England is a special place

As followers of this blog will know, the RSPB is busy right now saving many special places, from Dungeness to the Tana River Delta in Kenya.

While colleagues are immersed in the Lydd public inquiry and other forthcoming inquiries and cases around the country, we’re fighting a battle on another front. This time it’s the whole of England (and no, I’m not forgetting the rest of the UK where other important battles are going on, but that’s another story!).

I’ve reported before on the Government’s proposals for revolution in the planning system through the Localism Bill and the National Planning Policy Framework (NPPF).

Over the last few weeks the Localism Bill has been debated in a committee of the House of Commons. We’re playing a leading role in a large coalition of NGOs, lobbying MPs, officials and other bodies with an interest in the planning system. We are very pleased that the amendments we’ve been suggested have been tabled by MPs and (mostly) debated by the committee. What’s more, on some of the key issues such as the importance of sustainable development, the need for strategic planning and a statutory basis for the NPPF, the planning minister Greg Clark has said publicly he would reflect on them and report back to the committee at a later stage.

That’s a refreshing change from experience on past planning bills where ministers have resolutely refused to countenance any amendments to their proposals.

If you’ve written to your MP about this, a big thank you. We’ve been very encouraged by the response from our members, which really helps to show MPs and the committee that you care about these issues.

We’ve also just submitted our official response to the Department of Communities and Local Government about what we think should be in the NPPF, based in part on the report we commissioned on a Natural Planning Framework for England. Our ten key points are below.

There’s still a long way to go on both the Bill and the NPPF. If we get both right, this should help us to avoid the need for battles like Lydd in the future. Here’s to a wildlife-rich England that’s a very special place.

1. The NPPF has a critical role to play in delivering sustainable development through the planning system. 
2. Research commissioned by the RSPB suggests that a strategic, spatial framework integrated with major infrastructure planning would deliver most benefits for a wide range of Government objectives, including for the natural environment. 
3. We are disappointed that certain options for the NPPF appear to have been ruled out. If the NPPF is not integrated with National Policy Statements, it should still include a spatial element for matters within its remit, such as areas of national importance for ecological restoration. Full integration with major infrastructure planning should be a long-term aim. 
4. The NPPF should be given an explicit statutory basis in the Localism Bill. 
5. The presumption in favour of sustainable development must be in the context of the plan-led system and a clear definition of sustainable development which recognises the need to live within environmental limits. 
6. The NPPF must set clear expectations for local planning authorities to work with each other and with other bodies on a range of strategic planning issues, including climate change mitigation and adaptation and biodiversity protection and enhancement. Evidence of effective strategic planning should be part of the tests of soundness for local plans. 
7. Strengthening current planning policy for biodiversity (currently in PPS9) is essential to halt the loss of habitats and restore biodiversity. In particular, local authorities should work together with local partnerships to restore and create habitat at a landscape scale. 
8. The NPPF must set out the Government’s national ambition on a range of other environmental issues such as: climate change mitigation and adaptation, water quality, flood risk, landscape protection and minerals planning.
9. Environmental assessment methodologies are useful tools for promoting the achievement of sustainable development. In practice they have suffered from a number of shortcomings, which can be addressed in large part through good practice guidance.  However the NPPF should flag up the importance of these tools and set a policy expectation that environmental assessment should be properly integrated with the planning process.
10. Best practice guidance on environmental planning can be produced by the relevant expert bodies, including NGOs. However, there is a continuing role for Government to help users of the planning system understand their legal obligations, such as through ODPM Circular 06/2005.