Information for Policymakers

While Local Nature Recovery Strategies (LNRSs) are intended to support nature recovery and inform spatial planning, they are not suitable as standalone guidance for the identification and implementation of measures to protect chalk streams within spatial development strategies. This is primarily due to their limited geographic scope. 

Chalk streams are unique and vulnerable ecosystems that often span multiple local authority LNRS areas^[2]. For example, the River Avon spans Wiltshire & Swindon and Hampshire LNRS areas, while the River Kennet flows through the Wiltshire & Swindon and Berkshire LNRS areas. The River Lea flows through Bedfordshire, Hertfordshire and Greater Essex LNRS areas.  

As the LNRSs are developed at a local level, they may only address a portion of a chalk catchment, leading to fragmented protection and management approaches. This is particularly damaging to chalk streams, which are highly fragile and vulnerable to inputs across their catchments – with activities upstream heavily influencing water quality and ecological health further downstream. 

This undermines the ecological integrity of these interconnected systems, which require catchment-scale planning and coordination. Therefore, reliance on LNRSs alone cannot provide the comprehensive and consistent protections chalk streams require at the strategic level. Spatial Development Strategies provide a key opportunity to grant chalk streams the catchment-wide protections that they need to drive nature’s recovery and progress towards Environmental Act (2021) targets. 

Within some LNRS, such as those in Norfolk and Suffolk, not all chalk streams are not identified as priority habitats despite their rarity and high ecological value. Even if the LNRS were appropriate for the protection of chalk streams at a strategic scale, the wording in proposed new section 12D(11) would fall short – with a weak requirement for the SDS to “take account of any local nature recovery strategy”. 

In its current form, the National Planning Policy Framework (NPPF) fails to grant appropriate protections for chalk streams in new developments. As noted by the Minister, the NPPF includes general provisions for the conservation of biodiversity within Clause 193. This states that:  

‘When determining planning applications, local planning authorities should apply the following principles:  

a) if significant harm to biodiversity resulting from a development cannot be avoided  (through locating on an alternative site with less harmful impacts), adequately mitigated, or,  as a last resort, compensated for, then planning permission should be refused’.^[3] 

While we welcome the inclusion of the mitigation hierarchy within this policy, as a means for minimising harm to biodiversity, this policy falls short of the bespoke, catchment-scale protection that our chalk stream habitats need. 

This policy is not appropriate to protect chalk streams, which are fundamentally irreplaceable habitats and therefore, cannot be mitigated or compensated for. Chalk aquifers, once destroyed, cannot be replicated and with 85% of the world’s supply of chalk streams in England^[4], we have a national duty to protect them. As such, this policy cannot apply to irreplaceable habitats and is unsuitable for providing chalk stream protections. 

This NPPF policy is likely to be further undermined by Part 3 of the Planning & Infrastructure Bill, which would remove the need for site-specific assessment of ecological impact. Instead, an estimation of harm will be made with an associated cost to offset ecological impact. This means it will be difficult to determine the level of harm associated with a development on a site-by-site basis, enabling ecologically damaging developments to go ahead without sufficient measures to calculate harm to biodiversity.  

The NPPF does not specifically recognise chalk streams as an irreplaceable habitat or provide targeted protections tailored to their unique characteristics. As a result, decisions taken under the NPPF may fail to give adequate weight to the specific vulnerabilities of chalk stream habitats, leaving them exposed to incremental harm from development pressures across the catchment. 

Chalk streams currently lack explicit protection under primary legislation, which the Planning & Infrastructure Bill could deliver. Without clear national guidance, the existing legal gap creates a vulnerability within forthcoming Spatial Development Strategies, in which local policy to protect chalk streams may be overturned through appeals and legal challenge. 

Currently only 11 out of 220 British chalk streams have any legal protections as a Site of Special Scientific Interest (SSSI). These are the Hampshire Test, the Somerset Frome, Dorset Bere Stream, Wiltshire and Berkshire's Kennet, the Norfolk Nar, Yorkshire’s Hull headwaters and Greater London's Crane.  

Worse still, only 4 are protected fully at the highest level as a Special Area of Conservation (SAC). These are the Wiltshire Avon, Hampshire Itchen, Norfolk Wensum and Berkshire Lambourn.   

None of our UK Rivers, including chalk streams, are in good ecological health. Despite even these very limited protections, our chalk streams suffer from chronic pollution issues like all other rivers in the UK. Status as an SSSI or SAC does not provide the bespoke, catchment-wide protection that chalk streams need to truly recover as these fragile habitats are heavily influenced by activities across their catchments, meaning any protection needs to be wide-reaching and specific to chalk streams.  

This lack of legislative backing undermines efforts by strategic planning authorities to implement meaningful protection for chalk streams through spatial development strategies and leaves these rare ecosystems at the mercy of inconsistent planning decisions and procedural challenges. 

at end insert—

“(6A)A spatial development strategy must—

(a)list any chalk streams identified in the strategy area;

(b)identify the measures to be taken to protect any identified chalk streams from pollution, abstraction, encroachment and other forms of environmental damage; and

(c)impose responsibilities on strategic planning authorities in relation to the protection and enhancement of chalk stream habitats.”

To the Secretary of State for Housing, Communities and Local Government:

• To ask the Secretary of State for Housing, Communities and Local Government, what assessment she has made of the potential impact of changes to the planning system within the Planning & Infrastructure Bill on irreplaceable habitats, including chalk streams.
• To ask the Secretary of State for Housing, Communities and Local Government, what support her Department provides to local planning authorities to help ensure that new developments do not further degrade habitat quality and water quality in chalk stream catchments.
• To ask the Secretary of State for Housing, Communities and Local Government, whether the proposed reforms under the Planning & Infrastructure Bill will include specific safeguards for chalk streams and their catchments.

To the Secretary of State for Environment, Farming and Rural Affairs:

• To ask the Secretary of State for Environment, Farming and Rural Affairs, what assessment he has made of the Environment Agency’s 2024 Event Duration Monitoring dataset, particularly regarding the importance of our chalk streams in achieving Environment Act targets to restore precious waterbodies.
• To ask the Secretary of State for Environment, Farming and Rural Affairs, what recent assessment he has made regarding the ecological vulnerability of chalk stream habitats, and whether his Department plans to develop a national strategy for their protection and restoration.