IEMA responds to Government’s Planning Reform Working Paper on Development & Nature Recovery

IEMA has submitted its response to the UK Government’s Planning Reform Working Paper, which explores new strategic approaches to balancing development and nature recovery. Here, Rufus Howard, IEMA’s policy and engagement lead for impact assessment, outlines the Institute’s key recommendations and concerns.

The Importance of Strategic Planning for Nature Recovery

Integrating environmental protection with planning policy is essential for achieving sustainability goals. IEMA welcomes efforts to enhance environmental outcomes while streamlining planning processes. However, the proposed Delivery Plans require careful development to ensure they effectively support both nature recovery and a workable approach to planning and development control.

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IEMA’s existing guidance on environmental assessment, including Environmental Impact Assessment (EIA) and Biodiversity Net Gain (BNG), has played a critical role in shaping best practices. Drawing from this expertise, IEMA has provided key recommendations to strengthen the proposed model. 

Key Recommendations from IEMA Experts

On Delivery Plan design:

  • Evidence-Based Policy: Conduct and publish research to justify system changes and ensure the new approach is effective.
  • Integration with Existing Frameworks: Clearly define how Delivery Plans align with Local Plans, SEA, LNRS, BNG, EIA, HRA, and any future EORs.
  • Core Environmental Principles: Uphold precautionary measures, polluter pays, proximity, and rectification at source. Apply the prevention principle first, using the mitigation hierarchy to prioritise avoidance before compensation.

On Delivery Plan development:

  • Expert-Led and Transparent Process: Require qualified professionals to develop Delivery Plans, with public consultation and strategic impact assessment.
  • Resource-Backed Implementation: Ensure sufficient funding and that Delivery Plans are operational before projects proceed to offset impacts effectively.
  • Strong Governance and Oversight: Maintain transparency with accessible data on effectiveness and environmental outcomes.

On Delivery Plan implementation:

  • Site-Specific Assessments: Ensure local environmental and community impacts are fully evaluated, as many features are location-dependent.
  • Flexibility for Developers: Allow developers to choose between direct mitigation or contributing to a broader Delivery Plan, depending on which is more effective.
  • Adaptive Management: Ensure Delivery Plans respond to monitoring data and incorporate evidence-based improvements.

Potential Challenges and Areas for Improvement

While Delivery Plans may simplify developer obligations, concerns remain regarding their effectiveness. Key risks include:

  • Loss of site-specific environmental scrutiny: A shift towards strategic mitigation could weaken local environmental protections.
  • Uncertain implementation and funding: The effectiveness of centralized nature recovery mechanisms remains untested, and resources must be secured before implementation.
  • Disconnection from affected communities: The benefits of nature restoration should be distributed to the areas impacted by development, not just through generalized offsetting.

Impact Assessment’s Role in Sustainable Development

IEMA continues to advocate for a robust, evidence-based approach to planning reform. The role of impact assessment in shaping policy cannot be overstated—it ensures that development decisions account for long-term environmental and social impacts.

As the government progresses with its reform agenda, IEMA will continue to engage with policymakers, industry stakeholders, and environmental professionals to promote a system that works for both development and nature.

For more details on IEMA’s response, visit iema.net or contact [email protected].

To read the IEMA consultation response in full click here.

To learn more about the IEMA EIA Quality Mark click here.


Published by:
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Rufus Howard FIEMA

Policy and Engagement Lead

Dr Howard is the policy and engagement lead for Impact Assessment at IEMA and a leading professional in EIA, with two decades of international experience across renewable energy and major infrastructure. A Fellow of IEMA and Chartered Environmentalist, Rufus holds degrees in Biodiversity Conservation and Environmental Law, and a doctorate in Management. A trusted advisor, Rufus has directed environmental projects for major organisations such as the World Bank, The Crown Estate, Natural Resources Wales, the EBRD, Statkraft, Orsted, National Grid, and the Environment Agency. Rufus lives in Kent with his wife and three daughters and enjoys walking in nature, cooking, music, kayaking and archery.