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





1. In February we responded to the government’s consultation on the National Planning Policy Framework (NPPF), criticising its failure to tackle the urgent nature and climate crises, in particular by offering no permanent protection to public open space. The society sets out what it would like to see in the NPPF.



1.  In April the society sent comments on the government’s response to the landscapes review.  We also supported the comprehensive submission from the Campaign for National Parks, of which we are a member, and sent headline points jointly with British Canoeing, the British Mountaineering Council, and the Ramblers.

2. In May the society responded to the consultation by Defra on the Nature Recovery Green Paper. Read the document here.



1.  In October Wales Environment Link (WEL), of which the society is an active member, responded to the Welsh Government consultation on National Milestones and Indicators. The society acknowledged that measuring progress towards the 30x30 target by 2030 i.e. to protect 30% of all land and sea, would be a challenge.

2. The society responded to the London Mayor's consultation on its Public London Charter calling for developers and landowners in the capital voluntarily to dedicate open spaces as town greens, to protect them in perpetuity and give local people rights of recreation there.

3. Agriculture (Wales) white paper - in responding to this consultation, we have a particular interest in promoting public access to the countryside through Wales’s network of public paths and rights of access, and in securing better management of common land to reflect the many public goods which it provides.

4. In March the society responded to the Ministry of Housing, Communities and Local Government consultation on National Planning Policy Framework and National Model Design Code Consultation proposals calling, amongst other things, for pro-active measures to level up open space provision for all.



1. Wales Environment Link (WEL) of which the society is an active member responded to the Welsh Government consultation for a Clear Air Plan for Wales. The society highlighted the need for a definitive policy for the protection of open and green spaces. Read the WEL response in full.

2. In July, the society responded to the consultation by Defra on Environmental Land Management: policy discussion. Read the discussion document in full here.


3. The Minister for Housing and Local Government, Wales requested ideas on how we should support future post-Covid recovery and reconstruction in Wales - read our July response here.

4. Defra invited feedback to it's Financial Assistance Statutory Instrument. We criticised as weak and ineffective the government's proposals for monitoring and enforcing compliance with agricultural grants. Our August response is available to read in full here.

5. The consultation to inform Defra's new England Tree Strategy closed in September. Our response focused on how the aim to 'engage more people with trees and woodlands' could be achieved, in harmony with our strategic goal to promote public access through England's network of public rights of way and public rights of access, while ensuring that registered common land and the rights of commoners are not compromised. Read our response in full here. 6. In October we responded to the Ministry for Housing, Communities and Local Government consultation on the reform of the planning system in England. Key areas for concern included unsuitable and unsustainable development as a result of an over simplification of the planning process and that the protection of local open spaces, seen to be so valuable during lockdown restrictions, would be weakened in areas designated as 'Growth' and 'Renewal'. Read our response in full here.


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.

8. In February 2018 the society responded to the Planning Law in Wales, Law Commission Consultation Paper:Law Commission number 233.

9. With particular expertise re: Green Infrastructure and Natural Environment, Chapter 8 of the December 2017, draft London Plan, the society responded in detail to this section in February 2018 and confirmed their support of the response submitted by the Ramblers.

10. The society submitted an online response in January 2018 to plans to restrict the ability of a person to register land as a town or village green simply for the purpose of frustrating or preventing lawful development in Wales.

11. A summary of the society's recommendations to the Environment, Food and Rural Affairs Committee inquiry on the Agriculture Bill submitted in October 2018 can be read here.


1. In September 2017 the society responded to the Welsh Government consultation document 'Taking Forward Wales' Sustainable Management of Natural Resources'. 2. The Department for Communities and Local Government ran a consultation in February for the Housing White Paper re: Fixing our broken housing market. Read our response here. 3. The society submitted a response in July 2017 to the Department for Communities and Local Government Running Free consultation on preserving the free use of public parks. 4. Also in September 2017, the society made some written recommendations to the House of Lords Select Committee on the Natural Environment and Communities Act 2006. 5. The Department for Communities and Local Government received the society's submission to their inquiry on public parks, on 28 September 2017. 6. The society responded to the Joint Technical Consultation Environmental Impact Assessment (EIA) (planning changes to regulations on forestry, agriculture and water resources, land drainage and marine works) dated 14 December.


1. A submission to the London Assembly investigation into the management of London's Green Spaces was made in December and included an analysis of the advantages and disadvantages of alternative management models such as privatisation, outsourcing and mutualisation.