The Government’s planning proposals read as if the planning system had only one purpose: houses.
The proposed system would carve up the country into three zones. The growth and renewal zones would extend Permission in Principle for new infrastructure development, short-circuiting the planning process by allocating land for development upfront and limiting Local Planning Authorities’ discretion to refuse individual projects.
By contrast, the “protection” zone would, in fact, offer no additional environmental protection. It would be comprised of greenbelt, AONBs, Conservation Areas, Local Wildlife Sites, Sites of Special Scientific Interest, areas of significant flood risk and important areas of green space. Here, developers would continue to submit applications for development in the familiar fashion, with decisions made on a case-by-case basis.
In other words, in the growth and renewal zones it will be easier to build. In the protection zone, very little will change.
21st Century Objectives
In fact, the planning system exists to balance a range of national and local priorities in our increasingly land-constrained country. There is nothing intrinsically bad about a zonal planning system; it can help to plan more strategically and reduce costs by revealing and reconciling trade-offs upfront. But to be effective, it must give proper weight to the full range of purposes we need from our land: not just housing, but climate change mitigation and adaptation, sustainable land management and the recovery of nature.
Separately, the Government is considering positive and important proposals for the development of Local Nature Recovery Strategies (LNRSs) and a Nature Recovery Network (NRN). Unfortunately, these ideas are compromised by the lack of statutory force for them to be considered in the planning system. In the Environment Bill, there is only a weak duty to “have regard” to LNRSs in setting local environmental policies, with no link to day-to-day planning or spending decisions. The NRN has no legal identity at all.
Also in the Environment Bill are provisions for Biodiversity Net Gain, which would require developers to create more habitat than they destroy. These proposals are weakened by exemptions for permitted developed and major infrastructure projects. The new planning proposals risk weakening them further by extending the use of Development Consent Orders for large-scale house-building. The use of these instruments could lift whole towns out of the Town and Country Planning Act system, exempting them from net gain provisions and undermining the system before it even becomes law.
These two programmes of planning reform appear to have been developed in two separate tracks: an MHCLG housing track (with a build build build boost from No 10) and a DEFRA 25 Year Environment Plan track. Combining the two by strengthening the Environment Bill proposals and integrating them into a zoning plan could help to deliver both.
A Nature Recovery Zone and a Highly-Protected Zone
A zonal planning system could help to make strategic choices about land management if it incorporates nature’s needs and our need for “natural infrastructure”. These could be explicitly recognised in separate zones, with additional provisions to speed up investment in nature and safeguard existing natural treasures.
For example, a “Highly Protected Zone” could help to reinforce the protection already afforded by site designations such as SSSIs by incorporating other important sites like Local Nature Reserves alongside ancient woodlands, peatlands and other priority habitats in an area with a legal presumption against development. The idea could be extended to our marine environment, with zones allocated for Highly Protected Marine Areas, where damaging activities are prohibited to let nature recover.
A wider “Nature Recovery Zone” could be identified where there are planning permission in principle is given for environmental investments and new hard infrastructure is discouraged. For example, some projects to create important habitats like ponds and wetlands currently require planning permission, but this could be simplified or granted in principle for areas in a Nature Recovery Zone to speed up investments in ecosystems, helping to support nature and provide nature-based solutions to climate change and flooding. These areas could be provide space for large-scale rewilding projects, greening the greenbelt, nature corridors through the landscape, or “tier 3” environmental land management projects.
These zones could be the zonal articulation of Local Nature Recovery Strategies, giving LNRSs direct force in the planning system. Together, they could add up to an effective national Nature Recovery Network.
In 2021, the international community is expected to agree a new global deal for nature under the Convention for Biological Diversity. We hope that a new target will be set to reverse the decline of wildlife. To help get there, there is a growing movement to designate 30% of land and sea for the protection of nature. The Government has already committed to protecting 30% of our waters; Wildlife and Countryside Link members have written to the Secretary of State to propose that 30% of our land should also be managed for nature. Creating zones for environmental management could be a powerful demonstration of intent by the Government ahead of those critical talks.
Nature in the growth zones
Of course, allocating zones for nature, should not mean that other areas become a free-for-all for development
In these areas, we support the proposals for a much better environmental information base to inform decision-making, integrating environmental considerations upfront in a more strategic manner by mapping out important habitats in advance. To do that successfully, Local Authorities will need to have access to much richer information and the support of ecologists and environmental planners. Improving environmental information upfront can create more certainty for developers and reduce costly delays, as well as helping to protect nature.
Critically, though, these more strategic approaches can never entirely replace the need for site-specific survey work to investigate whether sensitive habitats and species are present that might not have been picked up in early, generic mapping
A 21st Century approach to environmental spatial planning
The Prime Minister’s foreword calls his planning proposals the most radical since the Second World War, but if anything they are pre-war in their perspective. Even as war raged, MPs were debating laws in Parliament that would protect National Parks and wildlife sites. The Government would do well to heed the wisdom of their wartime predecessors and consider the role that nature can play in helping us recover from crisis. This time, a narrow focus on economic recovery in the wake of covid-19 risks repurposing the planning system in a way that does not reflect the real needs of people or the economy.
To reshape our economy in a way that will be resilient against future environmental risks, support people’s mental and physical health, and help us restore nature, it is essential that the planning system gives as much weight to environmental considerations as it does to housing numbers.
If zonal planning is the Government’s preferred approach, then it must be fit for 21st Century objectives and the rift between MHCLG's house-building agenda and Defra's 25 Year Environment Plan must be closed. For these reforms to succeed, they should clearly allocate land for nature’s recovery, with strong additional provisions for protection and planning support for investments in our natural world.
Richard Benwell, CEO, Wildlife and Countryside Link
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