On Tuesday the Government published a new National Planning Policy Framework (NPPF) for England. You can see our previous commentary on the draft version here, here and here.

The NPPF sets out the Government’s planning policies for England and how these should be applied by local planning authorities in drawing up plans and making decisions on planning applications. That means the policies in the framework are important in setting the scene for future places and for protecting and enhancing the natural environment.

We are therefore pleased to note the emphasis on good design and the importance of this in creating better places and as a key aspect of sustainable development.

There are other positives – for example it’s clear that effort has gone into aligning the document with the Government’s 25 Year Environment Plan. Policy around biodiversity net gain has been improved and tightened – we need a step change in approach if we are to genuinely arrest biodiversity declines AND deliver improvements, particularly in light of the Government’s ambitious housebuilding programme. There is a risk of losses as well as gains if this policy is badly implemented. That is why we will continue to work closely with Defra to ensure the approach is carefully regulated and that it delivers for wildlife as well as the wider environment.

We are pleased that ancient and veteran trees are given the same protection as ancient woodland – an improvement since the last draft; that reference to local wildlife sites has been reinstated in the published NPPF (although protection for these does not go far as hoped); that there is more clarity around strategic and non-strategic policies and it is clear that non-strategic (or local) policies should be used to provide more detail, including on the natural environment.

We agree with the commitments to make better use of land and ensuring all areas have a plan in place. However, it must be the right plan at the right scale and we must not forget that some previously developed sites can be real havens for wildlife. Therefore, it is disappointing that the previous protections for brownfield land of high environmental value appear to have been weakened.  

Policy protecting Sites of Special Scientific Interest (SSSIs) has changed slightly since the consultation draft and is shorter than the 2012 NPPF policy – strong policy protection for SSSIs is important to us, and a key part of our armoury when fighting damaging developments such as at Lodge Hill.

A bungalow with solar panels on the roof surrounding by a thriving garden full of flowering plants and bushes, long and short sections of grass and trees at the edges of the garden

Will this policy work for wildlife? Image credit: Andy Hay (rspb-images.com).

There are other changes to the natural environment chapter, some of which seem hurried and could create confusion (perhaps no surprise in the rush to analyse over 29,000 responses and publish the final NPPF in time for the summer recess…). Further work on the accompanying Planning Practice Guidance will be needed to avoid unintended consequences.

However, we are left wondering whether the good policies will really get a look in. Notwithstanding improvements since the first draft, the published framework is undoubtedly balanced in favour of housing. There is a significant risk that changes such as the new approach to calculating housing need and the amended presumption in favour of sustainable development will simply load ever more homes into existing high demand areas (such as the south east of England) set amongst isolated pockets of wildlife, placing pressure on important local sites such as Local Wildlife Sites and brownfield wildlife havens.

Conflicts exist elsewhere in the Framework – opportunities to develop onshore wind, a low cost and technologically proven renewable energy source (which we support in the right locations) will be limited by NPPF policies, whilst unconventional hydrocarbons are given more support. Whilst we recognise there are improvements from the draft version we do question Government commitment to meeting the challenges of climate change.

Ultimately what this country needs (and what the NPPF fails to do) is to set out a vision for the kind of country we want to see – a national spatial plan for England. This would provide an effective framework for spatial planning at the local level and at the same time help integrate and deliver other public objectives, including for the natural environment. This would support commitments in the 25 Year Environment Plan for a Nature Recovery Network providing a plan for what we would like to see nationally, giving a clear steer to planning authorities.

It will take time for the new framework to bed down and for planners and decision-makers to understand what it all means. However, we urgently need a fully resourced planning profession supported by independent technical experts such as ecologists to ensure that all aspects of the framework are fulfilled and we don’t end up with plans that deliver housing and little else.

Finally, planning as with other sectors, is intimately linked with our environmental laws (many of which come from the European Union). That’s why we also need to:

  • Set out ambitious objectives for nature’s recovery and environmental restoration in law, including ensuring there are targets, milestones and measures in place to deliver them, 
  • Take action to close the gap in environmental protection that leaving the EU will create,
  • Co-develop and co-design strong environmental watchdog functions that work across the boundaries of the UK to hold themselves and future governments to account.

The Government are consulting on future environmental protection now, so there is still time to join our call for something far stronger than their current proposals, which fall short of their own stated ambitions. Find out more and add your voice here: rspb.org.uk/environmentwatchdog.

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