What does the Planning and Infrastructure Act mean for nature restoration and environmental delivery?

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Bea Gilbert

From planning reform to delivery

December 2025 marked a major milestone for the planning system, with the Planning and Infrastructure Bill receiving Royal Assent and becoming the Planning and Infrastructure Act (PIA) 2025.

The Act represents one of the most significant recent changes to the planning system, with the potential to materially affect how quickly development can be consented and how environmental obligations are delivered in practice. It forms a central pillar of the Government’s growth agenda, aimed at accelerating housing delivery (1.5 million homes), improving infrastructure consenting, and strengthening planning across England.

With the PIA in place, focus has now shifted from legislation to implementation, with a phased rollout of reforms spanning plan-making, development management, environmental mitigation, and nationally significant infrastructure delivery. The Government’s March 2026 Streamlining Infrastructure Planning: Implementation Plan confirms a structured transition approach, particularly for Nationally Significant Infrastructure Projects (NSIP) and environmental reforms. Full system operation is expected to develop progressively through 2026–2027.

The Act introduces several key reforms, including Spatial Development Strategies (SDS, strategic plans prepared at a sub-regional scale) to strengthen cross-boundary planning. Priority areas have already been identified, with draft regulations and guidance in circulation. Development management reforms to support local planning authority decision-making are progressing, with a national scheme of delegation in draft and measures to reduce and standardise planning committee sizes expected later in 2026. Meanwhile, reforms to the NSIP regime are being implemented gradually, with the March 2026 Implementation Plan confirming a continued focus on reducing consenting timelines, particularly for nationally significant infrastructure.

A new model for environmental delivery

While these reforms span the planning system, one of the most consequential changes is the introduction of a new environmental delivery model, which is likely to have the most immediate implications for developers and consultants. This new environmental delivery system is centred on Environmental Delivery Plans (EDPs) and the Nature Restoration Fund (NRF), to be delivered by Natural England. These changes aim to resolve the conflict between a need for sustained economic growth, housing and infrastructure, and the need for protection and recovery. Current policies face reoccurring problems, including delays to development delivery and slow, fragmented and unpredictable nature restoration. There is a lack of strategic coordination, and case-by-case negotiations often slow down housing and infrastructure delivery.

The introduction of EDPs represents a step away from project-by-project mitigation, and a step towards strategic, landscape-scale environmental planning and delivery. Natural England becomes responsible for land procurement, mitigation, and long-term maintenance, with the developer required to pay into the NRF levy. The introduction of EDPs and the NRF represent a fundamental reallocation of responsibility, moving ecological delivery from thousands of developers to a single national body, with the aim of the NRF to facilitate the pooling of resources to deliver conservation measures at scale, maximising positive environmental outcomes and secondary benefits such as public access to green spaces.

The Government foresees EDPs supporting nature markets, with the private and third sector provides of conservation measures being a critical aspect of NRF delivery. With this change, Natural England becomes a major competitor in the off-site market, which may boost the nature market or lead the private sector facing price pressure. For LPAs and consultants, strategic repositioning will be required. Consultants may reposition themselves to help landowners prepare for Natural England procurement, and with EDPs rollout currently unclear, consultants must be able to operate under the EDP and HRA systems.

Mixed responses

However, while the Government hopes that the introduction of the PIA and associated reforms will "unshackle Britain to get building", it’s important to note that the PIA has received criticism from industry bodies. In March 2025, CIEEM released an official comment on the PIA, highlighting a number of potential issues including potential uncertainty and increased costs for developers, concerns around a lack of monitoring and enforcement, and potential threat to Biodiversity Net Gain (BNG), which could be at risk of being absorbed into the NRF. A large concern is that EDPs may create a ‘pay to pollute’ system which prioritises economic viability over environmental mitigation. Many other industry professionals, developers and ecologists have expressed concern over the approach set out in the PIA. 94% of 452 polled professionals believe it could have a negative impact on nature recovery, providing developers with a ‘license to trash’ where developers can pay into levies, and with no need to identify and then safeguard species on-site, go straight to development. The Government’s position on nature being a “blocker” or a “shackle” to development has also been questioned, with the Environmental Audit Committee calling this characterisation “lazy”. Chair of the Committee Toby Perkins also stated that nature should not be scapegoated and stressed that “A healthy environment is essential to building resilient towns and cities”.

Towards efficiency?

Professionals have also questioned if EDPs will truly streamline the mitigation process. EDPs are an additional legislation, and do not replace Habitat Regulation Assessments (HRAs) or BNG. HRAs and BNG will continue to be legally required and developer-led. While EDPs may deliver some mitigation that HRAs require, reducing the need for project-specific mitigation, this will depend on the size and scale of EDPs, which are currently in the pilot stages. Currently, 23 priority areas are in early rollout stage, with the Government focusing on areas where nutrient pollution affects protected sites and areas where great crested newts are present. In these areas, EDPs may help speed up development and the nature restoration process, but there are concerns they may lead to missed local opportunities and bespoke nature solutions on a site-level.

While EDPs have the potential to counterbalance the often site-specific approaches of BNG and HRAs, where mitigation is often localised over small areas, it is unclear at this stage how extensive EDP cover will be, and how accessible they will be to developers. In order for the new approach to truly speed up planning and environmental protection, a vast coverage of EDPs across England will be required to ensure landscape-scale environmental improvements are possible.

Another issue comes with most EDPs expected to be voluntary, with developers given the option to opt-in, or continue with their current regime. One concern is that the cost of engaging with an EDP (which will be set out by Natural England) will impact developer buy-in, creating the risk of patchy coverage and limited landscape-scale possibilities. If the NRF levy is more expensive than the current workflow, with HRAs and BNGs already a developer expense, developers may opt out. To counteract this, the levies must be fairly priced, and the process for developers must be clear and accessible. The Government’s ambition and the success of the NRF depends on developer participation, and the EDP must incentivise developers to buy-in for the rollout to be successful.

Secondly, developers may have concerns about costs, a potential lack of monitoring and enforcement of the NRF and EDPs, and a loss of local nuance. To tackle this, clear processes, standards and expectations must be given to LPAs, developers and consultants. At present, a phased national expansion approach is confirmed, and secondary legislation and operational guidance will continue through 2026. Transitional arrangements will allow the HRA process to remain in place as standard while EDPs are not yet operational.

Making the most of it

Overall, the introduction of the PIA – if done well – has the potential to be advantageous by speeding up sluggish development, and implement targeted, evidence-based conservation programmes on a landscape-scale, filling a gap in the current process of bespoke assessments. Reforms could represent a step change in how development and environmental delivery are integrated, possibly addressing some long-standing constraints in planning performance and nature recovery.

However, delivery risk remains high. The success of EDPs relies on factors that are not yet fully defined, including the cost and accessibility of EDPs, the capacity of Natural England, and the willingness of developers. Success is also dependent on the Government heeding professional advice and tapping into the extensive knowledge of environmental professionals and ecologists to ensure the introduction of the PIA does not lead to negative impacts on nature. It is vital that nature does not become secondary to development and instead is seen as an essential component of building a future-ready world.

For developers, landowners and infrastructure promoters, the immediate priority is to understand how and when EDPs will apply, and how they compare commercially and programmatically to existing approaches such as project specific mitigation and BNG.

For consultants, there is a clear need to operate across both systems in the short term while also anticipating a shift towards more strategic, landscape scale delivery models. This may require new advisory roles, including supporting engagement with Natural England led schemes and preparing land for inclusion in strategic delivery programmes.

As the PIA transitions from legislation to implementation, those who engage early with these changes will be best positioned to manage risk and take advantage of emerging opportunities.