The UK Government has announced a plan to build 1.5 million homes across the country by 2029, aiming to address England’s housing shortage. However, this initiative has raised concerns among environmental researchers and wildlife charities, especially as the government considers changes to environmental regulations.
Part 3 of the Planning & Infrastructure Bill, currently under debate in Parliament, proposes Environmental Delivery Plans (EDPs) and a Nature Restoration Fund (NRF) as new tools for managing development’s environmental impact. Under these plans, developers could contribute financially to the NRF instead of carrying out all mitigation measures themselves. Natural England would be responsible for designing EDPs, with approval from the Secretary of State.
EJ Milner-Gulland, an expert on biodiversity policy, commented on these proposals: “This sounds good in theory but researchers like myself worry that without proper safeguards, these proposals won’t actually deliver real benefits for nature. Assessing environmental impacts and appropriate mitigating action is a complex process; short-circuiting it runs the risk that nature-restoring activities are rushed, inadequate and ineffective.”
Milner-Gulland outlined several recommendations for improving Part 3 of the bill:
First, she emphasized that compensation should only be used as a last resort. The Mitigation Hierarchy—a framework established since the 1970s—prioritizes avoiding harm first, then minimizing impacts, restoring or rehabilitating environments, and only finally offsetting impacts if necessary. She warned that “as the Bill currently stands, there is no assurance that the mitigation hierarchy will be followed... This poses the risk that developers will be free to skip straight to ‘pay and build.’”
Second, she argued against conflating compensation payments with genuine nature recovery efforts: “Pooling compensation with public restoration budgets does not magically create extra nature unless the compensatory money paid into the fund demonstrably goes beyond replacing losses.” She called for transparency about how net gains for nature would be achieved.
Thirdly, Milner-Gulland highlighted that setting levy fees appropriately is crucial so they reflect actual ecological impacts: “Fees must be scaled to quantified impact using robust metrics and risk-based multipliers (to account for uncertainty, time-lags, likelihood of success).” She cited examples such as the Newt Conservation Partnership’s approach and reforms in New South Wales’s Biodiversity Conservation Fund which now restricts levy use to a last resort.
Fourthly, she advocated creating habitat in advance through banking systems to reduce delays and ecological risks: “Creating habitat before impacts occur reduces time-lags and makes sure that nature improvements are actually delivered.”
Fifthly, Milner-Gulland stressed planning at both national and local levels so communities benefit directly from ecological improvements near their homes.
Lastly, she pointed out challenges related to monitoring compliance due to limited capacity within local planning authorities: “Where developers state they will use approaches... it is essential that these are followed through and delivery is monitored and enforced. But this remains challenging due to lack of capacity within local planning authorities; this needs urgent investment.”
Milner-Gulland referenced Natural England’s district licensing scheme for great crested newts as evidence that coordinated strategic approaches can work: “This simple change - planning habitat creation upfront... has produced faster more certain decisions for developers and measurably better results for wildlife.”
She concluded by noting: “Nature itself... is complicated and context-specific. This means there can be no single approach to balance biodiversity improvements in one place with biodiversity losses in another.” While acknowledging both housing need and ecological protection as urgent priorities she added: “But strategic planning for both nature and people is possible if the evidence is acted upon.”
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