Danny backs Lib Dem call for greater protection for our chalk streams

Dear Rt Hon Matthew Pennycook MP,
On 15 July, we held the inaugural meeting of the new All-Party Parliamentary Group on Chalk
Streams, attended by MPs and Peers from across the houses. Rare and biodiverse chalk streams are
the pride of many constituencies in England. Communities, local volunteers, environmental NGOs
and parliamentarians have long argued for their protection.
Our conversations at the inaugural meeting considered the current state of chalk streams across
England and the multiple, often compounding pressures they face, including over-abstraction,
pollution, habitat degradation and the demands placed on sensitive catchments by development.
Planning plays a critical role in shaping our landscape and can, when done right, protect and restore
these fragile ecosystems, through delivering sustainable abstraction, upgrades to water
infrastructure and habitat enhancements. Therefore, I was pleased to see that at the consultation
stage for the first time, chalk streams were included in England’s National Planning Policy
Framework (NPPF). However, these references are inadequate, treating chalk streams as features to
be identified, rather than globally rare, important habitats that require protection. I was disappointed
to see that in the NPPF published on Monday 17th August; no revisions were made to improve
these references that remain unchanged since the consultation.
Furthermore, chalk streams remain absent from the list of irreplaceable habitats within the
Framework’s definition, despite chalk streams meeting the requirements and the thousands of
consultation responses from the public calling for this recognition. Irreplaceable habitat status
carries the strongest protection in national planning policy, under which development that would
cause loss or deterioration ‘should be refused, unless there are wholly exceptional reasons’. As
published, the Framework defines irreplaceable habitats as follows:
“Irreplaceable habitats are habitats with characteristic ecological features and processes which
cannot successfully be created, or would take a very long time to establish and function normally.
Irreplaceable habitats are difficult to recreate due to their rarity (being endangered or vulnerable
to ecosystem collapse), environmental context, or because they have been established for a very
long time (time thresholds may vary). They generally support important and/or rare species
populations or assemblages. They include ancient woodland, ancient and veteran trees, blanket
bog, limestone pavement, sand dunes, salt marsh and lowland fen.”

Chalk streams are notably absent from the list of irreplaceable habitats. We do not believe that this
is because they fail to meet the criteria. Chalk streams satisfy every element of the criteria.
Rarity
Eighty-five percent of the world’s chalk streams are found in England. With only around 200 chalk
streams in the world, we have a unique national duty to protect chalk streams.
Cannot be successfully created, and have been established for a very long time
These rivers 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. The plant and animal communities
that have adapted to the flows and features of chalk streams are very sensitive to the impacts of
development (such as disturbance, pollution and over-abstraction) and the rivers’ crucial gravel
beds, if removed, cannot be replaced through natural processes.
Support important and/or rare species
Chalk streams are Britain's most biodiverse freshwater system and provide habitats for rare,
designated priority species including water vole (protected under the Wildlife and Countryside Act
1981 and listed as endangered on both the Great Britain and the England Red List for Mammals)
and genetically distinct Atlantic salmon (listed as endangered by the IUCN). They also support
populations of the threatened native, white-clawed crayfish (protected under the Wildlife and
Countryside Act and the Conservation of Habitats and Species Regulations 2017 and as Endangered
on the global IUCN Red List of Threatened Species).
The NPPF should provide unambiguous direction to planning authorities that chalk streams are
nationally important and irreplaceable habitats, whose protection and enhancement must be a
material consideration in planning decisions. Given this, I would be grateful if you could confirm
whether the Government considers chalk streams to fall within the NPPF’s definition of
irreplaceable habitats. If they are not currently considered to meet that definition, I would appreciate
an explanation of the basis for that view, and a commitment to correct this at the next opportunity to
review or amend the Framework’s list of irreplaceable habitats.
I look forward to sharing our further priorities with you as our programme of work develops, and
would welcome the opportunity to update you in-person whenever this would be of use.
Yours sincerely,
Sarah Green MP
Member of Parliament for Chesham and Amersham constituency