The National Planning Policy Framework could change a lot of things: in theory it could improve the lot of England’s dwindling biodiversity.
For example it states that local planning policy should:
promote the preservation, restoration and re-creation of priority habitats, ecological networks and the recovery of priority species populations, linked to national and local [biodiversity plan] targets; and identify suitable indicators for monitoring biodiversity in the plan
leaving aside the nit picking about local biodiversity plan targets not existing any more, this is a very ambitious aim.
This is tied in to the new England Biodiversity Strategy Biodiversity 2020, which was published quietly in August to little fanfare.
B2020 has ambitions of its own. The mission is: To halt overall biodiversity loss by 2020, support healthy well-functioning ecosystems and establish coherent ecological networks.
This will be achieved on land by:
- no net loss of priority habitat, and getting 90% of all priority habitat into recovering or favourable condition.
- more, bigger, less fragmented areas for wildlife
- increase by 200,000ha in the area of priority habitat, compared with now.
- 17% of England managed to safeguard biodiversity and ecosystem services
- 15% of degraded ecosystems restored to contribute to climate change mitigation/adaptation.
So, how could the new planning system contribute to making these things happen. One way would be to protect the existing resource so that there was no loss of priority habitat or species population as a result of any planned development. Another way would be to require developers to restore or create new priority habitat as part of new developments. Finally this would all have to happen in a spatially coherent way so all the bits joined up. Maps would be needed showing how ecologically coherent networks were going to be restored across administrative boundaries. Incidentally these were produced in the Regional Spatial Strategies.
Unfortunately the NPPF does not give much weight to the protection of priority habitat outside protected areas like SSSIs and at least one third of all priority grassland habitat occurs outside protected areas. The NPPF states that a development can go ahead and destroy an irreplaceable habitat if
“the need for, and benefits of, the development in that location clearly outweigh the loss”.
This brings to mind the whole debate around Biodiversity Offsets. How can you calculate the costs of destroying a wildflower meadow, and can creating a pond somewhere else really compensate for the loss? The NPPF introduces this concept of irreplaceable habitats – are these somehow different from the priority habitats already defined in law under Section 41 of the NERC Act (habitats of principal importance). There’s a clue below.
Alright then, what about requiring developers to restore and create habitat as part of a development, to contribute to that 200,000ha target. The NPPF is silent here, not even mentioning offsets. All it says is that if a development impact cannot be compensated, planning should be refused. But if you read the offsetting publications from Defra , as far as they are concerned, only ancient woodlands are irreplaceable and everything else can be easily restored or re-created. So who will ensure that developers do contribute to creating all this extra habitat – well you may not be surprised to hear that it will all be left to local communities to decide. Finally, compensating for the loss of one area of habitat by re-creating another area (or lower quality) somewhere else, does not get us moving towards 200,000ha of additional habitat, unless the compensatory area is magnitudes larger than the lost area.
Well what about being joined up, creating a coherent ecological network acros England? Sorry, that doesn’t really sound like localism does it? All decisions are being devolved down to the most local level possible. So ecological networks will also have to build from the bottom up. Parish by Parish.
That rather superficial analysis brings two things into stark contrast. Even leaving aside the distinct possibility that the NPPF will cause a development free-for-all leading to habitat destruction on a scale we have not seen since the 1980s, the NPPF has nothing in it which will actually contribute positively towards the targets set out in Biodiversity 2020. Even the much derided ecotowns had a target of 40% green infrastructure. The NPPF just pays lip service to GI.