Today’s blog, written by Pooja Kishinani (Campaigner-England), explores why the Government’s draft revised National Networks National Policy Statements (NNNPS) fails to address the climate and nature crises with urgency, and why we need a vision for national networks that delivers positive outcomes for the nature, the economy, and people.
The National Networks National Policy Statements (NNNPS), first introduced in 2014, sets out guidance for the development of strategic road and rail networks and strategic rail freight interchanges (SRFI) proposals, and the policy against which decisions on these nationally significant infrastructure projects are made.
The Government recently opened a consultation to seek views on revisions to the NNNPS to identify whether it is fit for purpose. Here, we provide an overview of the key issues we highlighted in our response to the consultation.
The draft NNNPS in its current form is fundamentally flawed because it does not reflect the urgency with which planning policy should respond to the nature and climate crises. In our response to the consultation, we raised four key concerns as to why the NNNPS does not sufficiently address the climate and nature emergency:
The lack of an overarching strategic spatial plan for national networks (or even road and rail in isolation) makes it difficult for the Examining Authority (usually the Planning Inspectorate) to determine if a specific project is the least environmentally damaging option and to compare the environmental impacts of alternative options, including cumulatively. This concern has also been highlighted in the National Infrastructure Commission’s (NIC) recent report, emphasising that detailed spatial planning will be important to support strategic environmental mitigation.
We support the NIC’s call for spatial plans, where they exist and can be prepared, to be designated as spatial planning documents subject to public consultation. Furthermore, it should be entirely possible to produce such spatial plans where investments and projects are largely publicly led as is the case with national road and rail networks.
In its current form, the draft NNNPS states “that at a strategic level there is a compelling need for development of the national networks – both as individual networks and as a fully integrated system” (3.22). This statement of need is blunt, simplistic, and problematic as a planning policy, and it fails to integrate wider economic, environmental and social considerations.
Under such a broad definition, any national network NSIP (Nationally Significant Infrastructure Project) at any cost to wider sustainability issues including climate and the environment could fulfil the ‘need’ as it merely has to be supported by one consideration - economic growth. It also assumes straight line growth in demand which may be simplistic, particularly given the lasting impacts upon travel behaviour arising from the COVID pandemic.
In reality the need for national networks NSIPs is highly location specific. We would urge the Government to amend this statement of need consideration by substituting the word ‘improvement’ for ‘development’. This would lean towards enabling a policy framework that allows for better integrated ‘win-win’ outcomes for people, the economy and the environment.
Moreover, the statement of need disregards the significance of the nature and climate emergency – an existential threat not just to national networks but our very survival. Environmental considerations should be recognised within a much more sophisticated and nuanced statement of need; and flowing from an improved NPS all related infrastructure development projects should deliver positively against both environmental/biodiversity and net zero priorities.
Currently, there is no monitoring report to demonstrate what impact policies and approaches within the 2014 NNNPS have had, or whether and how they need to be changed. The absence of any evaluation, for example, makes it impossible to assess the effectiveness or otherwise of a non-spatial planning approach in delivering benefits for nature, the economy, and people.
Most worryingly, the NPS does not go far enough to address the climate and nature emergency, which remains an existential threat not just to national networks but to our very survival. We need a policy framework that allows for better integrated ‘win-win’ outcomes for people, the economy and the environment during this critical decade for action.
The urgency with which we must act to minimise the impacts of both the nature and climate crises is not adequately conveyed throughout the document. For instance, the NPS should provide greater clarity on how Local Nature Recovery Strategies (LNRS) will be taken into account in relation major infrastructure planning processes.
Another example would be a stronger ambition for Biodiversity Net Gain (BNG). While we welcome the incorporation of a new section on BNG, given the significant scale and duration of Nationally Significant Infrastructure Projects, the BNG target should be at least 20% rather than the standard 10% for infrastructure projects in order to minimise the impacts on important sites, species and corridors for nature.
Climate and nature considerations must be central to all economic and investment decisions, as reflected by the Dasgupta Review on the Economics of Biodiversity. National network enhancements should therefore also be driven by net zero and with nature renewal considerations at their core.
Our conclusion is that in its approach to need and alternatives, the NNNPS is fundamentally flawed. We call for the NNNPS to enable more integrated ‘win-win’ economic, social and environmental outcomes. In the midst of a nature and climate emergency, we need an alternative vision for national networks which places the achievement of environmental goals - for biodiversity and net zero - at its heart.
Mistle Thrush (c) Ben Andrew/RSPB-Images.com