There’s something about alliterating names which is strangely popular. Take CCC, for example. No, I don’t mean County Cricket Club or even the Committee on Climate Change, but Congestion, Capacity, Carbon. That’s the title of the National Infrastructure Commission’s interim report on its priorities for national infrastructure. The Commission has identified seven key priorities:

  •  Building a digital society: fast, reliable data services everywhere.
  • Connected, liveable city-regions: linking homes and jobs.

  • New homes and communities: supporting delivery of new homes.

  • Low-cost, low-carbon: ending emissions from power, heat and waste.

  • Revolutionising road transport: seizing the opportunities of electric and autonomous vehicles.

  • Reducing the risks of extreme weather: making sure the UK can stand up to drought and flooding.

  • Financing infrastructure in efficient ways: getting the right balance between public and private sectors.

Its final report, to be published in the summer, will make recommendations to the Government for future infrastructure needs in these areas and is likely to have significant implications for nature in the UK and the special places the RSPB is trying to save, both on land and at sea.

We’ve been talking to the National Infrastructure Commission about these matters for some time now and last week we submitted our response to their interim report. We’re particularly pleased to see the Commission’s ambition that “everything we do must enhance the environment: tackling air quality, protecting natural capital, reducing CO2 emissions, improving quality of life.”

These are laudable ambitions, and of course the Government’s 25 Year Environment Plan, published last week, and the Clean Growth Strategy published last autumn, will be key to realising them, as well as making sure that after Brexit, all European environmental law is fully converted into UK law and is properly implemented and enforced.

There’s a lot of technical detail in the report and also in our response. But I want to share two things that struck me: one puzzling thing and one opportunity.

First, the puzzling thing. Despite its laudable ambitions for the environment, the report (and a previous environment report) strangely underplays the significance of infrastructure impacts on biodiversity at a strategic level. Air and water quality, flooding, noise and climate change are all considered key environmental parameters. There’s also welcome recognition of the importance of green infrastructure. But the report is strangely quiet on biodiversity.

Regular readers of this blog will find this bizarre in the light of the significant effort the RSPB devotes to dealing with damaging infrastructure proposals, from the proposed Severn Tidal Barrage to the Firth of Forth windfarms (housing is not part of the Commission’s remit, which is why I can’t use Lodge Hill as an example). To be fair, I don’t think the Commission is suggesting that biodiversity is unimportant when assessing the impacts of individual projects. It’s more a question of whether, in the bigger picture, infrastructure is driving biodiversity decline.

For the answer to that, we need look no further than State of Nature 2016. Although agricultural intensification gets the headlines as the most significant driver of species decline, urbanisation (which includes infrastructure development) is up there in the top four drivers.

If we leave sorting out biodiversity impacts to the project level, we’re often leaving it too late, because it’s much harder to avoid or mitigate impacts on individual schemes if they’re in the wrong place or are the wrong type of development. We need to look much more seriously at less damaging alternatives – at every level from national policy-making through to sub-national strategic plans (both on land and sea) before a project even gets on the drawing board.

Which brings me to the opportunity. The Commission needs to think spatially about the implications of its recommendations to the Government, because this will be a key means of influencing whether future infrastructure enhances or damages the environment. It could recommend to the Government that it undertakes a national spatial plan for infrastructure (perhaps along the lines of the Scotland National Planning Framework). This would help to ensure that infrastructure is properly located, minimising conflicts with wildlife and maximising opportunities for biodiversity enhancement. The Commission should certainly encourage the role of strategic spatial planning for delivering connected, liveable city-regions, delivering new homes in the right places and well-sited energy infrastructure, while also enhancing natural capital.

We look forward to seeing how they respond to our suggestions.