Critics of Part 3 of the Planning & Infrastructure Bill have called it ‘a licence to kill’ and a ‘pay to pollute’ scheme. The Bill proposes allowing developers to ignore local habitats and bypass their biodiversity net gain requirements (which have only recently been introduced) by lobbing some money to Natural England for a state-controlled nature levy scheme.
The latest group of opponents to the plan have been coordinated by RSK Wilding, and environmental consultant that works with developers. The 80+ signatories range from the Green Building Council to TV’s Chris Packham. Many of them also signed a similar letter last month.
Despite appearing to be a largely left-leaning group, they say that the private sector is better placed to protect the natural environment that a state-run bureaucracy.
The letter says: “We collectively call on the government to pause and rethink this legislation before it does irreversible harm to nature, to the integrity of the planning system, and to investor and public confidence.”
It says: “Our concerns are grounded in shared values: the protection and restoration of the natural environment, the delivery of high-quality development, and the promotion of sustainable economic growth. Part 3, as currently drafted, falls short on all three fronts.
“The government’s manifesto commitment for development to “promote nature recovery” is in jeopardy. The Office for Environmental Protection (OEP) has clearly stated that the Bill “would have the effect of reducing the level of environmental protection provided for by existing environmental law” and, as drafted, the Bill represents a regression in standards. This should be a line no government elected on a commitment to restoring nature is willing to cross.
“Furthermore, recent legal advice and opinions from leading King’s Counsel reinforce these warnings. They point to flaws in the drafting and legal uncertainty that risk protracted disputes and undermining environmental protections.
“We are especially concerned about the lack of due process and consultation surrounding these proposals. There has been no piloting, insufficient engagement with affected sectors, and a notable absence of robust evidence underpinning the assumptions made. This not only erodes trust but increases the likelihood of poor implementation, market disruption, and diminished outcomes for nature and communities.
“From a business perspective, the implications are troubling. Developers risk facing greater delays, added complexity, disparate approaches and increased uncertainty. The suggestion that nature is a barrier to development is not supported by the evidence. Instead, it is underfunded planning departments and inefficient processes that hold back progress. Well-designed green infrastructure has repeatedly been shown to enhance value, wellbeing, and resilience.
“We caution against centralising nature recovery funding through a levy system administered by Natural England, especially when previous levies have repeatedly demonstrated inefficiencies. The private sector has proven its ability to innovate and scale environmental markets effectively — and must remain a trusted and integral part of the solution.
“Moreover, weakening the mitigation hierarchy or sidelining on-site enhancements in favour of distant offsets risks increasing environmental injustice. Communities deserve access to nearby green space — especially those in high-development areas. A rushed approach will jeopardise these critical local benefits.
“We acknowledge the need to streamline planning and support growth. But half measures or weak compromises will not address the fundamental flaws in Part 3. A genuine solution must start with proper consultation, grounded in science, transparency, and collaboration with those who understand both development and environmental delivery.”
The signatories:
- Justin Adams OBE (Chair, Trust for Oxfordshire Environment, Visiting Fellow Oxford Martin School, Co-Founder, Ostara)
- Jamie Agombar (Executive Director, Students Organising for Sustainability-UK)
- Nida Al-Fulaij (CEO People’s Trust for Endangered Species)
- Glenn Anderson (Director, Swallowtail Consulting)
- Kate Ashbrook (General Secretary, Open Spaces Society)
- Craig Bennett (CEO, The Wildlife Trusts)
- Evan Bowen-Jones (CEO, Kent Wildlife Trust)
- Estelle Bailey (CEO, Berks, Bucks & Oxon Wildlife Trust)
- Tom Beeston (Chief Officer, Chiltern Society)
- Alexander Begg (Co-Founder, Wendling Beck, a pioneering two-thousand acre nature restoration and landscape recovery scheme)
- Sarah Belton (Director, Nutrient Neutral and Our Rivers Group)
- Prof Jeremy Biggs (CEO, Freshwater Habitat Trust)
- Charlie Burrell (Knepp Estate)
- Mike Childs (Head of Science, Policy and Research, Friends of the Earth)
- Sarah Jane Chimbwandira (CEO, Surrey Wildlife Trust)
- Dr Gabriel Connor-Streich (CEO Greenshank Environmental)
- Mitch Cook (Director, Greengage Environmental)
- Richard Crompton (Ecology on Demand & TeamBat, President of Cardiff Bat Group, former Bat Conservation Trust trustee)
- Jon Davies (Director, RSK Wilding)
- Estelle Dehon KC (Cornerstone Chambers)
- Justin Dillon (President, National Association of Environmental Education)
- Natalie Duffus (specialist in biodiversity net gain, Oxford University)
- Dr Sophus Zu Ermgassen (specialist in biodiversity finance, Oxford University)
- Bob Elliot (CEO, Wild Justice)
- Dr Hugh Ellis (Director of Policy, Town and Country Planning Association)
- Jim Foster (Conservation Director, Amphibian and Reptile Conservation Trust)
- Ben Goldsmith (CEO, Menhaden Capital)
- David Haimes (Director, Civity NGE)
- Helen Hamilton (Marches Planning and Environment)
- Sally Hayns (CEO, Chartered Institute of Ecology & Environmental Management)
- Andrew Hicks (CEO, BNGx)
- Prof David Hill CBE (former Deputy Chair of Natural England, past President of CIEEM, founder President of The Foundation for Nature, past member of HM Government Ecosystem Markets Taskforce)
- Kerry ten Kate (Non Executive Director, Finance Earth)
- R. Martin Kelly (Chair and Trustee of The Trees and Design Action Group)
- Christopher Kerr (Lawyer and Head of ESG, Davitt Jones Bould)
- Oliver Lewis CBE (CEO, Joe’s Blooms)
- Prof Sir John Lawton CBE FRS, (Author of ‘the Lawton Review’ and Chair of Making Space for Nature)
- Dr Raichael Lock (Convenor, Manchester Environmental Education Network)
- Dr Caroline Lucas (former Leader of the Green Party of England & Wales and MP)
- Emma Montlake (Joint Executive Director, Environmental Law Foundation)
- James Mansfield (Co-Founder and Managing Director, Finance Earth)
- Dr Amy McDonnell (Co-Director, Zero Hour)
- Simon McWhirter (Deputy CEO, UK Green Building Council (UK GBC))
- Nick Measham (CEO, WildFish)
- Lydia Meryll (SERA and Honorary Fellow of Knowledge Exchange, School of Environment, Education and Development, The University of Manchester)
- Prof Dame E.J. Milner-Gulland DBE (Tasso Leventis Professor of Biodiversity and Director of the Interdisciplinary Centre for Conservation Science, Oxford University)
- Tom Nelson (Director, Nature Impact)
- Robin Nicholson CBE (Convenor of the Edge, a built environment think tank)
- Pascale Nicolet (CEO, Newt Conservation Partnership)
- Robert Oates (CEO, Arbtech)
- Dr Rose O’Neil (Chief Executive, Campaign for National Parks)
- Chris Packham (Co-Director, Wild Justice)
- Nigel Palmer (Chief Executive, Badger Trust)
- Maya Pardo (Coalition Against Factory Farming)
- Rosie Pearson (Community Planning Alliance)
- Gill Perkins (CEO Bumblebee Conservation Trust)
- David Pinder (Chair, Green Construction Board)
- Jan Plumstead (Sustainability Lead, Bures CEVC Primary School)
- Jack Potter (Director, Wild Capital)
- Sir Jonathan Porritt CBE (writer, founding Director of Forum for the Future)
- Paola Reason (Director, RSK Biocensus)
- Rossiter Family (Belmont Estate)
- Beccy Speight (Chief Executive, RSPB)
- Dr Rich Stockdale (CEO, Oxygen Conservation)
- Kit Stoner (Chief Executive, Bat Conservation Trust)
- Archie Struthers (CEO, Nattergal)
- David Short (Environment Lawyer, Lux Nova Partners)
- Zak Simmonds (Director, National Rivers Consortium)
- Ruby Sleigh (Chair, Architects Climate Action Network)
- Lynne Sullivan OBE (Chair, Good Homes Alliance)
- Debbie Tann MBE (CEO, Hampshire and Isle of Wight Wildlife Trust)
- Morgan Taylor (Director, Greengage Environmental)
- Dr Tom Tew (CEO, NatureSpace, former Chief Scientist of Natural England, former Trustee of The National Trust and Heritage Lottery Fund)
- Guy Thompson (Managing Director, EnTrade)
- Dr Ruth Tingay (Co-Director, Wild Justice)
- Chris Todd (Director, Transport Action Network)
- Simon Towers (Director, Green Earth Developments Group)
- Isabella Tree (Knepp Estate)
- Dr Jo Treweek ((Director of eCountability and UK Habitat Classification, Biodiversity Chair of the International Association for Impact Assessment)
- Dr Paul Vare (Chair of Trustees, National Association for Environmental Education-UK)
- Dr Stephanie Wray (Director of Athene Consulting and Nature Repair, past President of CIEEM, Chair of The Mammal Society, Trustee of Gloucestershire Wildlife Trust)
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