Our response to the National Planning Policy Framework (NPPF)

swiftJohn Bridges

Please feel free to use any of these points in your own consultation responseThe Wildlife Trusts will be commenting in detail on the changes proposed in the draft review of the NPPF.

There are many elements for which we would like to express support, and several that concern us and for which we will request changes. We are looking to secure the implementation of a Nature Recovery Network. Sitting as part of an Environment Act (that requires the establishment of an ecologically coherent network following the principles set out by Sir John Lawton’s Making Space for Nature), we need policy that will:

A. Protect the existing elements of a potential network of protected wildlife sites, like nature reserves

B. Require local authorities to provide a spatial plan for the network, linking up current wildlife-rich areas through planning that allows wildlife to move and flourish

C. Require development to contribute to the establishment of the network, by actively creating spaces for nature in all new developments

The review of the NPPF is an opportunity to ensure that development contributes to the establishment of a Nature Recovery Network but hasn’t strengthened the relevant policies enough.

1) A key issue is the lack of any protection for those undesignated sites that already make up part of the potential network. We are lobbying strongly for Local Wildlife Sites (formerly known as Sites of Nature Conservation Interest) to be included in the hierarchy of protection.

2) Positive spatial planning for the environment not only makes it easier to locate development in a way that avoids damage to existing sites but can make the most of the benefits that nature provides to communities (ecosystem services) and enable development to help strengthen these services. There needs to be a requirement that local strategic plans, as a minimum, work with neighbouring planning authorities to provide this.

3) We welcome the policy support for net gain, but there is a lack of clarity and consistency in the current draft of the revised NPPF on net biodiversity gain had how this links to a Nature Recovery Network. The contribution needs to be a requirement, not an option.