There’s a lot of change in store for our countryside over the coming years – probably far more than we currently realise.
Earlier this year, the Department for Environment, Food and Rural Affairs (DEFRA) consulted on a new Land Use Framework that identified some of the changes we can expect to see.
By 2050, a total of 19% of our farmland – more than 1.6m hectares – will be repurposed to benefit wildlife or address climate change. Some of those changes will be small - planting trees in fields still used for food protection accounts for just 370,000 hectares of the total, for example. Others will be huge. Almost half the land impacted will be turned to non-agricultural uses such as creating new woodland and restoring peat-forming habitats.
Some farmland will be lost to housing development too, but the numbers are small. Hitting the government’s target to deliver 1.5 million homes by the end of this parliament – a target they are almost certain to miss – requires just 0.2% of our farmland. If home building continued at that rate until 2050, just 1.1% of our farmland would be needed; around the same lost to food production by introducing nature into field margins and by watercourses.
Given that context, it is no surprise that the planning system is interacting with the natural environment more and more. Here are a few of the ways that is happening.
The Planning and Infrastructure Bill
The route of HS2, the new rail line intended to provide desperately needed extra capacity on our railways, passes an area of woodland in Buckinghamshire which is home to a population of Bechstein’s bats. Bechstein’s are rare in the UK - due to a combination of habitat loss and being at the very northern-edge of their natural range – and are therefore protected.
Natural England raised concerns that high-speed trains passing their woodland home could result in some bat deaths. As a result, a 900 metre long, steel mesh protection structure was added to HS2’s design, intended to stop bats inadvertently flying too close to the trains. The cost of this bat tunnel? A cool £100 million.
Nobody would argue that protecting bat populations isn’t important, especially rare ones. But if you gave England’s bat charities £100 million to spend on bat conservation measures, a single 900-metre-long mesh tunnel is unlikely to come close to the top of their list of projects. It’s a wasteful way of spending that money to deliver ecological improvements.
The bat tunnel might be an extreme case, but is replicated across the country. Developers are asked to deliver site-specific mitigation, often at huge cost, which does little to address the wider issues impacting protected sites and species. Put simply, our current approach doesn’t deliver the best outcomes for the environment.
The Planning and Infrastructure Bill – or at least the environmental bits of it – are intended to remedy that.
The Bill would require Natural England to prepare “Environment Delivery Plans” (EDPs) designed to deliver particular conservation benefits across a defined area. That might be Bechstein’s bats in Buckinghamshire or Great Crested Newts across the whole of England. Rather than looking to deliver site-specific mitigation, EDPs would be at a much larger scale, and designed to deliver tangible benefits for populations as a whole, rather than the smaller subsets of that population which happen to live close to a particular development.
Developers would cover the cost of delivering an EDP by paying a levy to Natural England to build in the designated area and, in return, would no longer be required to deliver some site-specific mitigation. The objective isn’t to save developers money, but rather to ensure what we are already spending on ecological mitigation is used in the most effective way possible.
This is a welcome change, but one that is likely to make little difference in the short-term at least. Until an EDP is in place, nothing changes – and Natural England’s track record of delivering landscape-scale plans like this leaves a lot to be desired. The prospect of a nationwide network of EDPs seems remote, although some large-scale, strategic infrastructure projects may well see some benefits.
Suitable Alternative Natural Greenspace
The Ashridge Estate, owned by the National Trust, is part of the Chiltern Beechwoods Special Area of Conservation (SAC). Parts of it are also a Site of Special Scientific Interest (SSSI). That’s very high level of ecological protection.
The National Trust welcomes 1.9 million visitors a year, with 6% of those visiting the well-regarded café. But those visitor numbers are damaging the site. A report by an ecologist published in 2022 found more than 500 instances of damage including trampling, soil compaction and erosion, “nutrient enrichment” (which means dog poo), litter and many more.
You might think that the answer to these challenges is for the National Trust to better manage visitor numbers, perhaps close the café, even. But you’d be wrong; in fact, they recently refurbished the café to make it more attractive.
Instead, in an effort to stop any further increases in visitor numbers, Natural England have banned new homes within 500m of the site. Within a 12.6km “zone of influence,” new homes are only allowed if they are accompanied by a Suitable Alternative Natural Greenspace (SANG), designed to syphon off visitors from the Chiltern Beechwoods.
A survey of visitors at Chiltern Beechwoods found that 75% would use an alternative greenspace, with their number one ask for what it should include being, inevitably, a café.
SANGs need to be big – at least 8 hectares for every 1,000 residents – but developers have been trying to deliver them. Taylor Wimpey, for example, secured permission for a SANG on the edge of Berkhamsted to allow them to deliver new homes nearby. Although this SANG opens up previously private land to the public and provides a new natural area for public enjoyment, perhaps unsurprisingly local residents and CPRE objected.
This SANG is actually far bigger than Taylor Wimpey need for their own purposes, so they are selling “credits” to other developers, asking for a contribution towards the cost of delivering the SANG in exchange for those developers using some of the space to justify their own planning applications.
The country is littered with areas with similar protections to Chiltern Beechwoods, and so SANGs are becoming an increasingly common part of the planning system. This is a potential opportunity for landowners who own sites which might not be suitable for housing development – perhaps due to landscape impacts – but which could still be worth more to a developer as a SANG than they would for agricultural use.
Nutrient Neutrality
Nutrient neutrality is about avoiding pollution in our rivers by chemicals that act as nutrients for plants - typically nitrogen but also phosphates. If elevated levels end up in watercourses, that extra food causes algae populations to grow rapidly – so called algal blooms. This stops sunlight reaching the riverbed but, more importantly, when the algae dies, they sink to the bottom and decay – using up oxygen and releasing carbon dioxide and killing aquatic life. As every high school geographer knows, this is a process called eutrophication.
There are two main sources of these nutrients. The first is agricultural fertiliser. Not all the fertiliser spread on fields is taken up by the plants it’s intended for. Some leaches through the soil into watercourses. The second is untreated sewage from sewage works, especially after heavy rainfall. Most of our sewers in England are “combined” sewers taking both foul water from your toilet and surface water from gutters and roads. When it rains hard – and climate change means we will experience high intensity rainfall more often – that causes a spike in flow rates, which sewage works are often unable to cope with, overflowing into rivers as a result.
New homes, in contrast, are a very small part of the problem – and mainly because of the extra sewage flows they introduce to the sewage works.
Where a watercourse is designated as a Special Area of Conservation or Special Protection Areas, planning permission can’t be granted if nutrient pollution would exceed legal limits. In many cases, it already does – almost a quarter of local authorities include a protected river catchment where nutrient pollution is already above legal limits.
For development to go ahead in these areas, it must show that it is “nutrient neutral” and won’t increase nutrient flows into the watercourse.
That can be done on a site-specific basis by calculating the expected nutrient flows and mitigating them appropriately. For example, that might be by paying for a sewage works to be upgraded (although there’s a legal requirement for water companies to do this anyway). It can also be achieved by ending some agricultural uses – developers paid a pig farmer £1 million to stop farming pigs so they could build 1,400 homes, for example. In some parts of the country, dairy farmers have been offered similarly substantial payments to reduce the size of their herds.
The best way of delivering nutrient neutrality, however, is through landscape-scale interventions, like reed beds that soak up the nutrients. This approach can create large reductions in pollution in the most cost-effective way, making the problem better rather than simply stopping it from getter worse. Developers can cover the cost of those works through buying “credits” to unlock development – similar to the way Environmental Delivery Plans are envisaged to operate by the Planning and Infrastructure Bil. That does, however, need upfront planning and isn’t a widespread solution yet. So, for now, Natural England’s preferred approach is still to micro-manage where we can all poo.
You can read more of Paul’s writing on Substack and LinkedIn, and on social media as @Paul_SLG
This post was written by Paul Smith, Managing Director of land promoter The Strategic Land Group, based on his recent presentation at the BIAC Rural Planning Conference.