertise. It provides a checklist that reflects professional expectations, practical competence and commercial realism, so estates teams can procure the right support and keep continuity through design, planning, delivery and monitoring.

Where on-site delivery is constrained, Responsible Business set out a cost-effective approach to off-site units. The strategy encourages sourcing units directly from credible habitat providers, checking legal security and governance, comparing like-for-like pricing and using agents only where necessary because fees can increase costs materially. It also provides guidance on how to choose habitat banks in a way that protects the project and strengthens long-term compliance.

Crucially, the strategy positions the NHS as more than a buyer in a private market. It explains how NHS-owned green space can be assessed for registration as biodiversity gain sites, enabling a long-term, cost-controlled supply of units for future developments while improving the quality of green space around healthcare settings and supporting staff wellbeing and patient experience.

The finished output is an internal guide designed for real-world delivery: legally literate, commercially aware and rooted in Greater Manchester’s nature recovery priorities, including alignment with the Greater Manchester Local Nature Recovery Strategy and wider regional plans.

This work was informed by guidance and standards published by GOV.UK, Defra, Natural England, NHS England Greener NHS, the Planning Advisory Service hosted by the Local Government Association, the Chartered Institute of Ecology and Environmental Management and the Greater Manchester Combined Authority.