Dealing With Natural England and other Environmental Bodies #NPPF Concerns – Alternative Draft New Version

A few days ago we published a revised version of our alternative NPPF draft dealing with concerns raised by English Heritage and other bodies.

In this latest version we have looked at issues raised by Natural England, The Environment Agency, Wildlife and Countryside  Link and the RSPB.

The aim has not been a lowest common denominator approach or worse a big tent approach accepting every change.  Rather it has been looking for common ground and accepting reasonable amendments that clarify issues and neither add unacceptably to length or divert the thrust of a more proactive document.

The alternative draft can be found here

A log of the changes here, including of those suggested which we think should not be made.

Next we will tackle housing issues.

We are making good progress within a couple of weeks we think we will have got through all of the major groups comments.  What we hope this means is that it should be possible to ‘fix’ the key issues by broad consensus, leaving only the most difficult issues, concerning the ‘presumption’ and the duty to cooperate.

The Key Bodies #NPPF Responses in One Post

Ive tried to put together the responses from key national organisations here.

Some are late with their responses.  Some haven’t yet posted them or responded to emails, but quite a few have and even emailed their responses prior to posting them – thank you.  If there are nay major gaps please send me the links or responses ill gladly put them up.  Would be nuce in future to do a county by county round up of responses, if there are any volunteers in helping to gather them up.

Action for Market Towns

British Property Federation

Campaign Against Sprawl

Chartered Institute of Water and Environmental Management

Council for Protection of Rural England

Country Land and Business Association

Design Council Cabe

English Heritage

Environment Agency

Friends of the Earth

Heritage Alliance

Homebuilders Federation

Housing Groups Response (Nat Fed, Shelter etc.)

Historic Towns Forum

Landscape Institute

Local Government Association

London Councils

London Forum

National Farmers Union

National Trust

Natural England

Planning Officers Society

Ramblers Association

Rescue (British Archaeological Trust)



Royal Town Planning Institute


Theatres Trust

Town and Country Planning Association

Transport Groups Response (Chartered Institute of Highways and Transportation and other groups)  

Urban Forum

UK Green Building Council

Wildlife and Countryside Link

Woodland Trust

Environmental watchdogs warn of ‘unintended consequences’ of #NPPF – Telegraph


Controversial planning reforms risk harming the countryside, the Government’s own environmental watchdogs have warned.

The Environment Agency and Natural England, which have until now remained silent on the changes to the planning system, have both raised concerns over the Coalition’s proposals to make development easier.
As government bodies, both organisations usually avoid criticising government policy, but they have warned that the key part of the draft National Planning Policy Framework – a new presumption in favour of development – could have “unintended consequences”.
The proposed changes, which reduce the planning regulations from more than 1,000 pages to just 52, have sparked intense opposition from campaign groups, led by the National Trust, who fear it will lead to widespread development in the countryside.
Ministers insist the reforms, which would change the current system so that proposed developments would be given automatic approval if they are deemed to be “sustainable”, are essential to provide new housing and to drive economic growth.
Opponents, however, say the new rules tip the balance too much in favour of housing developers and risk sacrificing parts of the countryside for economic reasons, with even the green belt’s protection facing dilution.

The dispute descended into an ugly war of words between ministers and he National Trust, along with the Royal Society for the Protection of Birds and the Campaign to Protect Rural England.

The warnings from the Environment Agency and Natural England will be seized on by opponents and come in the formal responses submitted by both agencies to the official consultation on the reforms.

Natural England, which is responsible for protecting habitats and wild species, said the proposals failed to attach enough value to natural landscapes, risking development on countryside that should be protected for the sake of its beauty, heritage and wildlife.

It warned that decisions could “collectively lead to a degraded environment, which can undermine longer term economic growth and wellbeing”.

It said: “We consider that there is a risk that the wording of the presumption in favour of sustainable development could have unintended consequences of environmentally damaging development.”

The organisation also called for the draft NPPF to offer protection to Sites of Special Scientific Interest, which are currently protected in the current planning laws but not in the NPPF.

The Environment Agency issued a separate warning about the removal of policies that currently encourage development on brownfield sites ahead of greenfield sites.

The Environment Agency said: “We believe that there is a risk that the replacement of the brownfield first policy with ‘land of lesser environmental or amenity value’ could reduce the amount of contaminated land that is restored.”

It also raised concerns over an aspect of the plan that would see developments being automatically approved if councils did not have up-to-date local development plans in place for their area.

Fewer than 30% of local authorities currently have such plans and lawyers have warned that even those may be considered out of date once the new framework comes into force, allowing developers the chance to push through undesirable developments.

The Environment agency said: “We are concerned that an unintended consequence of applying the presumption in favour of sustainable development could be that, until Local Plans are updated and in place, some developments could be approved that have a negative impact on the natural environment.”

Ministers are currently considering more than 10,000 responses to the consultation on the proposals are expected to make a number of changes to the document before it is due to come into force next year. But they have refused so far to back down on the most contentious element – the presumption in favour of development….

The National Trust is now calling for a second consultation because of the scale of concerns raised.

A spokesman for the National Trust said: “We will be keeping a very close eye on what comes out through the government’s process and looking carefully at the end result.

“We are very keen for a second stage of consultation but we have yet to hear anything to raise our hopes.”

A spokesman for the Department for Communities and Local Government said: “We are now carefully and thoroughly considering all the responses to the consultation, and we will publish the final document in due course.”