DEFRA’s consultation on the implementation of Biodiversity Net Gain(BNG) is still running – it ends on 5 April - and yet we are hit by three more government consultations on planning and the environment:

• Environmental Targets
• Nature Recovery Green Paper – Protected sites and species
• Land use in England inquiry

Here’s where you can find them all and a short summary of each.

1.    Environmental Targets

Click here for consultation. End date 11 May.

Government says: “We are seeking views on the first suite of Environment Act 2021 targets. The Act requires that at least one target in each of four priority areas is set in: air, water, biodiversity, and resource efficiency and waste reduction. It also requires targets to be set for fine particulate matter (PM2.5) and species abundance. These targets need to be laid as draft Statutory Instruments by 31 October 2022 and will come into force once approved by Parliament. We are proposing targets that we consider will lead to action in areas that drive environmental outcomes where we face some of greatest threats and pressures. This is why we are considering targets over and above the minimum required; with additional proposals in biodiversity, water, marine and tree planting.”

Must aim higher

Wildlife and Countryside Link’s CEO, Richard Benwell provides an excellent summary in his blog here, in which he discusses the proposals, and how these do not aim high enough on ambition, scope and measurability to halt nature's decline by 2030.  He sets out more details in his Twitter thread on the topic, here. 

We, Community Planning Alliance, are running a webinar to discuss this consultation, at 4pm on 28 April: click here.

2.    Nature Recovery Green Paper – Protected sites and species

Click here for consultation. End date 11 May.

Government says: “Following our departure from the EU, the UK Government has set out a new framework of environmental targets under the Environment Act 2021 (the Environment Act). This includes an ambitious target on species abundance, with the objective to halt the decline in nature by 2030.”

“Our overall aim is to move to an approach which focusses more on outcomes and recovery. This should in turn enable us to build on the strategic approaches enshrined in the Environment Act which address issues upfront and early, while placing impacts and mitigations into the context of our nature recovery objectives for whole landscapes and catchments.

What thoughts?

‘KISS’ & ‘KIP’.  KISS (‘Keep it simple stupid’) is the theme throughout, with proposals to rationalise and simplify environmental designations. It’s true that the classifications and laws around protecting nature are horribly complicated and peppered with acronyms. So simplifications would help the public and community groups to understand protections. However, it is essential that with any simplification, government also focuses on KIP (‘Keep it Protected’).   There should be no reductions in protections in any new labelling system.

Habitat loss. The goal to have 30% of England protected by 2030 is catchy but does not seem terribly ambitious, given that 26% already is protected. The focus on creating new protected habitat is admirable, but more importantly, there needs to be a focus on preventing habitat loss.  

Human interaction factor. Public access to green space is very important. However, humans and their pets can cause terrible damage to woodlands and species. A recent example is Chilterns Beechwood’s Special Area of Conservation (SAC) in Dacorum, which is under increasing visitor pressure, and a mitigation strategy is required.  

3.    Call for evidence, “Land Use in England”, House of Lords Select Committee

Click here for inquiry details. End date: 26 April

“Over the course of its inquiry, the Committee will be undertaking a wide-ranging study of all aspects of land use in England, the policies which govern them, the short and longer-term outlook for how land use may change and may need to change, and the most appropriate response to these changes. Within this study we will be considering the role of the key drivers of land use change including climate change, biodiversity decline, population and economic growth, and the extent of their influence.

Most importantly, the Committee will be looking at how the Government can best develop a strategy to plan for these changes, and is also keen to hear proposed solutions to current and emerging challenges. The Committee has a particular focus on integration of policies and on planning for multifunctional land use, and would especially welcome contributions on these themes.”

Currently there are competing and un-managed priorities for land use. On a local scale, land uses are decided without looking at the national, cumulative, picture. Nationally there is no over-arching strategy or framework to manage competing uses.  Decisions are made in governmental silos.   The result is a 'wild west' of solar developers, biofuels growers, land promoters for housing, off-setting promoters and farmers all competing for the same land.

Three things the government could do better

The Community Planning Alliance(CPA), which I Chair, is calling for an end to silo thinking:

• A new Minister of Food Security and Land Use must be appointed to implement a land use strategy and co-ordinate the Government bodies involved, including the Cabinet Office’s Geospatial team.
• Implementation of National Food Strategy recommendation 9 (a rural land use framework based on a three-compartment model). 
• A ban on use of our best farmland for non-food purposes, and recognition of the importance of food production in the National Planning Policy Framework. 

And finally..

DEFRA’s consultation on the implementation of Biodiversity Net Gain

Click here for consultation. End date: 5 April.

DEFRA’s latest BNG consultation is running now. Goals are: to secure positive outcomes for biodiversity, to improve the process for developers, and to create better places for local communities. All you need to know is on the CPA’s website. The CPA has responded in full, and you will see guidance from one of the top BNG academics, Sophus zu Ermgassen, and a suggested email you can send to your MP if you only have two-minutes spare.   CPA concerns around implementation centre on:

A.    Avoidance & Additionality

B.    Boosting funding

C.     Community involvement & trust

Have fun responding...