Georgina Holmes-Skelton, Head of Government Affairs, National Trust – Written Evidence (LUE0039)



With our staff, members, volunteers and supporters, the National Trust is the biggest conservation charity in Europe. We protect and care for places so people and nature can thrive. Many millions share the belief that nature, beauty and history are for everyone. So we look after the nation’s coastline, historic sites, countryside and green spaces, ensuring everyone benefits. For everyone, for ever.



Introduction and summary


The National Trust welcomes the Committee’s inquiry into land use in England, which comes at a time when the competing challenges and pressures on land use have never been clearer. As a major landowner and conservation charity, we appreciate the complexity around planning and decision making for land use and the need to balance varying local and national needs from the finite land available to us. In this submission we have answered those questions that we feel most able to offer a substantial contribution towards the committee’s inquiry, based on our expertise and experience.


Key points:




Pressures and challenges


1. What do you see as the most notable current challenges in relation to land use in England? How might these challenges best be tackled? How do you foresee land use in England changing over the long term? How should competing priorities for land use be managed?


The greatest current challenges are the decline in biodiversity, and the need to store more carbon on our land. We also need to address the inequality of access to green space that currently exists, which has significant impact on health and wellbeing. The land use change required to tackle these crises will mean significant changes in where, what and how we grow food.


The twin crises of climate change and biodiversity loss represent the biggest challenges facing the places that the National Trust cares for, reflecting wider national, and indeed global, issues that require us to examine the way we use our land as a nation. Forty-one percent of all British wildlife species have declined since 1970 and 15% of species in Great Britain are threatened with extinction.[1] This decline has many causes, but they include impacts from development and land management changes in recent decades. The welcome government ambition to reverse biodiversity decline, deliver against commitments such as protecting 30% of land for nature by 2030, and take advantage of opportunities to grow natural capital and wider ecosystem services highlighted by the Dasgupta report[2] will necessitate different approaches to land use and management.


Land use has an important role to play in relation to climate change. At least 80% of peatland habitats, one of our most important land-based stores of carbon, have been lost or damaged in the UK.[3] Agriculture, land use and peatlands accounted for 12% of all UK greenhouse gas emissions in 2017, and the Climate Change Committee (CCC) has found that reaching net zero will require significant changes in land use across the UK. This includes increasing tree cover from 13% to 18% by 2050, restoring at least 50% of upland and 5% of lowland peat.[4] The way that we use land will also be relevant to our need to adapt and build resilience to the impacts of climate change, with issues such as flooding, excess heat, or drought affecting human infrastructure and ways of life, as well as nature.


There are other challenges. Our founders were passionate about the human need for outdoor spaces and experiences, and the experience of the coronavirus crisis highlighted the very real difference to people’s lives that access to green space and nature can bring. Some inner-city parks experienced close to a 300% increase in visits in Spring 2020 compared to 2018, and we experienced unprecedented visitor numbers to urban fringe sites. Unfortunately, Covid also exposed deep inequalities in such access to green space – research by Vivid Economics and Barton Wilmore, commissioned by the National Trust and partners, found 295 deprived neighbourhoods had no trees or accessible green space, affecting 440,000 people.[5] This has serious implications for physical and mental health of communities most at need.


The historic and natural aspect of our land is indivisible, as all of our land has been shaped by mankind’s activity over the past 10,000+ years. The importance of the historic environment and the need to make the most of the heritage assets and sites of all kinds across the UK cannot also be understated – from buried archaeology to the grandest historic estate. Every place has a unique local heritage that can transform communities and make people proud of their localities. Heritage underpins the uniqueness and character of our landscapes, fosters a sense of place and can drive positive social and economic change, supporting tourism, education, and community wellbeing. The historic environment is also a crucial aspect of the diversity and function of our landscapes, with historic features often sitting alongside or as a part of the historic ecology of land, actively playing a part in natural ecosystems, including as homes for nature. Seventy-eight per cent of Scheduled Ancient Monuments sit on agricultural land for example. Finally, sensitively retrofitting and reusing historic buildings and structures can help both mitigate and adapt to the impacts of climate change – and contribute to local housing, or commercial activity. These features therefore need to be cared for, and actively considered as part of the way that we manage and get the best use out of our land.


Around 80% of the National Trust land is farmed in some way. This includes farming by tenants with Agricultural Holdings Act or Farm Business Tenancies, by commoners with grazing rights, those with annual grazing licences and by some of our own teams. We have long standing relationships with those working on our land and aim to work together constructively for everyone’s benefit. For example, we already try to encourage nature and climate friendly approaches to agriculture. We recognise that a primary driver for most of our tenants and commons rights holders is their passion for farming and the quality of the food they produce. We respect and value this passion and their role in helping to feed the nation. We also recognise how adaptable farmers are, having helped the UK respond to previous national crises very successfully: for example, enhancing food production to make Britain more self-sufficient in the mid-twentieth century. The need to produce healthy high-quality food will remain a key driver of land use in the UK. However, the future of farming is bound up with the future of the natural environment, and so change is needed again, at a fast pace, to respond to the new crises of climate change and biodiversity loss and to enhance the sustainability and resilience of healthy food production.


There is also a need for housing, and a range of forms of vital infrastructure that communities need to support travel, energy, and access digital and other public services. Some of these needs are changing in a way that will impact on land use – for example, the transition to renewable energy sources which will require more land for renewable energy. Growing urban populations and changing modes and methods of transport will also create new pressures.


Balancing national level ambition and need on these issues against individual and local concerns is the challenge at the heart of taking a strategic approach to land use, and getting that balance right is certainly not straight forward. But the clear consensus evidenced by the work of the CCC,[6] Dasgupta[7] and others,[8] is that the balance at the moment is not the right one when it comes to nature and climate in particular, and this needs to be addressed.


A common thread that we see between these different pressures is the need to create sustainable, high-quality places, whether urban or rural, that support the needs of people and nature together. Every place has a different mix of opportunity and challenge – some places present the best opportunities for nature-based climate solutions, for example, that can also help address need for better local green space. Others may be better suited to prioritising nature-friendly food production or have opportunities to adapt under-used historic buildings into high quality housing with brilliant green and blue infrastructure. Conversely making the wrong choices, for example planting substantial amounts of non-native tree species in inappropriate locations, such as on peaty soils, could lead to adverse outcomes for nature and people.


However, individual choices and approaches at a local level may not deliver the change needed to address the challenges at hand, and at present it is hard to know whether the Government’s existing policy and funding translates into action that will deliver on the goals we have set. A land use strategy set at a national level could provide greater clarity over the contribution that land is expected to make to these different outcomes overall, articulate the scale and nature of change needed to reach net zero by 2050, halt the decline of species by 2030 and meet other targets established under the Environment Act, and address other imperatives, such as housing need. On this basis central government can then set top level priorities for land use and assess whether the structure and scale of its policy and funding interventions is sufficient to drive the needed change in practice. Many of the needed mechanisms are already in development, such as ELM schemes and Local Nature Recovery Strategies, but further changes to these, or additional policy or legislative measures may be needed. This could include anything from changes to the NPPF, statutory duties or obligations on public bodies, complimentary national or sub-national strategies for individual elements of land use, or revised or new structures or remits for advisory or arms-length bodies. There may also be a need for further resource and support for local authorities to embed approaches to place making within local plans and broader decision making which address wider social and economic needs through, or in concert with, actions to enhance nature and heritage and address climate change.


2. What are the key drivers of land use change which need to be planned for, and how should they be planned for? What is the role of multifunctional land use strategies in implementing these plans?


3. How might we achieve greater and more effective coordination, integration and delivery of land use policy and management at a central, regional, local and landscape level?


The main drivers of changes to land use in England lie in a combination of economic factors, planning, fiscal and policy incentives or disincentives and the decisions and actors of key stakeholders. The local planning system acts as a framework for decisions specifically around development, and therefore local authority decision-making, and regulatory and legislative frameworks also have an important role to play. Local Nature Recovery Strategies will theoretically offer a valuable tool to assess and map spatial opportunities for nature, which should collectively add up to a network of sites which can provide the habitat and nature enhancement needed to meet national targets for reversing species decline and enhance biodiversity.


Biodiversity Net Gain (BNG) also offers a potentially powerful way for local authorities to drive enhancements to biodiversity in association with development and the planning system – but only if implemented well, with evidence-led targeting of funds, a robust approach to securing additionality for nature, and monitoring and enforcement over the 30-year requirement. If poorly implemented, BNG risks enabling damaging development to take place, with little or no biodiversity gain achieved in practice, or small gains quickly lost. Much of its success or failure will ultimately fall to the judgement and capacity of local authorities.


Government arm’s length bodies such as Natural England, Environment Agency, and Historic England are important stakeholders in terms of their regulatory and advisory functions, and play an important bridging role between national level policy and individual landowners, managers or farmers – who are at the forefront of making choices and putting into practice actions that effect land use change on the ground. Supporting and encouraging these groups will be critical in achieving those multiple outcomes that we need from land; for example, there are opportunities to embrace and explore innovation and new ways of farming like agroforestry, paludiculture, as well as managing land directly for ecosystem services and goods such as carbon.


New policy mechanisms and funding streams arising from Environmental Land Management, BNG, lottery and other central funds offer significant opportunities to move further and more quickly towards more climate and nature-friendly approaches to land uses (alongside other benefits such as food production, public access, flood management etc). Public funding needs to deliver the greatest possible value for money in terms of generating real gains for biodiversity, climate and other environmental outcomes. This will require targeting of funding schemes, with advice and support, so that famers and land managers use public money to support actions that will deliver the best outcomes for their businesses and to achieve maximum public benefit.


This is a complex picture of competing priorities, drivers and stakeholders at different national and local levels and it will be challenging for a single strategy to address this complexity holistically. There are a number of broad principles that we think would be helpful to guide the creation of any multifunctional land use strategy that addresses the challenges outlines in Question 1, and taps into those drivers of change to ensure that delivery follows ambition:


1. A long-term England-wide strategy for land use would need to articulate a plan for how land use will contribute to delivery of existing national-level statutory targets and policy objectives. It must integrate policy interventions and funding streams across Whitehall (including planning, environment, climate and infrastructure) to ensure they are working together to deliver against objectives for different uses of land, including:


         climate mitigation and adaptation

         natural resource management

         people (including housing, access to nature and green space, recreation, health and wellbeing)

         transport and energy infrastructure

         farming and sustainable food production

         the conservation and opportunity of cultural landscapes and the historic environment


2. There needs to be a line of sight from national strategy and ambition through local plans to individual land holding/farm plans to ensure national strategy can be delivered at a sub-national level. Issues to consider include:

         how to enable change take place at sufficient scale to work across whole landscapes or river catchments.

         how to take a holistic approach that explicitly seeks to deliver multiple outcomes and balance a range of competing priorities, and deliver high quality place making at a local level.

         How to design the strategy collaboratively, with input from a range of stakeholders, including local government, statutory bodies, funders and landowners.

         whether explicit connections need to be built into local plans for nature recovery, housing, infrastructure and economic development and into local planning.


3. Public funding streams (including ELM and other grant funding) need to be aligned and sufficient in scale to deliver on the ambition for public goods delivery set in the national strategy, backed by a robust evidence base.


4. Public bodies are key to successful implementation and need the right resources and expertise to deliver in practice. This includes ensuring:

         Local authorities and other key public bodies have access to the right ecological, landscape and heritage expertise,

         All key public bodies (including local authorities, ALBs, National Park and AONB Boards, etc) have the resource needed to make the right decisions, and implement new responsibilities and schemes such as biodiversity gain and local nature recovery strategies in such a way as to deliver transformative change.    

         Farmers and land managers are supported and have access to the expertise and advice they need to understand and evaluate the value of what they are looking after in ecological/ landscape/ heritage terms, and adapt their business models, innovate, and take advantage of appropriate ELM and other funding schemes.

         The right data quality and systems to support delivery and monitor progress and outcomes, at both local and national scales.  


5. Developers and private sector investment both need to contribute to the delivery of the multiple outcomes and targets outlined in the national strategy, with effective frameworks (for example on Biodiversity Net Gain and ELM) that ensure private funding delivers genuine additionality for nature, climate or other public goods, and contributes effectively both towards national goals and local needs and plans.


6. The approach taken at every level must be adaptive:

         Our natural and historic environments are not fixed and as climate changes and human needs and lifestyles shift to respond to new ways of working and living, our planning system, infrastructure networks and strategic approach to land use will also need to accommodate change over time.


Farming and land management


4. What impacts are changes to farming and agricultural practices, including food production, likely to have on land use in England? What is the role of new technology and changing standards of land management?


We are losing natural habitats and wildlife too fast to afford low ambition in future farming policy. One in four UK bird species are now on the red list of threatened species and 26 per cent of mammals are at risk of disappearing altogether. Rivers are in deep trouble too: in England, only 14 per cent are in good ecological shape, largely due to diffuse agricultural pollution. These losses and impacts cannot be reversed easily without a fundamental shift in agricultural policy which sees farming and the environment treated as mutually beneficial and interdependent.


However, there is significant opportunity to create more resilient farming and landscapes, through ending the reliance on fossil fuel inputs and embracing environmentally sustainable approaches, such as greater heterogeneity of cropping and new techniques such as agroforestry and paludiculture. But farmers will need support and advice to put this into practice.


We are currently at the beginning of the agricultural transition in England, which will see the gradual phase-out of direct subsidies and introduction of the new Environmental Land Management (ELM) system up to the end of 2027. The Government has committed to maintaining the same level of agricultural funding up to 2024 and has outlined its plans for the bulk of any future funding to be spent on ELM from 2028. If designed and implemented well, this will achieve the Government’s ambition, as set out in Health and Harmony in 2018, to move to a new approach of public money delivering environmental public goods, such as repairing the uplands to store carbon, protecting rivers from pollution and planting hedgerows. The National Trust strongly supports the premise that the new ELM schemes must deliver public goods for public money. This would ensure better value for money to taxpayers than the former EU Common Agricultural Policy (CAP) support system, recognise the important interplay between farming and nature, landscape and heritage, and help farming play its part in meeting the 2030 nature and 2050 climate goals.


During the first phase of the transition to 2024, we anticipate many farmers will be adjusting to the loss of subsidies and preparing their businesses to take advantage of the new ELM schemes as they begin to be rolled-out, from engaging in the Farming in Protected Landscapes scheme, Farming Resilience Fund and initial piloting and early roll-out of the various ELM schemes. Many more farmers are also entering into the existing Countryside Stewardship Scheme as a stepping-stone to ELM, preparing themselves for a new approach to farming policy and land management.


There will be others who see opportunities arising from the Farming Investment and Innovation Fund to restructure and improve their farm businesses, buying new equipment and technology that can help mitigate climate change or improve water use efficiency, amongst other issues, as part of a continue focus on food production whilst adopting a more environmentally sustainable approach.


But there will be some who choose to retire from farming altogether, taking advantage of the new lump-sum exit scheme and making way for new entrants who may wish to embrace the new environmental opportunities afforded by ELM and emerging private markets alongside food production. These could also be of interest to larger commercial enterprises looking to consolidate and expand their operations.


Whatever choice famers make will see a change in land use and management, from work to improve and enhance the environment, to consolidating and intensifying food production.


For many farmers, these choices will be heavily influenced by the nature of their land, their existing knowledge, skills and farm infrastructure, economic returns achievable from relevant enterprises, and financial and regulatory signals from government as representing what society is demanding of the sector. Food security concerns, coupled with unprecedented inflation and volatility of feed, fertiliser and energy prices are likely to have a bearing on how these choices are made, with the greatest impacts likely to be seen in 2023. However, we need to be cognisant of the Government’s 2021 UK Food Security Report findings that environmental degradation and climate change pose the greatest medium to long term risk to food security. A healthy and thriving natural world is essential for supporting a resilient food and farming system. We must therefore continue to advance a holistic agenda which seeks to support a farming system that can produce food, whilst restoring and improving nature, and helping to mitigate and adapt to climate change.


Further intensification of food production in the UK will have consequences in terms of our dependency on other countries for input imports, exacerbating uncertainty for farmers and resulting in less resilient farm businesses. Moves to increase production in England will do nothing to address food prices, which reflect economic markets and conditions globally. We recognise the genuine concerns regarding fertiliser, feed and other input costs, and the knock-on effects for cropping choices (e.g., feed over milling wheat). However, this is fundamentally a market response, that would have occurred irrespective of policy reform or the phase-out of direct subsidies.


We firmly believe Defra can help farmers navigate this situation and use ELM, especially the new Sustainable Farming Incentive, to support a transition to more nature-friendly, regenerative and agroecological approaches to farming, which should reduce reliance on bought-in inputs and increase resilience in the medium and long term. Defra should also accelerate progress against the National Food Strategy independent recommendation for a rural land use framework, in order to get a better idea of trade-offs and synergies between food production, climate and nature.


Key to both of these recommendations is the need for a transition plan that clearly sets out a roadmap to 2028, establishing Defra’s goals for the agricultural transition, including the contribution to the 25 Year Environment Plan, Environment Act and Net Zero targets. Only then will we understand the impacts that changes to farming and agricultural practices are likely to have on land use in England, and the role of new technology and changing standards of land management.


5. What impact are the forthcoming environmental land management schemes likely to have on agriculture, biodiversity and wellbeing? What do you see as their merits and disadvantages?


We remain strongly supportive of the Government’s manifesto and 25 Year Environment Plan commitment to be the first generation to leave the environment in a better state than it inherited. Agricultural policy underpinned by the payment of public money for the provision of public goods, with the new ELM scheme as the cornerstone of delivering this approach, is in our view still the right vision.


As noted above, the Government’s agricultural transition plan needs to develop into a clear roadmap to 2028. This should establish Defra’s goals for ELM, particularly in relation to each scheme’s contribution to nature and climate targets, how each scheme will interact, not simply with each other but also other related policy areas (such as Local Nature Recovery Strategies), clarity on the process for how budget will be allocated and adjusted over time, and more information on what the future regulatory baseline will comprise.


There is a general lack of clarity over how delivery of nature objectives and goals for ELM will work alongside and with future ambitions around food production as well as with other environmental policy priorities such as Biodiversity Net Gain, or support for maintaining heritage and landscape (which ELM should have a direct role in delivering). We see a potential role for a land use strategy to help fill this gap.


There are aspects of ELM’s structural design as developed so far that we think could limit its ability to deliver for nature:


  1. Defra’s existing approach offering payments based on ‘income forgone plus costs’ is the only available basis for ELM payments at the current time, in accordance with WTO Green Box rules. However, this will ultimately limit the positive impact that ELM can have for both agriculture and the environment, especially where farmer uptake is likely to be affected by the attractiveness of other more advantageous and profitable opportunities from diversification and alternative land uses that could lead away from farming and environmental schemes as subsidies are phased out. Defra needs to continue exploring alternative outcomes-based payment approaches, including the potential to underpin ELM with natural capital principles, which may better reward farmers for the delivery of ecosystem services, especially where the value to society of an environmental outcome is measurable and quantifiable – for example carbon sequestration or flood risk mitigation.
  2. At present Defra has not publicly set out the specific goals that it is seeking to deliver through ELM, or how decisions will be made about targeting budget and spending on ELM schemes to achieve particular outcomes. We understand that within Defra four criteria have been identified as part of a “strategic specification” for ELM – affordability, attractiveness, deliverability and environmental outcomes. However we do not know how these criteria will be weighted or contribute to the goals that Defra is hoping to achieve. Without sight of these guiding objectives and method of prioritisation or an understanding of policy interactions, expected outcomes based on scheme design and level of farmer uptake, and therefore their likely contribution to meeting the targets of the 25 Year Environment Plan and Net Zero, it is difficult to say what impact the forthcoming ELM schemes are likely to have on agriculture, biodiversity and wellbeing.
  3. It would be helpful to understand what efforts are being taken by government to ensure that domestic agriculture policy and environment schemes are not undermined by future trade deals, i.e., farmers participating in ELM are not disadvantaged by food imports not meeting our higher environmental and animal welfare standards.


Beyond the framework within which ELM will operate, all three ELM schemes offer significant potential for agriculture, biodiversity and wellbeing, if designed, delivered and monitored well. Whilst there is a concern that the new Sustainable Farming Incentive 2022 scheme is not ambitious enough, we do recognise that this is a first step in rolling out a new ELM scheme – but the SFI scheme must evolve over time as the farming sector reaches a new level of environmental sustainability. This will assure the continued delivery of good value for taxpayers’ money.


Equally, the Local Nature Recovery (LNR) scheme offers significant potential for the role it will play in species recovery and habitat restoration, as part of Local Nature Recovery Strategies, and being the primary instrument for achieving national nature and climate goals. Fundamentally we feel that LNR needs to be much more ambitious and integrated with farm businesses than its predecessors, Environmental Stewardship and Countryside Stewardship. Nature-friendly farming, where food production and nature come together as part of a holistic approach, needs to become the norm.


In addition, we would like the Government to clarify:


Nature, landscape and biodiversity


6. What do you see as the key threats to nature and biodiversity in England in the short and longer term, and what role should land use policy have in tackling these?


7. What are the merits and challenges of emerging policies such as nature-based solutions (including eco-system and carbon markets), local nature recovery strategies and the biodiversity net gain requirement? Are these policies compatible, and how can we ensure they support one another, and that they deliver effective benefits for nature?


We’ve addressed these questions together, and offered brief views on all the emerging policies mentioned. All have potential benefits and negatives, but fundamentally there are still challenges in implementing all in a way that brings genuine benefit for nature, climate and people. We also note that there is still work to do to ensure these policies are aligned, and working effectively together to deliver the outcomes needed, which is where an England-wide land use strategy could add value.


The UK National Ecosystem Assessment 2011 stated that the key drivers of change are habitat modification as a result of change in land use, over-exploitation of terrestrial and marine resources, and air and water pollution.[9] Lawton, in his ‘Making Space for Nature’ report, found that species’ habitats were largely in poor condition, and the spaces that were working for nature were too isolated to support thriving populations. He concluded that ‘the remaining network of places for nature was not sufficient to either halt the loss of biodiversity or to meet the needs that we have of our natural environment’.[10] The Trust considers that this analysis is still correct. If we want nature to thrive – and if we want to receive the economic and social benefits that this delivers – we must give it space to prosper.


However, climate change also presents an existential threat to our natural environment, causing impacts such as the direct loss of habitat or nesting sites as a result of coastal erosion, flooding or storm damage; changing temperatures and seasonal patterns impacting on plant and insect lifecycles; and increasing instances of tree and plant disease. Research we’ve carried out looking at climate related hazards such as excessive heat and flooding suggests that three quarters of the most important land in our care is vulnerable to climate change.[11]

If we are to reverse the decline in biodiversity and remove enough carbon from the atmosphere through land-based sequestration to mitigate climate change, it must be achieved within the land that we have. It is helpful therefore to know where the best value can be achieved in terms of investing money in habitat restoration and creation in the places that are likely to have the biggest impact for wildlife and prioritise funding and nature restoration activity towards those locations.


Local Nature Recovery Strategies


Local Nature Recovery Strategies (LNRSs) could be transformative in terms of land use for nature, offering an England-wide spatial guide to where and how land could do more for nature across the country, integrated with various tools (including ELM and Biodiversity Net Gain) to deliver positive change. They could thereby offer a bottom-up guide to how land use could deliver for nature at a local level, while also setting a path to delivering against national ambition to address biodiversity decline. However, their effectiveness depends on several key elements, which Defra have not yet fully clarified.

Firstly, the relationship between LNRSs and the planning system is currently unclear, with little detail on what effect land being identified as ‘a suitable location for the delivery of potential measures’ will have, or indeed how this identification would be considered either directly in development management or in Local Plan drafting. We hope that LNRSs will be integrated effectively into Local Plans and that there will be some obligation on local authorities to take into account the recommendations of LNRSs, with detailed guidance to illustrate the relationship between LNRSs and existing local planning measures. There may be scope to consider whether there is a role for protective designations to play in protecting some or all such land for nature.


The basis on which Local Nature Recovery Strategies will incorporate land into their mapping is also currently unclear – i.e., whether LNRSs will map and prioritise opportunities solely on the basis of their nature potential, or if other factors, including the cost and likelihood of making the change for nature, will be considered. In our view the initial mapping stage should be focused solely on identifying the opportunities for nature and should map the priorities based on science and evidence without diluting their purpose with other considerations. Wider practicalities such as accessibility and site ownership and other local needs and trade-offs in terms of land use can be more carefully considered as part of strategic implementation, most often undertaken during the Local Plan creation process, and in relation to specific decisions or opportunities for putting LRNSs into practice.


Ensuring that individual LNRSs interlock together with sufficient consistency and coherence to form a clear nation-wide picture will be a challenge: data and recommendations made by individual LNRSs need to be available and meaningful beyond the local context, with each strategy merging sympathetically with neighbouring strategies. If the Government wants to deliver on their commitments and create a national Nature Recovery Network that works meaningfully to restore nature, they will need to urgently invest in the ecological expertise and data of the local authorities that are lagging behind others.

Finally, to be effective against national targets, LNRSs must have room to be flexible in the way they are presented and the methods of nature restoration they recommend. Local difference is not only important, but essential, to creating sympathetic plans that work with past, present and future landscape character to exploit the best opportunities for nature. An urban LNRS will look different to a rural one and there must be flexibility within the guidance to accommodate this difference, without lowering standards.


Nature Based Solutions


Nature-based solutions (NBS) are land management interventions that use nature and natural ecosystems to deliver improvements against societal problems, providing multiple benefits for the public and for biodiversity. We believe NBS are an important part of fighting the joint nature and climate crises, and we need government policy to incentivise delivery of high quality solutions that work for climate, nature and people.


For nature-based solutions to have a lasting and effective impact, they will need to be designed well and deliver multiple benefits for people, climate and nature that embed them in the landscape and local communities. However, if not properly planned and managed, nature-based solutions can be short lived or unsustainable, and have unintended consequences. For example, if implementing climate solutions significantly reduces agricultural or natural resource production, we risk displacing our emissions to other countries. NBS such as tree planting undertaken in inappropriate locations can also have negative impacts for biodiversity, landscape quality or local communities.


In October 2021, we ran a summit at Wimpole, which gathered together several major landowners (including the RSPB, National Parks) to discuss nature-based solutions (NBS). We discussed barriers to the delivery of NBS and agreed a series of gold-standard principles that outlined what a high-quality NBS should achieve, delivering for communities, nature and the climate.[12] Our agreed principles state that NBS need to:

  1. Be implemented alongside, not instead of, urgent and meaningful action to reduce greenhouse gas emissions, adapt to climate change and increase biodiversity, and be designed and monitored to ensure that there is a net gain of carbon sequestration.
  2. Create or restore wildlife rich habitats and ecosystems to genuinely support nature’s recovery and provide long term biodiversity increases in a changing environment.
  3. Wherever practical, be designed, implemented or managed in consultation with local communities to ensure they take account of past, present, and future landscape character.
  4. Facilitate opportunities, wherever practical, to deliver benefits for communities and people, at a local and a national level, including to address the impacts of climate change upon people, communities, infrastructure and society.
  5. Consider the location, ecology and the broader landscape, to put the right solution in the right place and deliver multiple benefits.
  6. Be future-proofed and adaptively managed to ensure they are climate resilient and effective for generations to come.


Carbon Markets


Carbon Markets are predominantly used for carbon offsetting, and it is broadly accepted that there is a role for offsetting in tackling climate change. The Climate Change Committee (CCC)’s sixth carbon budget shows that offsets will be needed to reach net zero by 2050.[13] The use of nature-based climate solutions is recognised as an increasingly important way to tackle climate change and benefit biodiversity at the same time.


However, land-based offsetting has clear limitations given increasing pressures on land for all the purposes we have discussed in our response. The CCC has been clear that carbon offsetting should be reserved to set against only those carbon emissions that cannot be eliminated or reduced in other ways. Certain forms of NBS also have the potential to cause ecological or climate harm in the wrong location (e.g., inappropriate planting of trees on peat soils). So, offsetting projects need to be robustly regulated and monitored to ensure that they deliver genuine gains for nature or climate, and that these are not “double-counted” - where the benefits delivered by an NBS contribute to reducing emissions for two or more organisations or individuals.


Offsetting must only be used at the end of the mitigation hierarchy – once all options to remove or reduce emissions have been exhausted. The NBS undertaken, moreover, must be truly additional to any action otherwise already planned or committed to and there must be no double counting. Monitoring and careful measurements are also essential for ensuring that an NBS genuinely delivers equivalent benefits to the harm caused. Offsets can only be delivered effectively when both the supplier and the customer are carefully monitored and held to a high standard.[14]


Of major concern is the fact that carbon markets are currently unregulated. We endorse the Woodland Code and the Peatland Code, but there are currently no requirements or checks to ensure that these are used. Quality offsetting for other habitats, such as soil carbon, cannot currently be assured, as there is no existing standard of equal quality to the Carbon and Woodland Codes. This should in our view prevent these types of offsets from being sold, but the lack of regulation means that soil carbon credits and other credits that do not meet the requirements outlined above – notably of being truly additional – are available for purchase, leading to substantial ‘greenwashing’, where poor offsetting is used to justify environmentally harmful behaviour. There is no regulation over either who can buy carbon credits, and therefore no way to ensure that offsets are being used against emissions which cannot otherwise be mitigated, or over who can sell carbon credits, meaning that tenants may be selling credits on land where they cannot guarantee the longevity of the carbon they are sequestering.


Biodiversity Net Gain


If implemented effectively, mandatory biodiversity net gain has the potential to transform the role that new development can play in enhancing our natural environment – contributing to growing the quality and the access that we all have to nature on our doorsteps, and to wider national targets and ambition for tackling the biodiversity crisis. However, there is also significant risk that a poorly regulated system enables development that damages nature without offering genuine gain in return, and thus not only fails to deliver overall gain for biodiversity, but is actively harmful. It is therefore crucial that the right checks, balances and safeguards are in place, and before BNG is considered the mitigation hierarchy must be followed to reduce, avoid or mitigate as much harm as possible. On the basis of the Government’s recent consultation we have some serious concerns.


BNG creates long term responsibilities for developers, land managers and local authorities. Ensuring that true additionality is secured in association with every development, with net gain plans and sites delivering in practice across the 30-year period (at a minimum), will be critical. It will need accurate and thorough environmental baselining and science-led approaches to identifying and assessing the opportunity and potential of sites to deliver net gain, as well as strong powers and provisions to support oversight, transparency and ongoing monitoring and enforcement. It should not be enough to create habitat if this does not lead to the anticipated uplift in key species that was predicted, for example, and local authorities should be able to monitor and address breaches or failures to deliver net gain in practice. We do not yet think that this is guaranteed from the Government’s current plans.


In terms of the mechanism for securing future delivery, biodiversity net gain will become a condition of planning consent. However, in our view a planning condition is a weak mechanism to control delivery of Biodiversity Net Gain because the planning enforcement system is discretionary, highly politicised, and substantially under-resourced.


From the perspective of balancing priorities for land use, there are also further unaddressed issues in terms of potential adverse impacts on other features of importance, including landscape character/heritage assets, as a result of BNG – particularly for off-site net gain. Some sites may be unsuitable for use for biodiversity gain, or certain types of habitat (for example, sites with buried archaeology, scheduled monuments, or other historic features of significance) and guidance on how LPAs and developers should assess and make decisions regarding the historic environment and landscape character will therefore be essential. We are concerned that heritage protection was not addressed anywhere in the recent consultation.


Compatibility and implementation of policy mechanisms


All the approaches and policies discussed above, along with ELM, have significant risks as well as opportunities in terms of helping to support and drive effective approach to land use. As indicated, each of these policies or approaches is in need of greater detail, support, or guidance from Government as to how they can be implemented in a way that delivers the most benefit and avoids or mitigates potential harm or negative impacts that could arise.


There is also a need for a clearer top level vision from Government in terms of how these interventions and the wider range of further public and private funding and investment streams that can make a positive contribution to improving nature (such as other central funds for nature and climate, levelling up and place-making, lottery grants, the UK Investment Bank, etc) should work together collectively to contribute to the same national goals in a coherent way. If each approach is pursued independently, it is likely that effort and money will be wasted delivering activity that is not sustainable in the long term, does not make the best use of land available, or which could even be actively contradictory or mutually damaging – for example planting trees in inappropriate locations.


Unfortunately, at present it is extremely difficult to assess whether the combined effect of these policies will be sufficient to reverse the decline of nature and meet the statutory targets arising from the Environment Act, or deliver the land-based contribution to reduce emissions to net zero by 2050. It will be challenging for local authorities to prioritise action and see how they can best contribute to wider national goals within their local context.


This lack of clarity about policy coherence is not the only barrier to implementing a strategic approach to land use. In practice, delivering many of these policy mechanisms effectively will be reliant on local administration and implementation. Local Nature Recovery Networks and biodiversity net gain will both place significant burdens on local authorities and the planning system, as well as on advisory bodies and statutory consultees. In this context, we note that many local authorities are already facing serious resource challenges, after many years of significant central funding cuts and the ongoing impact of the pandemic on their services and activities. While some additional funding has been announced to support implementation of BNG, in our view this will not go far enough to addressing this need. Significant further investment will be needed from Government to substantially grow capacity and skills to maximise outcomes for nature and people, to minimise adverse impact on the overall efficiency of the planning system.


It's also important to note that the interventions discussed here will not be sufficient in and of themselves, and must be backed up by an effective regulatory framework, including a broader system of land designations and species protections, which also include (what are currently) the Habitats Regulations. These systems and policies must work together strategically to create the landscape Lawton describes that we need, with high quality areas for nature, areas that are improving and developing for nature, and areas that connect these systems, with flexibility across the network. The Government is currently seeking to reform the Habitats Regulations and protective nature designations, as set out in the recent nature Green Paper. While there are reasons to reform these protections, and we strongly agree with the Government’s desire to create a system that actively restores our biodiversity rather than just protecting it, we have concerns that the proposed changes could water down existing protections and/or stall much needed change for several years, when urgent action is needed.



Environment, climate change, energy and infrastructure


8. How will commitments such as the 25-year environment plan and the net zero target require changes to land use in England, and what other impacts might these changes have?


We’ve already talked about the importance of land use to delivering on the Government’s ambition from the 25 Year Environment Plan and statutory targets to be set under the Environment Act 2021 for environment and the 2050 Net Zero target in our previous answers.


We have referenced the work of the Climate Change Committee in their 2020 report on land use. This important report offered a helpful guide to the scale of change likely to be needed specifically in relation to carbon - increasing tree cover from 13% to 18% by 2050, restoring at least 50% of upland and 5% of lowland peat.[15] The Sixth Carbon budget goes further, proposing as part of their balanced net zero pathway for the land use sector: the full restoration of upland peat by 2045 and re-wetting and sustainable management of 60% of lowland peat by 2050 and the integration of trees on 10% of farmland and extending the length of hedgerows by 40% by 2050.[16] The CCC estimates that these changes can be made while maintaining the same levels of food production per head as today.


It’s worth noting also that considerations of land use and climate change relate not only to the emissions sequestered or emitted by the land itself, but also the emissions connected to the action of farming or managing of the land - agricultural emissions were 54.6 MtCO2e in 2018, 10% of UK greenhouse gas emissions (GHGs). Reaching net zero will rely therefore not only on making the suggested changes to direct land use, but significant change in terms of decarbonising farming practices.


To some extent the changes needed to meet net zero are complimentary with the Government’s environmental targets and the international commitment to protect 30% of land for nature by 2030. Nature based solutions present opportunities to address both through land use that keeps more carbon in the ground and creates more habitats for our precious species. For example, some (but not all) of the 17.5% tree cover that Government is proposing as a target under the Environment Act could count towards protecting 30% of land for nature if that tree planting is done in the right way – with the right species mix, in the right places. Delivery against both these targets can therefore support progress reaching Net Zero by 2050 and halting biodiversity decline - another Environment Act Target.


Land use change will also be needed to help us adapt and grow resilience to the effects of climate change across sectors. Climate change will impact on where and how we grow food, the availability and quality of habitat, and where we choose to build our homes and infrastructure. There is not currently a specific target or goal that reflects this need, and our view is that significant further work is needed both to understand the scale and nature of future land use changes relating to climate adaption and understand the policy interventions or changes that may be necessary to achieve them.


The most effective way to ensure we meet our targets is to ensure that one parcel of land is working effectively to deliver against multiple objectives – and this should include supporting wider objectives such as creating green space for people to access or improving the care and access to heritage and landscape features. In our view ELM schemes should be able to support all these outcomes, and there will also be opportunities through BNG and NBS.


However, as previously discussed, there is not currently a clear vision from Government as to how it sees land use change contributing to these goals, or how multiple benefits will be sought and delivered through the range of policy mechanisms it has put in place. It would be helpful for Government to explain how they see the overlap between their many targets and outline a holistic delivery plan for these targets, which could inform or form part of a Land Use Strategy. There may also be a role for a body such as CCC to undertake further work and modelling of land use pathways for nature and climate. 


In the meantime, work is being done by environment sector organisations seeking to explore pathways that deliver for both nature and climate. We ourselves are part of an academic partnership looking into the potential of different natural greenhouse gas sequestration methods, such as afforestation. The output of this research project will allow us to understand the effect of different land use scenarios and to calculate the land use that is needed to reach various targets.


9. How should land use pressures around energy and infrastructure be managed?


The National Trust is fully supportive of the target to achieve net zero by 2050 (and we have a significant programme of work underway to reach our own organisational net zero goal of 2030). However, we acknowledge that in order to meet this national goal, there is likely to be a need for new large scale renewable projects, which will significantly increase land pressures in relation to energy and infrastructure and have impacts on our landscapes.


Existing infrastructure associated with energy generation is likely to need to be significantly altered and new infrastructure developed in different locations to meet this shift, especially in relation to offshore wind. There will also be impacts associated with new, or re-sited transmission infrastructure. However, growing renewable energy will be a vital means of enabling the UK to meet its legal requirement, reduce carbon emissions and halt climate change. With careful planning, including consideration of design and siting, it should be possible to minimise adverse impacts on nature, heritage and landscape, and schemes should be holistically designed to take into account the effects on these features.  


It is also important that schemes also take account of the long-term impacts beyond the initial lifecycle of the development, including the likelihood of requests for renewing consent, increasing the scale of development in the future, or indeed removal and reinstatement.


Given the need to balance many demands on land, there would be significant benefit in the development of a strategic plan for energy and infrastructure, including the provision of Green and Blue Infrastructure needed to support sustainable development across the country. This document could take forward the work undertaken in the development of the National Infrastructure Strategy and bring together strategies from other national infrastructure providers, such as National Highway’s RIS or National Grid’s NOA, into a comprehensive document which includes a spatial element. The National Infrastructure Commission could lead the development, monitoring and review of such a strategy and this can then support decisions taken either through the NSIP or TCPA systems. Such an approach would have significant advantages for managing land use pressures for energy and infrastructure with consideration of opportunities and constraints allowing for securing of any strategic enhancements and mitigation as well as providing clarity and certainty for all involved.

Land use planning


10. What do you see as the advantages and disadvantages of the existing land use planning system and associated frameworks in England? How effectively does the system manage competing demands on land, including the Government’s housing and development objectives? What would be the merits of introducing a formal spatial planning framework or frameworks, and how might it be implemented?


As the UK’s largest private landowner, a conservation charity, significant tourism and rural business, and occasional developer, we engage with planning law and processes on a daily basis. This includes everything from the management and sustainable development of our own land and buildings to the need to engage constructively and effectively with the development proposals of others when they impact the places we hold in trust for the nation.


The land use planning system is one of our most effective and important tools for shaping the physical environment to meet our collective needs. An effective system should deliver appropriate development in the right places, provide communities with necessary services and infrastructure, safeguard our environmental future, and conserve and enhance our historic and natural environments to create great places for people to live for everyone’s benefit. While the current system has served the Trust well over its 75-year existence, there are a number of areas in which the system and associated frameworks could be better utilised to deliver ideal outcomes.


Within the current system and framework, we identify the following key advantages:




In contrast, we take the view that there are a number of disadvantages to the current land use planning system:



The continued de-regulation of Permitted Development Rights (PDR) over recent years has, we feel, undermined the ability of local authorities to undertake effective strategic planning, by removing of the need for a full planning application, with the prior approval process only covering limited matters. This has made it harder to deliver strategic government policy objectives. For example, PDRs have had negative impacts on attempts to regenerate High Streets, by allowing changes of use of buildings to residential, and the creation of new residential dwellings in unsustainable areas as a result of the change of use of commercial units. This leads to a significant undermining of the plan-led system, with competing demands on land often not being able to be managed locally to secure the best outcome for all. The uncertainty surrounding any planning reform is adding to this inefficiency, as many local planning authorities have paused or are progressing Development Plans at a slower rate. There is urgent need to provide clarity for the future of the land use planning system in England and a clear strategic direction on its priorities.


In the absence since the early 2010s of any “higher tier” or strategic planning function, the Trust has found that the plan-led system has become more polarised, often focusing on achieving housing requirements within a local area, with the Duty to Cooperate failing to deliver anything more than tightly constrained local authorities working with their immediate neighbours to address housing need. In our experience, the duty does not secure the ability to plan and deliver at scale to address the full range of economic, social and environmental issues we face, nor does it allow the ability to address these issues at a landscape-scale or ecosystems level, such as river catchments or corridors or linking the functional need for green infrastructure with modern cities or city regions. This puts at risk the delivery of many government objectives and puts significant pressure on local councils to meet multiple demands on land, often in small or tightly constrained areas, with economically less attractive land uses (open space for example) being marginalised and limited ability to plan for key larger infrastructure requirements (e.g.: hospitals or transport interchanges). We think it is likely that government will struggle to achieve the join-up and coherence of approach needed to deliver on its national ambition for nature and climate if it relies only on the current duty to cooperate.


We are aware of the work being undertaken by the Greater Manchester Combined Authority in producing a strategic plan for much of the Greater Manchester area led by the Mayor and consider that there could be opportunities for similar approaches with other mayoral and combined authorities. However, this document has taken a significant period of time to produce and therefore ensuring a timely process for the production of any new strategic framework approach will need to be carefully considered along the resourcing requirements.





12. Which organisations would be best placed to plan and decide on the allocation of land for the various competing agendas for land use in England, and how should they set about doing so?


Our answers to the Committee’s questions have highlighted the complexity of taking a truly holistic approach to land usethe range of considerations and practical challenges in planning and implementing strategy and policy measures that translate to change on the ground.


Of fundamental importance is achieving a balance between delivery of local and national ambitions and needs. We need high quality places that support thriving communities rich in access to nature, beauty and heritage, and which help us adapt to and tackle challenges such as climate change. We also need to be able to meet the nation’s needs in terms of domestically produced food, energy and digital infrastructure. In our view neither an entirely top-down or bottom-up approach is likely to succeed in delivering this effectively and fairly, maximising value for public money.


There is a role for central government to be clearer about its overall vision for land use in England and spell out in greater detail the contribution that it expects land use change to make towards its key environment, climate and other policy goals and priorities, and how it envisions our finite resource of land contributing to all of these ambitions. On this basis central government can then set top level priorities for land use and create a framework for ensuring that the structure and scale of its policy and funding interventions is sufficient to drive the needed change in practice. It can also consider what other policy or legislative changes may be needed – that could include anything from changes to the NPPF, statutory duties or obligations on public bodies, to revised or new structures or remits for advisory or arms-length bodies.


However, the Government should not be seeking to micro-manage individual land use choices at a local level, and local authorities and communities need to be empowered to make decisions about their local areas that contribute to the top-level priorities set by government. We support the importance of a locally driven planning system; however the system as currently operated focuses only on choices about development. The development of spatially explicit and accessible decision support tools that would enable local authorities to take a more holistic, system-wide approach and explore the consequences of interventions, would help them align their decisions and local plans with an England-wide land use strategy. We would support the development of an integrated land use framework that would place nature and carbon developments in the same frame as, for example, housing allocation.


Georgina Holmes-Skelton

National Trust

April 2022



[1] National Biodiversity Network, State of Nature Report 2019

[2] Final report of the Independent Review on the Economics of Biodiversity led by Professor Sir Partha Dasgupta, Feb 2021, The Economics of Biodiversity: The Dasgupta Review

[3] IUCN - Peatland Damage | IUCN UK Peatland Programme (

[4] Climate Change Committee, Jan 2020, Land Use Policies for a Net Zero UK 2020


[5] to-urban-green-space-as-part-of-uks-green-recovery

[6] Climate Change Committee, Jan 2020, Land Use Policies for a Net Zero UK 2020

[7] Final report of the Independent Review on the Economics of Biodiversity led by Professor Sir Partha Dasgupta, Feb 2021, The Economics of Biodiversity: The Dasgupta Review

[8] For example, Professor Sir John Lawton, Sept 2010, ‘Making space for nature’: a review of England's wildlife sites; National Biodiversity Network, State of Nature Report 2019

[9] UK National Ecosystem Assessment, June 2011, UK NEA (

[10] Making Space for Nature – 10 Years On, MakingSpaceforNature_10years_final.pdf (

[11] National Trust Press Release, 5 March 2021, National Trust maps out climate threat to coast, countryside and historic places | National Trust

[12] National Trust Press Release, 29 November 2021, Some of the nation’s largest landowners make unprecedented pact to jointly tackle the climate and nature crises | National Trust

[13] Climate Change Committee, Sixth Carbon Budget, 9 December 2020, Sixth Carbon Budget - Climate Change Committee (

[14] We support this Wildlife and Countryside Link paper, which explains our concerns with carbon offsetting and the criteria needed for it to be helpful to the effort to tackle climate change. Wildlife_and_Countryside_Link_Offsetting_Briefing_23042021.pdf (

[15] Climate Change Committee, Jan 2020, Land Use Policies for a Net Zero UK 2020

[16] Climate change Committee, Sixth Carbon Budget

[17] p.4



[20] Supplementary written evidence from Natural England (NER0092). Budget figure as at May 2017

[21] Historic England Three Year Corporate Plan, 2018-21,