Project Summary

High Fen Wildland (High Fen) is a 292-hectare grassland site located in the Norfolk Fens in the east of England. The site is managed by Nattergal, which took ownership in 2022. Previously, the site was an arable and daffodil farm with limited food production value due to the complex hydrology, before being bought and converted to grassland by the previous owner with support from Natural England. Nattergal’s aim for High Fen is to fully rewild the site through the restoration of its near-natural hydrology and the improvement of species abundance, communities and diversity.  

High Fen is demonstrating how Biodiversity Net Gain (BNG) and the Peatland Code (PC) can be used in tandem to support these goals, with plans to generate up to 60,000 carbon units through the Peatland  Code and 550+ BNG units, spatially allocated across the site. High Fen is unique due to its hydrological isolation and potential for restoration of a broad range of habitats, including calcareous grasslands, lowland fen, peripheral scrub, willow carr, wetlands and reedbeds.  

Milestone 1: Initial Project Scoping

Often the initial task is to understand the site(s) you want to use and the land use change needed for nature restoration or creation. This includes considering the goals of the land managers involved, the vision within the wider catchment or neighbouring area, and whether there are permits or planning consent needed for any proposed changes.

At this stage, you can also conduct a high-level assessment to determine which revenue streams can be generated from ecosystem services , e.g. carbon credits, flood reduction cost savings, or biodiversity units, which will be crucial for identifying buyer interest.

Finally, it is useful to have an idea of the costs of the project and potential grant funding that may be available to support initial development.

Milestone 2: Identify and Work with Sellers

Initial ownership of the ecosystem services will belong to the landowners or, in some cases, the tenants of the sites that the project is using. However, these can be passed onto others, such as third-party project developers, with appropriate legal arrangements and compensation. In some cases, there may be a sole seller of the ecosystem services, where the site or landholding is large enough that it delivers the volume of ecosystem services needed to cover the costs of the project and attract buyers.

However, in order to achieve scale and impact, a project will likely involve multiple sellers, such as neighbouring farmers and estate managers. Scale of land is often needed to deliver significant environmental outcomes, and also to attract private finance.

Where they are not the land managers in question, project developers must plan how they initially contact and engage with these sellers going forward, building their wants and needs into the project.

Milestone 3: Baseline and Estimate Ecosystem Services

At this point, you will have understood the vision for the project and identified a particular ecosystem service or set of services to be sold. The next step will be to carry out detailed analysis – baselining each ecosystem service and quantifying what will be able to be delivered from the interventions, as well as planning how to monitor and maintain these interventions. You will need to rely heavily on ecological expertise for this more scientific Milestone.

At this step, standards, verification and accreditation methods will be considered in more depth.

Milestone 4: Identify and Work with Buyers

Based on your earlier market analysis in initial project scoping, you will have identified one or more groups of beneficiaries who may be willing to ‘buy’ or pay for the ecosystem service(s) to be created, restored or maintained. Buyers vary – as do their requirements – but at this step, greater buyer engagement is now needed to develop a deal that channels money towards the nature-positive outcomes that your project wants to deliver.

 

 

Milestone 5: Develop Business Case and Financial Model

You’ll have started building your business case and financial model in earlier steps – laying out your project’s vision, the market proposition and estimating costs and income. This step offers a review, in addition to providing details needed to build out the financial model and business case more fully. Both of these key documents will be iterated throughout project development, and will likely be altered during project delivery as new information emerges. These documents are interlinked and, if developed correctly, will ensure your project’s viability and help you with discussions with stakeholders – including sellers, buyers and future investors.

The financial model will also enable you to better understand the type of structure your project may take to attract investment (i.e.a loan, an equity investment, a bond) and what sort of returns you can afford to pay/offer.

Milestone 6: Develop a Governance Structure

A governance structure will inform the way in which the project is run when fully operational and for what purpose. It identifies appropriate decision making processes, who is responsible for what actions, and what controls are in place to make sure that the project is meeting its stated goals, all while abiding by the risk appetite of its engaged stakeholders. The legal entity to host the project will be a key driver in this, and the appropriate choice of entity will be dependent on several factors that are outlined below.

Your governance structure should align with and underpin your business case, as a necessary component of how the project will deliver its environmental outcomes and other strategic targets.

Milestone 7: Identify and Work with Investors

It is important to note that not all projects will need up-front investment, but for those that do, this section provides a framework for thinking around the development of the investment model. This does not constitute financial advice – as the GFI is not licensed to do so. However these considerations are based on the insight offered by project developers and other market stakeholders.

An investor will be a new core stakeholder in your project, and it’s just as important to think of what you require from investors, as much as what they require from you – so that you can build a positive and collaborative relationship with them.

This entails defining the investment ask (in line with the financial model), the strategy for approaching the right investors, and the negotiation of terms that can then be formalised in contract development (Milestone 8).

 

Milestone 8: Establish Legal Contracts and Closing

When all relevant stakeholders have been engaged and their terms of engagement are clarified as much as possible, this is the time to develop the legal contracts and close the deal. This stage is last because legal fees are expensive, and it is generally advised to determine as much as possible in previous stages before starting to draw up contracts in earnest.

Note: The information in this Milestone does not constitute any form of legal advice but instead serves as practical advice on how to manage engagement with lawyers and the process of contract development.

The Green Finance Institute is not a firm of solicitors or connected in any way with the courts. The information and opinions we provide in this section and across the Toolkit do not address your individual requirements and are for informational purposes only. They do not constitute any form of legal advice. We recommend that appropriate legal advice should be taken from a qualified solicitor before taking or refraining from taking any action.

Community Engagement

Community engagement is highly advisable for any project that aims to sell ecosystem services, to ensure fair outcomes for local communities and the long-term success of the project. Project developers can build connections with local stakeholder groups early on to spot both risks and opportunities.

Policy and Regulation

Project developers and enterprises will need to keep a continuous check on how current and future policy may affect the project, and also opportunities for the project to inform policy. The role of private finance for nature across the UK is being encouraged by the UK government and its devolved administrations, and new rules, standards and markets are being developed.

 
Quick Stats 
  • Location: Norfolk 
  • Size of Land: 292 hectares 
  • Tenancy & Ownership: Owner-occupiers 
  • Nature Market Focus: Peatland Code, BNG 
  • Project Partners: Natural England, Lincolnshire Wildlife Trust, Environment Agency, Centre for Landscape Regeneration, Centre for Ecology and Hydrology 

 

Acknowledgements 

With many thanks to the following individuals for their time and insight: 

Matthew Hay, Natural Capital Manager, Nattergal  

Frank Street, High Fen Wildland Site Manager, Nattergal

Ben Hart, Head of Operations, Nattergal 

 

 

 

Date Published: 27/10/2025

Next Milestone

Key Points: 

  • High Fen was purchased by Nattergal in 2022 due to its potential to be a restored lowland fen, its hydrological isolation and historically low agricultural productivity. 
  • The site’s hydrology plans have been the main determinant in its wider ecological planning, such as areas of peat rewetting and wetland mosaic restoration. 
  • Baselining took place in the first year of ownership which included a UKHab survey, peat coring, species surveys and LiDAR.  
  • This data helped show that a combination of Peatland Code and Biodiversity Net Gain unit sales would be most appropriate as revenue streams, spatially allocated across the site according to different parcels’ ecology, soils and hydrology. 
  • Nattergal has worked with many local project partners, including local landowners, landscape partnerships, and its county council (on the Local Nature Recovery Strategy), to access shared learnings and other opportunities.  
  • Permitting has been a significant challenge for High Fen, with some applications taking over 12 months to secure.  

 

Landscape and Original Land Use  

High Fen is located within the Norfolk Fens. Since the 17th century, the Fens have been drained to convert the region for major arable farming developments, due to their abundance of peaty, fertile soils. It is one of the most productive agricultural regions in the UK. However, this intensive farming has had a significant impact on the Fens’ biodiversity levels, natural hydrology, carbon storage and sequestration capabilities. 

A visualisation of this productive agricultural land has been provided by DEFRA’s Multi-Agency Geographic Information for the Countryside (MAGiC).  


Figure 1: Map of Soil Grade across the Norfolk Fens (MAGiC) 

Like its surrounding area, High Fen has an abundance of deep and peaty soils, and was historically used for arable farming. However, the land was eventually taken out of arable cultivation due to low productivity – linked to its soils and seasonally inundated ground. It was at one point a daffodil farm, and most recently had sheep and horse gazing, while being managed under Countryside Stewardship, primarily for wet grassland wading birds. 

High Fen has a complex hydrology. The River Wissey, which runs along the western boundary, supplies much of the site’s water. However the Cut-off Channel to the north and east, which was constructed in the 1950s as part of regional flood defence infrastructure, diverts water that would have naturally flowed from the higher ground of the Norfolk Brecks. The combination of peat and chalk soils contributes to a complex hydrological environment, with seasonal variability and water retention challenges – which the Nattergal team describes it using a ‘leaky bathtub’ analogy.  

Despite these challenges, one of the unique advantages of High Fen is that it is hydrologically isolated, meaning that rewetting can be carried out without affecting neighbouring landowners or requiring their permission, which is typically seen as a massive barrier elsewhere. 

Nattergal acquired the site in 2022 after it was put on the open market and brought to their attention by a local farmer, who highlighted its potential for wetland restoration.  

Matthew Hay, Natural Capital Project Manager at Nattergal, says that the team did not have much ecological data at the time of acquisition. However, High Fen’s size, hydrological isolation, and habitat composition made it appealing: “we were enraptured by the site, and could see that it was desperately trying to revert itself to a natural wetland state.” Nattergal also considered the site’s potential for the Peatland Code’s upcoming lowland fen protocol, through its Version 2.0, which was published in 2023. 

Figure 2: Map of High Fen 

 

Vision for the Land and Initial Baselining  

In its ambition to fully rewild the site, Nattergal set out with two major aims: 

  1. to rewet as much of the site as possible, preserving its lowland peat soils, and;
  2. to increase the species diversity and abundance on-site. 

Following acquisition, Nattergal commissioned a UKHab Survey with eCountability, and commissioned peat coring with Agricarbon to identify the site’s peat soil presence (but not depth), showing that 60% of the site is peatland. The Freshwater Habitats Trust also provided an assessment of flora species presence – concluding the site had poor biodiversity levels – and guidance on creating a resilient wetland system. Finally, Nattergal teamed up with an experienced hydrologist, Dr Nick Haycock, to further investigate the site’s complex hydrology. These initial assessments took around three months over the summer of 2023.  

Hay stresses that LiDAR and borehole excavations were both crucial for understanding the site’s re-wetting potential. Understanding the movement and behaviour of groundwater on the site, highlighted were drainage was occurring and shaped the restoration plans. 

While these assessments showed clear potential for habitat restoration and rewetting, they also revealed key considerations. For example, this monitoring immediately ruled out the potential of rewetting the upper, eastern half of the site due to its natural supply and drainage. Nattergal also discovered that the site had very high densities of badgers (36 sets), which were likely impacting the breeding success of previously abundant ground-nesting birds.  

Hay comments that, two years on, Nattergal is still building its understanding of the site and its hydrology, but was able to form a more detailed plan with this initial baselining within the first year. Detail on its more extensive baselining can be found in Milestone 3. 

After this first year, the visualisation of the future for the site was illustrated by Digg & Co. depicting the restored habitats of the site and the reintroduction of various native species. Hay comments that this illustration has been highly useful in stakeholder engagement.  

Figure 3: Illustration of High Fen’s Potential Future State (Digg and Co) 

 

Nature market and revenue scoping 

Once Nattergal received its peat depth and UKHab survey results, peatland carbon and Biodiversity Net Gain (BNG) unit sales were identified as the two most likely revenue sources. 

For peatland carbon, Nattergal used the Peatland Code’s Field Protocol to understand what areas of the site would be eligible under its new lowland fen protocol. For example, the lowland fen protocol does not accept areas of peat soil depth less than 45cm. With Nattergal’s ecological assessments, this  criteria initially ruled out around 150 hectares of the site.  

Nattergal also considered BNG unit sales, including those linked to high distinctiveness floodplain wetland mosaic, medium distinctiveness scrub and grassland. The UKHab survey (geared towards BNG’s habitat classification) helped Nattergal to understand the more easily improved habitats that could generate a higher BNG unit uplift. High Fen is also located in a large National Character Area, which gives Nattergal an advantage in selling to developers across up to 11 Local Planning Authorities (see below). This gave Nattergal initial confidence of a sufficiently large pool of demand. 

Figure 4: High Fen’s location within the Fens NCA (in green) (Natural England) 

Nattergal initially considered an ecotourism offering and  is open to exploring this again in the future. 

Nattergal will calculate the water benefits created by restoring High Fen, and will price in these benefits to the carbon and BNG units. In time the water services may be sold as a separate benefit if additionality can be proved. High Fen represents an excellent site to study and develop new methodologies for commercially realising water benefits provided through rewilding.  

 

Influential Partners and Local Initiatives 

Hay comments that High Fens’ neighbouring farmers and landowners have played an invaluable role in shaping the project and educating the Nattergal team about the Fens, sharing long-term knowledge. 

More formally, High Fen is part of the Ouse Washes Landscape Recovery (LR) Project, which is developing a 20-year partnership coalition across 4,000 hectares. This has offered shared learnings with other landowners, opportunities to create a ‘rewetted corridor’ with neighbouring landowners, and funding for some minor baselining activities. 

High Fen is also a partner in the Fens East Peatland Partnership, administered by Lincolnshire Wildlife Trust. This has offered shared learnings with other major fens rewetting projects, such as Wicken Fen, but has also given Nattergal access to an internal database of different contractors and service providers relating to fens rewetting. This has been particularly useful where Nattergal has been required to use a tender process for selecting contractors – which is a requirement of Natural England’s Peatland Grant Scheme, which Nattergal secured for the site (see below). 

Finally, Nattergal has engaged with Norfolk County Council on its Local Nature Recovery Strategy (LNRS), which is due to be published by the end of 2025. High Fen has been formally recognised as an area of strategic significance within the LNRS, which will mean the creation of a higher number of BNG units (through the metric’s strategic significance multiplier). 

Further partners on High Fen’s later baselining and modelling can be found in Milestone 3 

 

Legal, Permitting, and Tax Considerations 

High Fen is not designated under any conservation classifications, but the team has addressed several permitting requirements. These include:  

  • archaeological investigations and reports,  
  • protected species mitigation for its bund construction, 
  • flood risk activity permit (pending), 
  • water abstraction licences (pending).  

Hay says that permitting has been a slow process that has required patience and continuous effort. For example, Nattergal has undertaken intensive water vole mitigation, and Hay is currently giving feedback to Natural England on the process’s challenges. Nattergal also requires a winter water abstraction licence, due to the fact the River Wissey has been disconnected from its floodplain and continues to be artificially drained by the Cut-Off Channel. This additional winter water will have the added benefit of increasing the site’s resilience to climate change. The abstraction license is expected to take up to 15 months to secure. 

Nattergal has legally bound the site using a conservation covenant, with the Lifescape Project as the Responsible Body. Though only required for its BNG sites, Nattergal has chosen to apply its conservation covenant across the whole of the site – including for its peatland restoration areas – to ensure greater confidence in the permanence of the project.  

No significant tax implications were identified during early planning. However, accounting considerations include income recognition and amortisation of costs. 

 

Funding project development 

Nattergal has largely used its own funds, including the company’s equity, to cover costs across the Project, including land acquisition costs, permitting and legal costs, baselining and ecological planning fees.  

High Fen has also secured a grant from the Nature for Climate Peatland Grant Scheme, which will cover almost 75% of the costs associated with rewetting the carbon areas, as is permitted within the Peatland Code’s additionality rules.  

 


Figure 5: A photograph of Willow carr in High Fen Wildland (Nattergal)