New Environmental Plans Could Speed Up Infrastructure Projects

Government-backed Environmental Delivery Plans (EDPs) are being introduced to manage the ecological impacts of developments, such as housing and nationally significant infrastructure projects. Natural England, a public body sponsored by the Department for Environment, Food & Rural Affairs (Defra), is tasked with planning and delivering these conservation projects. The initiative, along with the Nature Restoration Fund and an associated levy, was established by the Planning and Infrastructure Act 2025.

Streamlining Development and Conservation

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The government states that EDPs are evidence-based plans designed to address specific impacts of development on sites or species. Georgina Dowling, Stantec's national lead for environmental planning and assessment, explained that the concept allows developers to pay a flat rate, with Natural England then responsible for delivering the necessary mitigation. This approach aims to discharge legal obligations related to specific environmental impacts.

Shen Neville-Clarke, Greenshank Environmental's director for NSIPs and major projects, highlighted current challenges where numerous developers compete for limited mitigation land, driving up costs and causing delays, citing issues in areas like the Solent and the Norfolk Broads. EDPs are intended to provide a strategic, catchment-wide approach to ecological needs, involving habitat creation and changes to farming practices, funded by developers paying a levy. Neville-Clarke suggested that this could lead to better environmental outcomes and strategic-scale restoration rather than fragmented small schemes.

Proponents suggest that EDPs could reduce planning friction by allowing developers to discharge obligations through the levy, potentially accelerating the consenting process for large infrastructure projects by shifting the Habitats Regulations Assessment (HRA) responsibilities to Natural England. However, Neville-Clarke also voiced concerns, noting that environmental standards are currently vague, a financing gap exists, and there is no precedent for infrastructure-scale projects. He warned that the new system might prove worse than existing methods.

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Expert Concerns and Potential Shortcomings

Neville-Clarke expressed skepticism about the effectiveness of some proposed EDP measures, suggesting that many impacts might be included without clear, quantifiable benefits for water quality, potentially leading to "taxpayer-funded greenwashing." He raised concerns about funding if projects fail and the possibility of developers polluting before paying the levy, suggesting the system could become unconstrained.

David Thomson, Pell Frischmann's sector director for environment, who identifies as "very pro-development," sees EDPs as a potentially good solution for linear infrastructure and other large developments, particularly where issues like great crested newts are involved. He noted that EDPs could eventually cover other protected species, avoiding site-specific assessments. However, Thomson cautioned that other planning requirements, such as those under environmental impact assessments (EIAs) and HRAs, would still apply if not covered by an EDP. He added that EDPs might not significantly shorten project programmes unless they address a specific issue that saves substantial time.

Dowling echoed this sentiment, stating that EDPs are unlikely to provide a universal solution for NSIP developers seeking significant programme acceleration, but rather one of several tools available. Both Dowling and Neville-Clarke indicated that EDPs are currently in an early, research-oriented stage, with a significant taxpayer-funded R&D programme underway to determine which ecological impacts should be covered. Developers will need to compare their project's specific impacts against what an EDP covers, pursuing private mitigation for any unaddressed impacts.

Thomson pointed out that while EDPs are currently voluntary, there is potential for some to become compulsory. The ultimate impact of EDPs on the infrastructure sector, according to Dowling, will depend on the volume of plans Natural England brings forward.