Reforms to the National Planning Policy Framework: missed opportunities to drive nature’s recovery

(c) David Wootton (

In today’s blog, Carl Bunnage (Head of Nature Policy - England) and Pooja Kishinani (Campaigner – England), reflect on the changes needed in England’s planning system to address the nature and climate emergency.  

The planning system is one of the most important tools for driving nature’s recovery while also meeting development needs. However, continual changes to the planning system have left it poorly equipped to fulfil this vital purpose.  

In December 2022, the Department for Levelling Up, Housing and Communities opened a consultation as the first part of  its proposed approach to updating to the National Planning Policy Framework (NPPF). The proposals include amendments to the NPPF, principles to guide the preparation of new National Development Management Plans (NDMPs), and policies to support levelling up.  

Missed opportunities to drive nature’s recovery  

Whilst we welcome the opportunity to engage with the Government on how it can deliver its levelling up plans, we found its proposals a significant missed opportunity to tackle the nature and climate crises. Instead of bringing forward the strategic policies that would ensure the planning system works for nature, the consultation lacked proposals to amend the NPPF to support planning for biodiversity.  

Instead, it kicks nature and climate matters into the long grass, postponing their consideration for a consultation as part of a full review of national planning policy, probably in around a year’s time. This includes detail of the interaction of planning policy and important nature policies derived from the Environment Act 2021 which come into effect this year, such as Biodiversity Net Gain and Local Nature Recovery Strategies. This is too long time to wait when we are in the critical decade to halt and reverse nature’s decline. 

Key messages in our consultation response   

Whilst we support some good things proposed within the consultation, our response focuses primarily on how the planning system can address the nature and climate emergency. The NPPF should include the following to help achieve Environmental Act targets and net zero:  

- Explicit objectives for meeting nature recovery targets under the Environment Act 2021, and net zero by 2050 under the Climate Change Act 2008. 

- An explicit reference and definition of the mitigation hierarchy. After all, the best way to reduce environmental harm is to first avoid any negative effects on the environment, before minimising, mitigating, and then compensating for any environmental damage. 

- A strong ongoing commitment to a plan-led system with local democracy and public participation at every stage and provisions for local areas to show ambition in reversing nature’s decline, climate change and driving high quality place-making by exceeding national planning policy requirements. 

- Strengthened protections for designated sites for nature conservation, and the surrounding land that supports them.

- The prohibition of development on irreplaceable habitats, applying strengthened policy protection for ancient woodland and ancient and veteran trees to other habitats identified as irreplaceable. 

- A new designation to safeguard land against inappropriate development through the planning system for nature’s recovery. These sites (Wildbelt) would be identified by Local Nature Recovery Strategies and recognised in local plans with protections provided to enable these sites to support nature recovery. Such sites have the potential to nurture the recovery of habitats and wildlife, putting these sites on the path to qualify for a formal nature conservation designation once condition and long-term security criteria have been met. They can then become thriving local places for nature, climate and people. 

- A requirement for local plans to set a time-specific target for reaching the Access to Greenspace Close to Home Target (as described in Natural England’s Green Infrastructure Standards) that everyone should live within 15-minute walk of a green or blue space, and a requirement for all new developments to meet this standard. This target forms part of the Environmental Improvement Plan 2023 and is essential to ensure all communities have adequate access to nature for health and wellbeing. 

-A requirement for local plans to have a Green and Blue Infrastructure Strategy (as described in Natural England’s Green Infrastructure Standards) to ensure local planning authorities strategically plan opportunities to increase access to nature and benefits from nature-based solutions.

Stronger ambitions are necessary to deliver environmental targets  

We welcome questions within the consultation on how planning policy can encourage small-scale nature interventions, our experiences working in partnership with Barratt Homes at the nature-friendly community of Kingsbrook, at Aylesbury, has provided positive examples. However, merely tinkering around the edges of the planning system will not deliver the Government’s environmental targets and ambitions.  

More effective measures to unblock new onshore wind-development on sites that do not bring them into conflict with nature are also needed if we are to meet energy security and climate objectives. 

The further full review of the NPPF (probably towards the end of this year or early next) offers a real opportunity to address the planning system’s deficiencies. We hope that the wait will have been worth it, and that the review will finally include essential reforms to help ensure that the planning system addresses the most fundamental threat facing society – the nature and climate crises.  

We will be closely monitoring changes to the NPPF and will keep you updated on any opportunities to get involved in campaigning for more nature-friendly policies.  

To download and read our full response, click on the link at the bottom of the blog. 

Other campaigns you can get involved in:  

Take action to save our seabirds by supporting the ban on industrial sandeel fishing.  

- Attend a local consultation event run by your water company and help shape nature-friendly investments in their five-year spending plans.  

NPPF Consultation Response:

NPPF Consultation Response of the RSPB March 2023.pdf