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.”
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