You might not know what a chalk stream is. You might not even realise you have a chalk stream near you! This is because despite their biodiversity and beauty they have been forgotten and ignored. Your local chalk stream may not even be recognisable as a chalk stream as its clear waters have turned murky and polluted, riverbanks damaged, wildlife vanished. It doesn’t have to be this way and it shouldn’t. These irreplaceable chalk streams were once the muse of great English poets and authors, inspiring works like Wind in the Willows. Chalk streams are important to our wildlife, our culture, our history and should be a source of national pride. We are lucky enough to have most of the world’s chalk streams in England. These precious chalk streams are our international responsibility. We can’t properly care for, restore and enjoy our chalk streams unless we protect them.

Chalk streams are rich in wildlife. They are difficult to restore, impossible to create or replace and incredibly rare and unique. These are all the necessary requirements to be considered an irreplaceable habitat and yet they are still missing from the irreplaceable habitats list.  

The NPPF defines irreplaceable habitats as technically very challenging or time-consuming to restore, considering factors such as age, uniqueness, the number of species found there, or rarity.

Chalk streams need very specific conditions to even exist, like the chalk bedrock that filters the water making it cool and clear. This is why it is impossible to recreate them elsewhere. They are also vulnerable to damage, and relatively incapable of self-repair. In other words, chalk streams are irreplaceable and should be classed as such.

Last year, thousands of our members and supporters urged their MPs to support the chalk stream protection amendment to the Planning and Infrastructure Bill.

Unfortunately the amendment was not successfully voted through, but our efforts resulted in contributions about chalk streams from MPs dominating the debate with countless calls for their protection. Over 100 MPs voted in favour of the amendment, and asked for new commitments from the Government for chalk streams.   

Housing Minister, Matthew Pennycook said, “The Government acknowledge the case for giving explicit recognition to chalk streams in national planning policy, […] we will lay out and consult on proposals to include that explicit recognition and in so doing make clear, unambiguously, our expectations for how plan makers and decision makers should treat chalk streams.” 

While chalk streams have been mentioned in the proposed national planning policy, it isn’t strong enough. Chalk streams are mentioned once in the new ‘National Decision-Making Policies’ but these policies aren’t statutory, meaning they’re not legally required. The policy does not prevent damage from taking place, it just asks the developer to assess and mitigate it, but damage and pollution can still occur. There is also no mention of preventing over-abstraction of chalk streams or having a larger buffer between the development and chalk stream habitats. 

This is the first time chalk streams have ever been mentioned in the NPPF and that's thanks to all of you! However, these mentions fall well short of delivering on the Government’s promise of “explicit recognition” which would make “clear, unambiguously, expectations for how plan makers and decision makers should treat chalk streams”. With two mentions of chalk streams as mere examples, this draft lacks the detail and strength needed to properly protect chalk streams.  

The mentions of chalk streams in the draft NPPF are as follows:  

Plan Making Policy* N1: Identifying environmental opportunities and safeguards states that development plans should “set out the hierarchy of international, national and locally designated sites and areas of importance for their landscape, geological (including soil) or biodiversity value in the plan area, and identify other features which require particular consideration in managing development due to their environmental value such as chalk streams”. Once again, chalk streams are included as an example, rather than being afforded specific protection. The policy requires only that they are identified, and whilst identification should be used to ‘steer the location of development’, the policy then stresses that this ‘should not necessarily preclude the allocation of land for development’. This gives no certainty, so is too weak to truly protect these fragile chalk streams. Whilst the policy also requires that opportunities for conservation are identified, this falls short of the robust planning protection needed to prevent ongoing pressures of pollution and over-abstraction. 

National Decision-Making Policy* P3: Living conditions and pollution states that development proposals should “assess and mitigate impacts where the development could have an unacceptable adverse effect on water quality, especially where this concerns sensitive water bodies such as chalk streams”. Policy for chalk streams should require pollution to be avoided in the first instance; it is not good enough to miss this step and simply require impacts on water quality to be reduced. The NPPF also makes no mention of how to deal with the other pressure that impact chalk streams, such as excessive abstraction to provide water supplies. Chalk streams are difficult to restore and impossible to create or replace, and neither the overarching plan-making policies or the subsequent decision-making policies provide sufficient protection. This is why chalk streams must be added to the irreplaceable habitat list, to avoid harm in the first instance and reflect the true fragility and rarity of these extraordinary habitats.  

You can read the draft National Planning Policy Framework currently open for consultation in full here: National Planning Policy Framework: proposed reforms and other changes to the planning system - GOV.UK  

* These plan-making Policies show how overarching plans should be developed. These include Spatial Development Strategies, which concern cross-boundary issues, and Local Plans, which set out a guide for development at a local level. National Decision-Making Polices (NDMP) are a new set of policies proposed in the draft NPPF that then set out how individual planning decisions should be taken. They are intended to deliver consistent planning decisions across the country.