The National Planning Policy Framework (NPPF) consultation is currently underway. The outcome of this consultation will determine the balance between the needs of business, communities and wildlife and natural spaces. There clearly has to be a balance: some people wish for no development and some wish for unrestrained development but the fact is that this does need to be balanced. Some people will be disappointed that they can’t build wher they want, and some sites that are currently green will ultimately be built upon.
But…where should that balance lie? The NPPF is quite clear – the balance should be in favour of “sustainable development”. There are many faults with this premise, not the least of which is the lack of a definition of “sustainable” – this leaves it open to interpretation, and in many places the words “sustainable” and “economic” are almost interchangeable. The message is clear: businesses must be allowed to expand and nothing should deter the building of houses. The assumption is that planning will be pro-growth.
Local Authorities can put plans in place, and they are obliged to identify land for different kinds of development, including housing, economic activity and for community use, as well as sites for mineral extraction. They can also identify Designated Green Spaces the definition of which is relatively loose, but could be spaces for either recreation or wildlife sites. All sounds good so far…but there are a lot of buts.
First of all, local businesses will be allowed to bring forward neighbourhood plans and neighbourhood development orders. Businesses, but not other local community groups. They can put together their own development plans free from constraints of additional permission. Local communities can comment but cannot block such development. They must consult with local businesses in producing a local plan, but cannot overrule them – business development takes precedence.
Second, at present there is a target for re-development of pre-used land. This will be removed. This land is expensive to both buy and develop, and with the incentive removed to do it, developers will inevitably and understandably favour green-field sites that are cheaper to buy and build on.
They also plan to exempt certain changes of use from planning constraints, including industrial, storage and business to residential. Now, flexibility is a good thing, but leaves the door open to justify building a business site on economic grounds only to see it changed to residential in future.
Green space designation looks fine and good – but it is strictly limited in scope. Essentially it refers to green spaces that are urban or peri-urban and of limited size, and which are not already included in green belt or other designated land. It really means parks, recreation grounds and small wild spaces – immensely valuable in themselves but not sufficient to protect the needs of wildlife in the wider landscape.
What about protection for wildlife? Well, it is very limited. The presumption will be against development in those areas with statutory protection under EU Biodiversity legislation, and in National Parks, AONB’s and SSSI – but always with the proviso that development can happen if the benefit outweighs the cost. Ancient Woodland is promised protection, but what kind of protection, and what strength it will have, are not defined. And there is no protection at all for the immensely valuable Local Wildlife Sites – small sites such as our own which provide refuge and habitat for wildlife but which do not meet the criteria for SSSI because their value is local, not national or regional. There is no mention either of the Nature Improvement Areas – landscape-scale conservation areas envisaged in the Natural Environment White Paper as a result of collaboration between neighbouring landowners in the private, public and charitable sector. They do not have to be incorporated into the local plan, and the local plan is very much open to challenge – it is up to the Local Authority to show that a development is not sustainable before permission can be denied. Challenges are already coming in, even though this is only at the consultation stage. It seems this plan will deliver growth, if only for lawyers, as challenge seems the most likely outcome of any refusal.
Major infrastructure will also be treated differently, with the presumption that these developments will go ahead. HS2, for example, a development that is likely to affect many irreplaceable ancient woodlands, including, possibly, our own.
What will this mean for wildlife protection? The future does not look bright. Minimum statutory standards, and wildlife squeezed progressively into smaller and smaller designated areas, progressively further removed from local communities. Small, fragmented Green Spaces serving mixed purposes of recreation and wildlife conservation, with wildlife squeezed to the margins, the road and rail corridors and ever-reducing Local Wildlife Sites.
We think this needs to change. We think that there need to be key changes in the underpinning philosophy that will allow everybody to benefit: businesses, communities and wildlife. In particular
- The presumption in favour of development and growth should be removed: instead, there should be a presumption only that development will be sustainable, and will balance the need of communities, business and wildlife. And sustainable should have a well-recognised definition.
- Statutory protections should have teeth: there should be an extremely high threshold for building on or developing in areas with current statutory protection. There should be new statutory protection of equivalent to SSSI awarded to ancient woodland, Local Wildlife Sites and other key habitats. Nature Improvement Areas should also have such protection: development within these should be carefully considered and wildlife needs to take priority here.
- Development of brownfield sites should also take priority, but with careful caveats: where such sites themselves have become valuable wildlife habitats, and with clear consideration of the need to provide green space and wild areas within cities and towns.
Nobody denies that things need to be built, and nobody wants a NIMBY charter. But unless such building is controlled, we will see wildlife, and local people, pushed to one side, marginalised, ignored, forgotten and degraded. We need a strong campaign to stand up for little wildlife areas that are so valuable. Withouth strong advocacy they will be lost forever. How tragic would that be?
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