Read more about the consultation responses below.
Biodiversity Net Gain: Brownfield Exemption Consultation
The Landscape Institute supports biodiversity net gain (BNG) as a strategic tool for nature recovery – not a site-specific checklist. While we understand the government’s ambition to unlock housing delivery, we have significant concerns about the proposed exemption from BNG for brownfield residential development. As currently drafted, the definition is too broad; the 75% hard-surfacing threshold is open to gaming, and the 2.5-hectare area exemption would capture the majority of England’s brownfield pipeline. This would severely limit the capability of BNG to enhance nature in England.
Analysis, part sponsored by the LI, suggests the consequences could also fall hardest on the most deprived communities, where brownfield development is concentrated and access to nature is already most limited. This would result in such future residents missing out even more on the health, cooling and biodiversity benefits that green infrastructure provides.
We recommend retaining the 10% BNG target, using established ‘previously developed land’ (PDL) terminology, mandating Open Mosaic Habitat screening, and tying any off-site mitigation to local green infrastructure strategies. We also urge government to publish a statutory Equality Impact Assessment before proceeding.
Permitted Development Rights for Onshore Wind Turbines
The Landscape Institute supports the expansion of onshore wind as part of the net-zero transition, and we want to see it delivered well. However, we have concerns that the proposed permitted development rights framework for onshore wind turbines could remove the professional scrutiny that is needed to ensure turbines are sensitively sited.
We recommend that a simplified Landscape and Visual Impact Assessment (LVIA), aligned with Natural England’s National Character Area (NCA) profiles, be mandatory for every prior notification. We also suggest:
- Extending exclusions to include conservation areas and the settings of National Parks and National Landscapes (with a minimum 2km buffer).
- Replacing ‘curtilage’ with ‘land holding’ to help prevent estates from inadvertently creating informal wind clusters without strategic assessment.
- Stronger guidance on preserving heritage settings, hedgerows and habitats during cabling works.
- Clearer decommissioning conditions requiring full infrastructure removal and ground reinstatement.
Image: Coastal Planting in Autumn, Urban Green © Nick Harrison.
