Response to Natural England’s Operational Statement

The Chartered Institute of Ecology and Environmental Management (CIEEM) recognises the pressures facing Natural England, including the increasing volume and complexity of planning casework. The approach shown in the Operational Statement reflects these pressures and the need to prioritise finite resources. We welcome the emphasis on early engagement and addressing environmental issues at the outset of the planning process, alongside increased focus on strategic planning and nature recovery. This aligns with our Good Development campaign, which emphasises the importance of embedding environmental considerations from the beginning of the development process rather than trying to resolve them at later stages which leads to more costs, delays and unsatisfactory outcomes for both developers and nature.

However, we are concerned about the practical implications of the change in approach set out in the Statement. For many years local planning authorities, applicants and ecological consultants were accustomed to receiving case-specific input from Natural England. In recent years this has been less forthcoming as Natural England operated under increasing financial constraints. The Operational Statement indicates a further shift away from what had been the norm. Greater reliance on standing advice, strategic solutions and local decision-making has placed more responsibility on local authority ecologists and planning officers to interpret guidance and determine whether ecological matters have been adequately addressed. Yet local planning authorities themselves are in many cases inadequately resourced to discharge this responsibility efficiently. The result has been increasing nature-related delays to projects and frustration for developers and their ecological consultants. Nature has been seen as the problem, rather than the lack of experienced resource for effective and timely decision-making.

Also, the success of a system that relies more heavily on standing advice and strategic solutions depends on the resources remaining current and the solutions backed up by an appropriate evidence base. Maintaining and updating guidance and properly evaluating the impact of solutions requires sustained investment in Natural England’s technical capacity. Without such investment there is a risk that practitioners and decision-makers will increasingly rely on guidance that doesn’t fully reflect current requirements or emerging issues, especially in the face of climate and environmental change. Increased reliance on local interpretation could also lead to greater variation in evidence requirements, mitigation expectations and decision-making. This could create uncertainty for applicants and ecologists.

It will also be important to ensure that the meaning of ‘no comment’, ‘no further comment’ and similar responses is clearly understood. The absence of detailed comments from Natural England should not be taken to mean that ecological impacts are absent, that submitted assessments are adequate or that proposed mitigation is sufficient.

In summary, CIEEM supports the principle of directing expertise towards areas where it can have the greatest impact. We also recognise the professionalism of those providing planning advice within Natural England. However, the success of the approach set out in the Operational Statement will depend on sustained investment in ecological skills, expertise and capacity across the planning system, together with robust monitoring, evaluation and adaptive management of area-based measures. As strategic solutions become increasingly central to planning, it will be important that Natural England and its partners are adequately resourced to evaluate their effectiveness and demonstrate that they are delivering the intended environmental outcomes. Confidence in these approaches needs to be built on genuine evidence of ecological success not planning efficiency.

CIEEM welcomes continued engagement with Natural England, Defra and other partners to ensure that these changes strengthen, rather than weaken, the planning system’s ability to deliver nature recovery alongside good development.