Proposed changes to the planning system

We are concerned by the proposals in this Working Paper, which include scrapping site surveys, impact avoidance and mitigation in some scenarios. We believe this could cause devastating impacts on our 18 bat species as well as damage irreplaceable habitats. As such, we responded to the Government and you can read our response at the link below.

In September 2024, we responded to a consultation by the Ministry of Housing, Communities and Local Government (MHCLG) on reforms to the National Planning Policy Framework and other aspects of the planning system.

Primarily, we were concerned that the proposals lacked ambition or meaningful change with regards to the environment. The proposals would further tip the balance in favour of the economic aspects of development, over and above the social and environmental aspects, despite all three forming equal pillars of sustainable development. The proposals advocate for pushing development at almost all costs, despite concerns from local authorities, housebuilders and environmental groups.

Some concerns we had are as follows:

• The proposed changes would result in near-automatic approval of applications where land supply policies are out-of-date. This could risk environmental degradation. We remain concerned that the overarching policies regarding sustainable development in practice prioritise development over sustainability. We would welcome future changes to promote integration of ecological and climate targets into planning decision-making.

• It is damaging to take up land that could otherwise be used as natural green space and habitats in order to build homes that communities cannot afford to live in. We need to maximise the use of land for development in ways that result in comfortable and liveable housing for people alongside nature, rather than restricting local areas from seeking the tenure type they need more of.

• The consultation consistently conflates accessible green space and nature. None of the proposals are focused on nature recovery, just access to green space, which while positive, would incentivise creation of aesthetically appealing spaces with only limited benefits for nature and biodiversity. We would, therefore, welcome recognition in policy that green spaces also need to be beneficial for nature too, for instance through inclusion of native wildflower planting, hedgerows, water bodies, trees and appropriate/well-sited homes for wildlife, all protected from anthropogenic degradation.

• This consultation, despite having a chapter named ‘Supporting green energy and the environment’, makes no mention of issues like habitat degradation and insufficient enforcement of ecological requirements, instead focusing entirely on climate change and renewables. We think that these are all very important and relevant issues for the planning system to consider, but we were expecting more ambition considering the Government’s renewed commitment to meet domestic and international biodiversity targets. We are clear that policies on climate change will not automatically result in improvements in biodiversity and both issues must be considered together.

• Our local authority planning departments are clearly under-resourced and so long-term sustainable funding changes are needed to address this. We would hope to see a reduction in disparities between planning departments, supporting the ability to push for more ambitious environmental and ecological contributions from development.

• Requiring LPAs to allocate more land for more housing cannot be at the cost of putting housing in the wrong place, including where new housing would damage biodiversity or lock in housing poorly prepared for climate change. We would encourage including environmental quality (or potential quality) as a hard constraint that justifies a lower local housing requirement, in recognition of the importance of nature recovery and ecological connectivity between sites.

• Forcing LPAs to issue more permissions is not the most efficient way of tackling this issue as it does not address the significant portion of permissions that waste local planning authority time because they are not built (see the Town and Country Planning Association report Our Shared Future).

• We are also concerned that the combination of increased local housing requirements and the requirement to review Green Belt if a local authority can’t otherwise meet development needs would result in local authorities being coerced into accepting sub-par or even harmful development in the Green Belt to avoid penalties for missing housing targets.

• Setting a default expectation that brownfield developments will be given permission could make it so that environmental concerns are only an afterthought rather than an equal objective of sustainable development. This would shift the decision-making from whether to grant an application to whether to refuse an application, a much lower bar, which risks degrading or failing to protect the environment.

Proposed changes to planning regulations were published in the Government White Paper, Planning for the Future, on the 6^th of August 2020 along with a consultation that closed on the 29^th of October 2020.

Bat Conservation Trust has provided a detailed response to the Government's consultation and you can find that HERE.

BCT recognises 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.