Consultation Responses

Please find below the society’s response to consultation documents:

1. The society responded to the Law Commission’s consultation on Conservation Covenants in June 2013 and welcomed the opportunity to respond to this consultation. One of the society’s main concerns is to ensure that the public will benefit from any conservation covenant and have access to land that is the subject of such a covenant. Read the society’s full response on Conservation Covenants..

2. The society welcomed the 25 Year Environment Plan but metrics and indicators must be clear and deliverable otherwise the ambitions of the Plan will be weakened. It is vital that everyone has access to high quality natural green space to contribute to their well-being as well as mental and physical health. This consultation response relates only to the metrics relevant to the core interests of the society. It is important that the indicator framework is kept under regular review so that it continues to be relevant and provide the best ways of assessing progress. Read the society’s full response on
Measuring environmental change – draft indicators framework for the 25 Year Environment Plan.

3. The revised National Planning Policy Framework 2018 (NPPF) does encourage wider environmental Net Gain and includes the mitigation hierarchy but in general the planning system is failing to help to enhance the environment and the Defra biodiversity offsetting pilot had mixed results. It is not clear how net gain would help deliver the goals of the 25-year environment plan, particularly in relation to Nature Recovery Networks. Read the society’s full response on the Net Gain Proposals.


1. In May 2018 the environment secretary Michael Gove launched a review of the national parks and areas of outstanding natural beauty (AONBs), to be led by author and journalist Julian Glover. Our national parks and AONBs have stood the test of the last 70 years. They have retained their distinction and special qualities, their spectacular and breath-taking beauty, peace, wildness, and ability to inspire and to refresh. The society believes that their purposes still hold good providing an appropriate balance between conservation and recreation, tempered by the Sandford principle. Read the society’s full response to the
government’s review.

2. The society responded to the Welsh Government’s consultation on its proposals for future agricultural policy. The society contended that public benefit should include public access, whether by paths or open access to land (freedom to roam), because such assets support local economies, and improve people’s health, well-being and safety. Public access also helps to connect those who use paths for whatever reason (non-motorised transport, for health reasons and for recreation) and those who own and manage the land. Naturally we advocate that the public exercise its rights and freedoms responsibly and with respect for landowners, land managers and other users. Read the society’s full response on Support for Welsh farming after Brexit.

3. Our membership includes those who exercise rights of common and owners of common land. The society is represented on the National Common Land stakeholder Group advising the Department for Environment and Food and Rural Affairs on the Commons Act 2006. The society campaigned during the passage of the Commons Bill through parliament for local authorities to have a duty to act on encroachments and unlawful activities on common land and we cautiously welcome the proposal to create byelaws to try and deal with adverse activities on SSSIs. Read the society’s full Response to a Consultation on the proposed scope and application of Natural England’s SSSI byelaw-making powers.

4. The society’s response to a Defra consultation on environmental principles and accountability for the environment.

5. The society submitted written evidence to the House of Lords Select Committee on the Natural Environment & Rural Communities Act 2016 (NERC), focusing in particular on the role of Natural England. Read the society’s briefing document for the House of Lords NERC debate.

6. The society welcomed the opportunity to respond to the National Planning Policy Framework (NPPF) draft text consultation. We were concerned that the draft text focused primarily on housing development and recommended that there should be requirements to create places with access to open spaces which benefit public health and well-being. Green infrastructure should be planned at the outset. Read the society’s full response to the NPPF consultation.

7. The society welcomed the opportunity to respond to the Consultation on Health and Harmony: the future for food, farming and the environment in a Green Brexit but believes that the online Citizen Space tool is an inflexible tool for that purpose, and considers that the questions posed in the consultation paper are sometimes an unhelpful distraction from the key issues.