How can we plan for a better environment?

The purpose of this report is to summarise what Local Planning Authorities (LPAs) are doing to plan for a better environment and how they can potentially capitalise on the opportunities of the environment and climate change agenda. It is a starting point, and we hope that it generates further discussion and ideas regarding best practice.

It is based on set of informal interviews with senior planners in the following Local Planning Authorities between December 22 and January 23:

Bedford Borough; Bolsover District; Bracknell Forest; Braintree District; Cornwall; Carlisle City; Colchester City; Doncaster Council; Dorset Council; Durham Council, Greater Manchester Combined Authority; Essex County; Lancaster City; Salford City.

Annex 1 provides a full list of participants.

Following the interviews, two roundtables were held to discuss and agree the findings set out in this draft report

Planning reform, the Environment Act and Improvement Plan, and the Government’s broader consideration of land use in England, provide significant opportunities for planning to play a key role in meeting Government’s aspiration to create a better environment for future generations.

And yet we know from our work with Local Planning Authorities (LPAs), including biodiversity net gain, nature recovery and nutrient neutrality, that this is a complex agenda requiring integrated, coordinated approaches to achieve multifunctional benefits from the use of land.

As more and more LPAs respond to this rapidly evolving policy agenda, they will need to consider what makes a good Local Plan for the environment. We know that many LPAs have worked hard to take account of the evolving legal and policy context in reviewing their Local Plans in recent years. We are also aware of the significant amount of work LPAs are engaged in to support delivery of policy objectives through collaboration with local partners.

We think it is important that LPAs can learn from each other and share their experience of what makes a good Local Plan for the environment. Whilst it is still early days, there is a lot of good practice out there. Through this report, we aim to draw together some insights and experience from a range of LPAs and share this more widely.

We hope that local planning authorities will find it helpful and that it provides a useful starting point for thinking about planning for a better environment through the Local Plan.

Throughout December and January, we spoke to senior planners in 14 local authorities to gain some insight into how LPAs are planning for a better environment. We held semi-structured interviews with officers in district, unitary, county, and combined authorities in different parts of the Country to gather different perspectives. A total of xx officers attended the conversations and a list of local authorities is attached at Appendix 1.

We have grouped the insights under 5 principles of effective planning: leadership and governance, policy and evidence, decision making, process and systems, and delivery.

1. Political and corporate leadership at a local level is an essential pre-requisite for mainstreaming the environment in planning.
2. The new environmental agenda and planning reform will require a more coherent and streamlined approach to developing policy objectives in relation to the environment. 
3. Development management considerations are integral to good plan-making so that decision making is efficient and balances multiple policy objectives in a place.
4. This is a new and evolving area of work with many strands, and planning authorities will need to develop new skills and knowledge with internal and external partners.
5. Consideration of how policy objectives will be integrated and funded to deliver multi-functional land use is a key component of good planning for a better environment.

Leadership & Governance

Political and corporate leadership at a local level is essential for mainstreaming the environment in planning.

The legal and policy context for addressing the environment and climate change agendas is evolving rapidly. The Environment Act is a powerful new driver because it introduces mandatory requirements into the planning system. The NPPF review is an excellent opportunity to clarify and strengthen environmental policy requirements, and National Development Management Policies are expected to have a crucial role in helping planning authorities balance competing priorities in decision making. Local Plans will need to consider how to deal with this external legal and policy environment in a timely way.

Political and corporate priorities have a significant influence on how the Local Plan responds to environmental challenges and opportunities. Climate and ecological declarations, access to greenspace post-pandemic, and human health are major policy drivers. In many local authorities, elected members are keen to go further faster, especially on climate change. If this is to be achieved on a consistent basis, Local Plan timescales will need to be more responsive to political appetite for change.

Corporate leadership at all levels is needed to ensure a whole-system approach, supported by collaboration between departments, regular engagement and partnership working. Corporate plans and strategies for carbon, sustainability and environment are instrumental in driving the environment agenda through planning.

The governance of sustainable development is dominated by economic growth. The need to respond to climate change provides an opportunity to consider how growth can be achieved more sustainably and secure multiple social, economic, and environmental benefits. Local authorities should consider what governance arrangements exists and how this can be improved to better align economic and environmental objectives.

The degree to which the environment is seen as a barrier or opportunity for growth varies considerably depending on the socio-economic context of the area, development land values and environmental quality. In areas facing post-industrial decline, high levels of deprivation, and high unemployment, the environment is not a priority. This contrasts sharply with areas of high growth, low deprivation, and high-quality environments where climate and nature are a high priority for communities.

Policy and Evidence

The new environmental agenda and planning reform will require a more coherent and streamlined approach to developing policy objectives in relation to the environment.  

The scope of environmental planning has grown in recent years as Local Plans respond to the concepts of sustainable development and place making. In line with the NPPF and planning guidance, Local Plans generally incorporate a long list of policies for protecting and enhancing the environment. It is therefore becoming increasingly important to identify the synergies and linkages between policy objectives, be clear about relative priorities, and describe how policies should be delivered.

It is important that policies for the environment are framed within a broader narrative. Sustainable development or growth is often a ‘catch-all’ although it is very evident that policies are being increasingly framed in the context of climate change, and this seems to be leading to a greater priority for the environmental aspects of sustainable development.

The timescales for Local Plans against a background of fast-moving legislative and policy reform means that Plans can quickly become out of date in terms of policy coverage. By having flexible policies, planners can make Local Plans work harder and stay aligned with the changing national context.

Several LPAs have progressed partial Local Plan reviews, DPDs and SPDs to ensure that the environment and climate change is more fully considered in planning and that planning plays a key part of the local response to climate and ecological emergencies.

Strategic planning at a county or combined authority scale often enables local authorities to pool resources and skills and develop joined up approaches to policy and delivery. This is particularly evident for BNG, GBI, and strategic mitigation for habitats sites. Due to the different trajectories and timescales of planning across different areas, LPAs need to work together to manage complexity and realise the benefits, for example, consideration of how strategic policy approaches can be applied most usefully and practically in different areas with different requirements.

Green and Blue Infrastructure (GBI) is the dominant framework for considering environmental challenges and opportunities through the Local Plan and is often associated with provision of ecosystem services and natural capital. GBI policy priorities are typically set out in a GI strategy and sometimes in the Infrastructure Delivery Plan. However, because GI is not a ‘must do’, LPAs will need to consider carefully how GI priorities beyond the development boundary will be delivered as part of a coherent landscape scale network.

Typically, Local Plans include both strategic and development management policies for GBI. Strategic policies set out a framework at a landscape scale whereas DM policies are designed to improve the quality of development. There is an important link between GI and design at both levels.

Natural Capital could provide a framework for evidence and policy within the context of sustainable development. However, it is early days and many LPAs have decided to rely on a GBI approach. As more Local Plans incorporate natural capital approaches, it will be important to share ideas and good practice and understand the views of planning inspectors.

As a new mandatory requirement, most LPAs understand the potential for Local Nature Recovery Strategies to set out a spatial representation of land use priorities to deliver environmental benefits. LPAs need to understand how the LNRS at a ‘county’ level should work alongside related policy objectives including GBI, natural capital, BNG etc at a district level. For those planning authorities at various stages of reviewing their Local Plan, some interim guidance and advice based on the existing NPPF and PPG would be helpful, including examples and case studies.

Many LPAs are developing policy approaches to support low carbon/net zero housing including energy efficient buildings, low carbon construction, and renewable energy generation. Whilst the development of climate proof policies has been challenging, several examples are beginning to emerge successfully following examination by inspectors. It will be important for LPAs to work with Government and PINS, and share and learn from each other, to ensure that more Local Plans are found sound.

Two themes emerged in relation to evidence for Local Plans. Firstly, despite there being a wealth of evidence and data available, there is often a lack of good evidence about the quality of the environment at a localised level. Secondly, that a lack of consistent and comprehensive monitoring means that there is a limited feedback loop into future evidence needs and policy making.

Decision making

Development management considerations are integral to good plan-making so that decision making is efficient and balances multiple policy objectives in a place.

The pace and complexity of the emerging legal and policy context is a challenge for development management teams. The workload for DM officers in increasingly technical, for example, planning applications which require BNG, energy efficiency, tree-cover calculations, and there are more policy objectives to be considered and balanced with other priorities.  LPAs will need to ensure that policy is developed in collaboration with development management teams, allow sufficient time for it to bed-in, and provide accessible, short packages of support and training. Some authorities are looking at how to augment and coordinate expertise, for example, using planning performance agreements to bring specialists together and sharing specialists across multiple authorities e.g., ecology, design. This will require a more strategic and proactive approach to development management.

Despite demonstrating Local Plan viability, securing developer contributions to meet environmental policy objectives is often challenging due to competing socio-economic priorities. Securing developer contributions tends to be easier where the benefits are retained locally and environmental objectives are designed-in from the start, for example in a Garden Village. It is much more difficult to secure contributions at a district-wide level. LPAs will therefore need to consider a more coherent approach to securing funding for environmental improvement.

Process and systems

This is a new and evolving area of work with many strands, and planning authorities will need to develop new skills and knowledge with internal and external partners.

Some LPAs are being proactive and putting in place new processes and systems to help them address the various new legal and policy requirements. Many others are thinking about how to approach it and secure the resources to design and implement it. For example, biodiversity net gain and nutrient neutrality will require additional specialist advice to enable LPAs to deal with planning applications and provide post-decision monitoring and reporting. Planners will need financial and commercial skills to understand the delivery landscape and how to make it work locally e.g., delivery of mitigation through environmental credit schemes. They will need to understand the operating rules and legal risks and establish suitable governance arrangements.

Most LPAs say they do not effectively monitor the outcomes of policies and decisions beyond legislative requirements e.g., habitats sites mitigation, and that annual monitoring is perceived as something of a tick-box exercise. More meaningful monitoring is needed to understand whether planning is having a positive impact on place making outcomes and inform successive Local Plan reviews. This would require developing robust environmental evidence baselines, through mapping of GI and/or natural capital assets, and regular reviews. The new system of Environmental Outcome Reports proposed in the LURB will be important in this regard.

To deliver policy objectives, LPAs must work in partnership with a range of stakeholders, including landowners/managers, to develop projects and schemes that deliver multiple benefits. NGOs such as the Wildlife Trusts are important delivery partners and planners need to work corporately to help build these cross-sector pathways to delivery.

Delivery

Consideration of how policy objectives will be integrated and funded to deliver multi-functional land use is a key component of good planning for a better environment.

The degree to which planning authorities are actively involved in delivering environmental outcomes varies. In some areas, where there is a strong focus on housing and employment, and having an adopted Plan, the primary aim is often about giving weight to environmental concerns, not necessarily how those concerns will be addressed in practice. In other areas, the environment and climate change are integral to the Plan’s vision and growth strategy which tends to lead to a greater emphasis on delivery. This means that whilst the direction of travel for plan-making should be towards greater consideration of delivery, each area will have a different approach according to their circumstances.

The big challenge for LPAs in terms of delivering policy is how it is joined-up and funded, and the availability of land in the right place. Significant funding and capital investment is needed to deliver environmental enhancement and land use change at the pace and scale required to enable development and meet the targets in the Environment Act.

Planning authorities recognise the increasing pressures on land, the trade-offs between biodiversity, climate, energy, housing, and food production, and the need to consider multi-functionality. Simultaneously, the market for environmental goods is evolving, leading to a premium on some land, which in turn may affect development viability. As a sector, there needs to be a greater awareness and understanding of the finances of different land use decisions by all parties.

LPAs should consider how environmental infrastructure is planned, funded, and delivered alongside other forms of infrastructure. For example, several LPAs highlighted the challenges of delivering GBI beyond development boundaries to meet the objectives of an area-wide strategy. Whilst BNG and LNRS are expected to be important vehicles for identifying and securing funding for the GBI network, additional mechanisms will be needed as part of a coherent, strategic approach.

Planning at a ‘smaller than district’ area enables more effective integrated planning for the environment including provision of sustainable infrastructure, surface water management, and nature. High-level planning and place-making principles can set out a strategic approach to land use and natural capital, aligned with the Local Plan strategy and policy objectives. These plans can be incorporated into design codes.

Many councils are taking action themselves regarding their own estate. Some are finding ways of improving the environmental benefits of new and existing council housing, including BNG, surface water management and climate mitigation and adaptation. There is also evidence that councils are reconsidering their approach to land disposal in view of emerging markets for environmental goods.

This section provides a summary of the main report by asking what the implications are for plan-making. It is a mixture of what we perceive to be existing good practice and some ideas about how it could be done differently and is intended to promote discussion.

Local Plans will need to align more closely with the changing external legal and policy environment in a timely way, and be flexible and responsive to policies, plans and strategies that are being produced at different times. In practice, it means that plans which are regularly reviewed and prepared within a shorter time-frame are more likely to be consistent with the current legal and policy context.  

Local Plan timescales will also need to be increasingly responsive to local political and corporate priorities to keep pace with the appetite for change e.g., climate emergencies. Corporate plans and strategies for carbon, sustainability and the environment are instrumental in driving the agenda through planning. There should be a golden thread from corporate plans and strategies through the Local Plan to delivery.

The environment should be considered at the start of the Local Plan process as a key determinant of a spatial growth strategy which leads to the creation of sustainable communities in the right place. Some LPAs have suggested that an alternative approach to plan-making would start with a map, add designations, then GI and other environmental assets, and then consider how development can fit in.

The economic and social value of the natural environment should have more weight in the way local authorities plan for growth and investment, in effect, to level-up planning. There is an important role for planners to highlight the function and benefits of the natural environment for place-making, supporting growth and creating sustainable communities.

Policies for the environment should be framed within a broader narrative and it is becoming increasingly important to identify the synergies and linkages between policy objectives, be clear about relative priorities, and describe how policies should be delivered.

Planners will need to do more to engage proactively with different departments regarding interaction with environmental policy objectives e.g., biodiversity net gain. This might include exploring what is in the different service plans, gaps in policy and delivery, ways of working, cross-department governance, identifying leaders and champions etc.

Local Plans should support decision making by articulating a clear understanding of what they must, should and could do in relation to relevant legislation and policy. Policies should be complementary and linked as much as possible to optimise effective and efficient decision making and delivery.

For environmental policy themes, the Plan should seek to emphasise the impacts and opportunities for the environment and people. For example, air and water quality are important for a healthy functioning natural environment and the health and wellbeing of people.

Strategic planning at ‘wider than plan level’ can provide a coherent policy framework for Local Plans to consider what is important and how policy objectives can be applied in different contexts and locations e.g., a County GI Strategy.

Planning at a ‘smaller than district’ level enables more effective integrated planning for the environment.  High-level planning and place-making principles can set out a strategic approach to land use and natural capital for an area, aligned with the Local Plan strategy and policy objectives. These plans can be incorporated into Design Codes.

Some councils are undertaking a call for green sites to help identify where it is feasible to deliver environmental compensation and enhancement. Councils will need to start thinking about a more strategic approach to land, linked to the Local Plan map and Local Nature Recovery Strategy.

Green and Blue Infrastructure (GBI) is the dominant framework for considering environmental challenges and opportunities through the Local Plan. However, because GBI is not a ‘must do’, Local Plans will need to consider carefully how GBI priorities beyond the development boundary will be delivered as part of a coherent landscape scale network. Local Plans should ensure that there is a strong link between GI and mandatory Design Codes.

More meaningful monitoring is needed to understand whether planning is having a positive impact on place making outcomes and inform successive Local Plan reviews. This would require developing robust environmental evidence baselines, through mapping of GI and/or natural capital assets, and regular reviews.

Local Plan policy should be developed in conjunction with development management teams. This will help to ensure that policies deliver multiple objectives and high-quality places.

One of the biggest challenges for plan-making is how policy is funded and delivered in a joined-up way, and that the right land is available in the right place. LPAs should consider how environmental infrastructure is planned, funded, and delivered alongside other forms of infrastructure.

PAS would like to thank the following people for their valuable insights:

Bedford Borough         Gill Cowie, Sonia Gallaher, Kim Wilson

Bolsover District          Chris McKinney

Bracknell Forest          Julie Gil

Braintree District         Emma Goodings

Cornwall                      Rob Lacey

Carlisle City                 Chris Hardman, Richard Woods

Colchester City           Sandra Scott, Shelley Blackaby

Doncaster Council      Jonathan Clarke

Dorset Council            Anna Lee, Terry Sneller

Durham Council          Zoe Lewin, Mike Allum, Stuart Priestly

GMCA                         David Hodcoft

Essex County              Rich Cooke

Lancaster City             Maurice Brophy, Rebecca Richards, Diane Neville, Fiona Clark

Salford City                 Fiona Fryer, Will Horsfall, James Shuttleworth