Andrew Chick Ecology

This is my response to the Planning Reform Working Paper – Development and Nature Recovery – https://consult.communities.gov.uk/planning-policy-and-reform/d085490e/consultation/intro/

Protecting Nature in Planning and Development

The current planning system and its geographic scale should remain unchanged, with the government listening to statutory conservation bodies like Natural England rather than creating new ones. Local Planning Authority (LPA) ecologists, who have a deeper understanding of county-level impacts, must be taken seriously.

Efforts to remove local considerations from HRA and licensing are unnecessary. While nutrient neutrality payments are debated, the majority of LPA applications are small-scale, contributing to ecological decline through cumulative impacts.

Ecology consultancy often focuses on protected species, yet existing legislation—WACA 1981, Hab Regs 2017, NERC Act, The Env Act, and NPPF—already supports nature recovery. The issue is not the legal framework but the government’s failure to apply it. Chronic underfunding of LPAs results in poor ecological assessments, delays, and an imbalance of power favoring large developers with government access.

The expansion of District Level Licensing to other species is concerning, as its effectiveness for great crested newts is still uncertain. With around 70,000 species in the UK, most remain understudied yet are interconnected and vital to ecosystems.

Slow HRA processes stem from a lack of LPA ecologists, statutory conservation staff, and planners—problems caused by underfunding, not inefficiency.

Finally, clean energy infrastructure must not come at nature’s expense. Urban biodiversity is crucial for ecosystems and public health. Disconnecting people from nature could worsen physical and mental health issues, increasing pressure on the NHS. Sustainable development must integrate both environmental and human well-being.

Strengthening Environmental Oversight in Development

Local Planning Authorities (LPAs) must be properly funded to employ at least two ecologists, ensuring planning applications are assessed, environmental enforcement is upheld, and Nature Recovery plans are implemented. Without this, UK wildlife will continue to decline, exacerbated by climate change and government rollbacks, with severe consequences for both nature and human survival.

Natural England must be empowered to make independent decisions without political interference. Rather than creating a new body, the government should trust its expertise to safeguard biodiversity. Additionally, Local Authorities need funding for enforcement officers to hold developers accountable. Current fines for environmental violations are inadequate, allowing destruction to continue unchecked.

The Lost Nature Report highlights the UK’s failure in environmental enforcement, with many developers linked to government officials. This demands increased scrutiny, not leniency. Large developments frequently violate conditions with little consequence due to weak enforcement and funding shortages.

Government ministers with ties to developers should not oversee environmental decisions, as their interests often conflict with genuine Nature Recovery efforts. Robust oversight, independent decision-making, and strict enforcement are essential to prevent further ecological decline.

Prioritizing Local Leadership in Nature Recovery

Delivery Plans must be led by Local Planning Authorities (LPAs), ensuring strategic guidance aligns with local ecological conditions and the community benefits of Green Infrastructure. A balanced approach is essential, integrating broad objectives with site-specific ecological needs.

Biodiversity Net Gain (BNG) can support Nature Recovery but should not be the primary solution. Its calculations can be manipulated, and LPAs often lack the staff to assess them properly. The use of AI in ecological decisions is also concerning, as nature’s complexity cannot be fully understood or predicted by algorithms.

Funds from biodiversity offsetting should be directed into a National Nature Recovery Strategy, managed by a properly funded government body. The current system of unregulated offsetting providers fails to maximize its potential for meaningful conservation.

Strengthening Local Environmental Assessments

Individual environmental assessments are essential for identifying site-specific impacts and mitigation. Replacing them with a single strategic assessment would be unworkable, harming both developers and biodiversity.

Investment should focus on strengthening the existing planning system and Natural England, rather than creating a new body. The government must also ensure LPAs are properly funded to audit developments and enforce compliance through site monitoring reports.

Rethinking Sustainable Development

Current development remains unsustainable, displacing biodiversity rather than integrating it. A truly radical approach would embrace permaculture principles, nature-led design, and carbon-negative infrastructure. The outdated “two up, two down” model must evolve, alongside greater public awareness of the cost of ignoring the Nature Emergency.

The environmental community has lost faith in the government’s ability to meet even its own environmental pledges. If advice from consultations is ignored, history will judge this administration for failing to act at a critical moment for nature and climate.