National Planning Framework 4 – Call for Ideas

AEnvCoW Response Summary

As highlighted in the NPF4 briefing, our economy relies on our significant natural resources for food & drink, tourism, energy and financial services. Pressure from planning and development in terms of housing, renewable energy and infrastructure creates significant environmental risks, particularly during the construction phase.

The Association outlines its understanding of the challenges in the current planning system and the opportunities within NPF4 to better protect natural resources during development. Evidence suggests poor environmental performance during construction is common, with avoidable impacts on watercourses, species, designated sites and habitats. The Association considers these impacts likely to increase as climate change exacerbates extreme events and environmental pressures.

An Environmental Clerk of Works (ECoW) is defined as an environmental or construction professional with direct responsibility for monitoring compliance with environmental legislation, policy or mitigation. While sometimes required through planning consent, the role is inconsistently implemented, poorly understood and often under-resourced. The Association is concerned that mitigation identified in planning is not always delivered on site and that enforcement is limited, encouraging environmentally non-compliant practices.

NPF4 provides an opportunity to strengthen environmental protection by improving the effectiveness of the ECoW role. The Association supports clearer scope, appropriate resources and reporting mechanisms, independent appointment and stronger regulatory oversight to improve accountability and environmental performance during construction.

Without clearer definition and implementation, environmental commitments made at planning stage will continue to be undermined. Embedding effective monitoring and accountability within NPF4 would help protect natural heritage, natural resources and biodiversity while supporting responsible development.

pdf National Planning Framework 4