26 Jul 2019
Preliminary observations on new Planning Practice Guidance for the Natural Environment
This reflective piece looks primarily at the green infrastructure and net gain components of the recently released NPPG for the natural environment and should NOT be seen as a comprehensive review.
The natural environment has become populated with an increasing and bewildering array of terms and concepts; natural capital, ecosystem services, green infrastructure, net biodiversity gain and net environmental gain and nature recovery networks. Each term in itself requires unpacking but crucially needs to be understood in terms of how they all fit together so as to deliver better environmental outcomes. This is problematic as they have all been introduced at different times and for different purposes so their fit is not perfect. The guidance does not address this and thus leaves the concepts floating within their own definitional and policy spaces begging the question how they might fit together in plans, policies, programmes and projects. Given the recent national and local authority declarations of a climate emergency this does represent something of a missed opportunity.
There is reference across the NPPG to guidance on these terms with a relatively weak statement that they can be used to inform policy without imposing stronger policy requirements. The guidance on ecosystem services for example dates back to 2014 and includes a huge array of reports rather than clear guidance. Given the recent IPBES report (2019) alerting us to a biodiversity crisis with further declines this seems a further missed opportunity to incorporate latest ecosystem services research. Equally, The UN sustainable development goals are overlooked and they also offer strong guidance with indicators that could help address this. The UK government has signed up to these and I am not sure is fully aware of their requirements; this surely should be fed into wider planning guidance?.
The definition of green infrastructure is improved within the NPPG from the more restrictive one employed in the NPPF now embracing blue infrastructure explicitly.
“Green infrastructure can embrace a range of spaces and assets that provide environmental and wider benefits. It can, for example, include parks, playing fields, other areas of open space, woodland, allotments, private gardens, sustainable drainage features, green roofs and walls, street trees and ‘blue infrastructure’ such as streams, ponds, canals and other water bodies. References to green infrastructure in this guidance also apply to different types of blue infrastructure where appropriate.”
Paragraph: 004 Reference ID: 8-004-20190721
The definition, however, does not stress green infrastructure as a planned and managed network designed to deliver multiple benefits. This in my view is important as it distinguishes it from green space and features.
It is good to see that the role of gardens is recognised as green infrastructure assets even though they lie outside the planning system. The role of green infrastructure in delivering multiple benefits is recognised through the different ecosystem services it delivers and its contribution to core planning goals.
- Building a strong, competitive economy
- Achieving well-designed places
- Promoting healthy and safe communities
- Mitigating climate change, flooding and coastal change
- Conserving and enhancing the natural environment
It is in the strategic role and operation that the NPPG most disappoints. There is no explicit recognition that GI networks should become a core issue for statements of common ground (duty to cooperate) or that they should be included in strategic and local plans. Given their contribution to all the above including the climate emergency it does seem strange that there is not stronger guidance that these networks should be identified in much the same way as housing need requirements. It merely states that they can be a useful tool.
However, it does recognises their contribution to other policies such as CIL although Section 106 agreements, where they are most frequently used, are not identified. It also misses the opportunity to identify green belts as core components of green infrastructure in cities where they exist. This is key as the positive approach to green infrastructure and its management is often lacking in green belt policy and they remain separated in their own silos rather than integrated. I would like to have seen the recognition that green belt is a core component of green infrastructure and should be valued and protected for the range of ecosystem services it delivers as well as the more traditional components of green belt policy.
Given our own work on developing good green infrastructure policy, it is important that local and strategic plans develop policies that cover ALL the different functions of GI. There does not seem to be any guidance that promotes or requires this multifunctional aspect for good GI. There is a need to go beyond the simple set of environmental policies and it is here that mainstreaming of GI across other policy areas is important.
Use of GI in planning decisions.
It is good to see that green infrastructure needs to be considered at the earliest stages in planning proposals. There is recognition of using various planning tools to achieve GI outcomes but the guidance lacks clarity on how actually to achieve good outcomes. One of the core GI uses is securing long term funding for maintenance which does not impact on viability. This conundrum is not addressed and there needs to be a culture change in seeing green infrastructure as a benefit as opposed to a burden. The climate emergency offers a powerful hook to achieve this. The guidance is weak on how this is to be achieved but it good to see recognition that this needs to be done at an early stage and involvement with communities is a key aspect of this.
“Arrangements for funding need to be identified as early as possible, and factored into the design and implementation, balancing the costs with the benefits. Local community engagement can assist with management and tailoring provision to local needs”.
There is recognition that net gains for biodiversity can be achieved as part of green infrastructure provision;
“Net gain in planning describes an approach to development that leaves the natural environment in a measurably better state than it was beforehand. Net gain is an umbrella term for both biodiversity net gain and wider environmental net gain”.
This is useful as a definition with the emphasis on “measurable”, but the lumping of biodiversity net gain and environmental gain under the same umbrella could confuse as there is clear view that biodiversity net gain should be normally a prerequisite before environmental net gain is considered. The separate treatment of biodiversity net gain and environmental net gain without reference to this is potentially dangerous.
It is also disappointing to see the singular of the term used here. In the NPPF the term net environment gains is used reflecting the need to prevent one aggregate measure being used that somehow reduces the different ecosystem services to one figure.
“Plans, and particularly those containing strategic policies, can be used to set out a suitable approach to both biodiversity and wider environmental net gain” signifies relatively weak wording and commitment here. In under resourced planning departments this is likely to be an optional extra rather than something that “should” be done. Given the recent climate emergency declarations it is important that such gains are required in plans and policies.
The natural environment is a key asset for our economic and social wellbeing ; fact. The NPPG confirms this but fails to really commit local planning authorities to strategic actions to achieve these, instead favouring them to recognise the value of doing so. It seems to me that there is a missed opportunity with regard to requiring nature and green infrastructure to be part of the statement of common ground thus helping address the climate emergency concomitant with developing good policy and plans. Indeed ,the overall panoply of environmental terms and concepts encountered here need not only to be unpacked (as the guidance does) but rather integrated and explained how they fit together to deliver better environmental, economic and social outcomes (this is lacking).
 As part of the NERC work I am doing a briefing paper on this will shortly be published on the web site. https://mainstreaminggreeninfrastructure.com/index.php
Thanks for the useful analysis!
By: Mark Reed at: 27 Jul 2019, 08:34:31