28th October 2020
Proposed changes to planning regulations were published in the Government White Paper, Planning for the Future, on the 6th of August along with a consultation that closes on the 29th of October at 11.45pm. We recognise the need for more affordable housing, but any reform of the planning system needs to be done in a way that is sensitive to the needs of local communities and avoids impacts on the environment and wildlife. We have previously highlighted our concerns around the proposals (available HERE) and many of you have added your voices to ours – thank you for your support.
We have now provided a detailed response to the governments consultation and you can find that HERE.
A summary of our concerns:
The current planning system has been developed over many years and it has benefits for people, business and wildlife that can and should be built on by careful reforms rather than by wholesale abandonment of existing policy. Planning reforms need to give support to the aims and objectives of the Environment Bill including Local Nature Recovery Strategies and Biodiversity Net Gain.
The planning system must demonstrate:
1. environmental protection. The on-going decline of biodiversity has been well documented. Good planning is essential for people as well as the environment. By strategically integrating nature’s recovery with land-use planning so they are viewed collectively and alongside each other, this will help to ensure that development proposals do not continue to cause on-going losses, whilst efforts are being made to halt the loss of biodiversity. Our Natural Capital is vital for a prosperous England and should be assessed as part of scrutiny of any proposed change to the planning system.
2. resourcing (a) data. having up to date and robust environmental survey data is essential. For some species such as bats and birds, surveys will need to be on a site by site basis as development proposals come forward. The current environmental data set is far from complete and cannot be relied on to give a proper assessment of biodiversity. Strategic-level mapping will not be capable of replacing on-site survey work. It has already been demonstrated and agreed by the building sector that if carried out at the right stage, this process is not onerous. Without such information, Natural England will not be able to properly fulfil its legal obligations to advise public bodies.
3. resourcing. (b) There are ongoing collaborative pieces of work to streamline the planning and licensing process that should be taken into account. Earned Recognition for ecologists is aiming to reform species licensing with a view to making it faster and more effective for all stakeholders. There is also a Wildlife Assessment Check that assist SME understand the likely biodiversity on site that will need to be considered upfront prior to submitting for planning. Other actions that can assist are: to improve Local Authority access to ecological expertise, increase the number of strategic planners and development management officers, and issuing formal guidance to developers so that they are aware of the quality of information required by Planning Authorities.
4. Democracy - the current planning system already has an integrated democratic process that allows local people and communities to have a voice in how their area is developed. These proposals will remove a major significant tier of democracy which will not necessarily speed up development.
Reforms must ultimately achieve three things:
1. Avoid causing harm. It is often seen as cheaper to mitigate rather than to work with nature and avoid harm. The emphasis must be placed on avoidance and not mitigation and compensation. There must be a presumption against development in protected areas where harm or damage will arise.
2. Give nature space. People need to have access to natural green infrastructure. There needs to be a programme to green our existing infrastructure. The link to nature that is acknowledged as being important for people’s physical and mental health and wellbeing.
3. Ensure proper and adequate public consultation and participation in decision making.
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