Category: Nature recovery

Picking Up The Bill: What Are We Now Thinking About Part 3?

As in the Planning and Infrastructure Bill. And as in how much is the bill and who pays it?

There has been much noise over Part 3 of the Planning and Infrastructure Bill (“development and nature recovery”) since the Bill was introduced into Parliament on 11 March 2025. For what it’s worth (maybe not a lot), I’ve been trying to work out what I think.

If you would like a summary of Part 3 as introduced, please see colleague Susie Herbert’s 13 March 2025 guest blog post PI Bill Guest Post – Some Early Thoughts On The Bill’s Nature Recovery Provisions. I then summarised some of the criticism of Part 3 in my 11 May 2025 blog post, Nature Recovery Position.

On the day that the Lords Committee stage started, 17 July 2025, the Government tabled a series of amendments to Part 3, seeking to strengthen it – see Summary: Planning and Infrastructure Bill, Government Amendments to Part 3 (Lords Committee Stage) (17 July 2025) and the amendments themselves tabled for Committee on 17 September (those tabled by Baroness Taylor relating to clauses 55 to 85).

The amendments had followed discussions with conservation groups and environmental bodies (see e.g. UK government putting pressure on nature groups to drop opposition to planning bill (16 July 2025)). The Office for Environmental Protection welcomed the proposed amendments in a statement  published that same day, 17 July 2025:

“The Office for Environmental Protection (OEP) has written to government to welcome its proposed changes to the Planning and Infrastructure Bill. 

In advice to government on the Bill in May, the OEP identified a number of areas where it advised environmental protections should be strengthened, while recognising the government’s intent to secure ‘win-win’ outcomes for development and for nature. 

Government has now published details of a series of proposed amendments to the Bill. 

OEP Chair Dame Glenys Stacey said: “The government’s amendments go a long way towards addressing the issues we raised in our advice. 

“I have written to Matthew Pennycook, Minister for Housing and Planning, to acknowledge the significant extent to which government has taken positive steps in response to our advice. 

“The Bill sets out government’s intention to strike a different balance between risk and opportunity for nature protection and for development. 

“While it is our view that, even after the material amendments the government proposes, the Bill would, in some respects, lower environmental protection on the face of the law, we think that, in the round, the additional safeguards proposed today make government’s intended “win-win” for nature and the economy a more likely prospect.

“Should the Bill receive Royal Assent, the practical implementation of the new measures will be key. We will continue to watch closely and to scrutinise how this significant change in environmental law is implemented.” 

That may be said to be a rather limp thumbs-up, but it is certainly a thumbs-up. Given that the Environment Act 2021 gave the OEP the principal objective, in exercising its functions, of contributing to environmental protection and the improvement of the natural environment, and given that its role includes giving advice as to proposed changes in environmental law, and given that the OEP will, I have no doubt, scrutinise implementation every step of the way, one might take some comfort from that position.

However, the amendments haven’t completely quelled concerns. For example, see the statement by CIEEM (i.e. the Chartered Institute of Ecology and Environmental Management) published on 18 July 2025:

“We believe that the Government’s proposed amendments still fall short. They fail to guarantee the vital safeguards nature needs, fail to preserve hard-won protections for species and habitats, and overall, still represent a step backwards for environmental standards in England.  And let us not forget that these environmental standards deliver significant economic, health and wellbeing benefits for us all. This battle has not just been about protecting nature for nature’s sake, but also protecting the vital benefits and services that nature provides.

While the proposed improvements to Environmental Delivery Plans (EDPs) are a step in the right direction, major flaws do remain.

Most notable is the glaring absence of the mitigation hierarchy – a cornerstone of current environmental protections. Without it – and the imperative to avoid adverse impacts on biodiversity from occurring in the first place – the Bill opens the door to the devastation of some of our most important natural sites and species. And whilst we note the Ministerial Statement recognises the use of the mitigation hierarchy in EDP development, such Statements are too easily reversed and do not have the strength of primary legislation.

Equally important, is the need for EDPs to guarantee that environmental compensation and enhancement happen before any damage is done – so as to avoid a dangerous nature deficit and to protect vulnerable species from local extinctions.”

One of the Part 3’s most vocal critics is solicitor Alexa Culver, legal counsel at RSK Wilding, a company which uses “habitat restoration as a means of offsetting clients’ biodiversity and carbon impacts while concurrently generating other environmental and social benefits”. Alexa certainly knows her stuff and posted on LinkedIn on 18 July 2025 her “Legal Analysis of Government’s Proposed Concessions to Part 3 of the Planning and Infrastructure Bill”. It is worth a read but in summary her concerns assert the lack of “any legally meaningful protections for habitats and species, or our environment”;  that Part 3 would “override any requirement for a “mitigation hierarchy”; that “irreplaceable habitats remain unprotected”, that there “remains no legal liability on any party to deliver compensation measures under an EDP”, creating “unacceptable risks for developers, who may see planning permissions refused because EDPs are failing”, and that in the case of a failing EDP “remedial action may not take place until 10 years after unmitigated harms to nature have occurred”.

The Chancellor possibly didn’t calm the debate by then positing the issue as people in housing need versus snails; Rachel Reeves defends retreat over planning bill as tactical move to speed up reforms (FT, 22 July 2025):

“Chancellor Rachel Reeves has claimed the UK government made a tactical retreat over its flagship planning bill in an attempt to speed it on to the statute book.

Ministers have been accused of watering down provisions in the bill, but Reeves on Tuesday said she hoped that the concessions would help “shave off a couple of months” of parliamentary wrangling in the House of Lords.

“I care more about the young family getting on the housing ladder than I do about protecting some snails,” she told an end-of-term hearing of the Lords economic affairs committee.”

The Lords Committee stage hasn’t yet reached Part 3; this will not be until September.

It’s interesting and, I would say positive, that the OEP posits that the “the additional safeguards proposed … make government’s intended “win-win” for nature and the economy a more likely prospect.” The truth is surely that without these measures we just carry on in a lose-lose position? We’re not really protecting or improving the environment; we’re not building homes.

Bear with me:

First of all, what is the issue which I think that the government is trying to solve by way of Part 3, or at least what I think Part 3 should be focusing on?

There is a lot of abstract talk, but surely at the heart of it all is the specific “appropriate assessment” test in regulation 63 of the Conservation of Habitats and Species Regulations 2017: basically prohibiting an authority from approving “a plan or project that is likely to have a significant effect (either alone or in combination with other plans or projects)” on a European site or a European offshore marine site (i.e. basically a special area of conservation or special protection area) unless it has “ascertained that it will not adversely affect the integrity of the European site or the European offshore marine site (as the case may be).”  The only exception is almost impossible to meet – if the authority:

“is satisfied that, there being no alternative solutions, the plan or project must be carried out for imperative reasons of overriding public interest (which, subject to paragraph (2), may be of a social or economic nature), it may agree to the plan or project notwithstanding a negative assessment of the implications for the European site or the European offshore marine site (as the case may be).

(2) Where the site concerned hosts a priority natural habitat type or a priority species, the reasons referred to in paragraph (1) must be either—

  1. reasons relating to human health, public safety or beneficial consequences of primary importance to the environment; or
  1. any other reasons which the competent authority, having due regard to the opinion of the appropriate authority, considers to be imperative reasons of overriding public interest.”

So (1) we have a test which, unusually, is substantive rather than just procedural – there is no such “pass/fail” test in relation to anything to do with, say, approving projects which may endanger human health or the most precious and unique of heritage assets.

(2) We have a test which has come to be interpreted extremely strictly by way of European and domestic case law – see e.g. the 2018 CJEU Dutch nitrates deposition cases (concerning authorisations for schemes for schemes for agricultural activities in sites protected by the Habitats Directive and where nitrogen deposition levels already exceeded the critical load) and all that has followed.  

(3) Largely due to systematic under-investment and mismanagement by successive governments in relation to the regulation of the water industry, of farming processes and of the use of fossil fuels, the ecological integrity of various special areas of conservation and special protection areas is already at or beyond tipping point, leading to the various de facto recommended vetoes on development by way of advice from English Nature: nutrient neutrality requirements in some areas, water neutrality requirements in others (NB the Chancellor’s “homes vs snails” comment is directly relevant to the north Sussex situation), restrictions on additional traffic generating development due to issues of nitrogen deposition in others and in yet others restrictions on homes due to the risk of additional recreational pressure on specific protected sites.

(4) Due to organisational inertia and possibly the lack of prioritised resources, authorities, often working with Natural England and/or the Environment Agency and other bodies, have been slow (at best – sometimes AWOL) in arriving at strategic schemes to mitigate or avoid adverse effects, meaning these vetoes on house building  as well as, often, other forms of development, stay in place for years, with only the largest of individual projects able to arrive at a site-specific means of passing the “appropriate assessment” test, often with a consequent hit to viability affecting for instance the level of affordable housing that can be provided. Maybe – local politics – it even suits some local authorities to have those vetoes remaining in place?

I have written about this repeatedly. Stuck record.

29 June 2019 Another Green World: The South Coast Nitrate Crisis

9 October 2021 Development Embargos: Nitrate, Phosphate & Now Water

18 March 2022 New NE Nutrient Neutrality & Recreational Impact Restrictions (+ DEFRA Nature Recovery Green Paper)  

26 March 2022 More On That Natural England Advice

16 July 2022 Neutrality

All this time, a lose-lose.

The previous government snatched at a solution to the nutrients issue, which I described in my 29 August 2023 blog post The Government’s Big Move On Nutrient Neutrality – Now We Have Seen The Government’s LURB Amendment – which envisaged simply excluding from the “appropriate assessment” test any “potentially adverse effect on a relevant site caused by nutrients in urban waste water, whether alone or in combination with other factors.” This was so much more radical – and environmentally regressive – than anything proposed within Part 3 of the current Bill. Of course, it was decisively defeated in the Lords – see my 16 September 2023 blog post NN No.

We do need a solution! The Conservatives’ solution was never going to work. To the extent that Part 3 would enable the Secretary of State to give Natural England the role of coming up with tested plans, with strategic solutions to secure the recovery of special areas of conservation and special protection areas and to arrive at mechanisms for securing contributions from developers towards those measures – allowing individual developers having diffuse off-site impacts of the ecological condition of those sites to know that the “appropriate assessment” test is not for them to address (unless they want to embark on a site-specific solution) and that they can simply pay their way – I am supportive of Part 3. As OEP concludes, a win-win.

My concerns are probably coming from a different place to some of the opponents to Part 3:

  • I have deep scepticism as to how quickly or pragmatically these plans will in fact be delivered by Natural England, without a significant ramping-up of the organisation’s capacity and capability. And notwithstanding environmental campaigners’ concerns that Natural England will in some way, without specific legal duties, be soft as to what they require, the reality is surely that, far from for instance not applying the mitigation hierarchy or allowing irreplaceable habitats to be harmed, there is surely as much of a risk that they will “gold plate” what is required.
  • Is the Government being too ambitious in its framing of Part 3 as enabling EDPs not just to address these specific “diffuse off-site impacts” situations I have focused on in this post, but enabling them to address the ecological value of the particular development site itself, reducing the amount of on-site assessment required? For myself, I do still wonder whether this goes too far and whether, in any event, this will not in practice be the focus of initial EDPs.

Agree or disagree? Planning lawyer blog writers are certainly not a species with any form of protection so please do your worst.

Simon Ricketts, 3 August 2025

Personal views, et cetera

Nature Recovery Position

Part 3 of the Planning and Infrastructure Bill is possibly facing the most criticism. Do its provisions with regard to the preparation of environmental delivery plans, enabling a nature restoration levy to be set which is to be paid by developers in lieu of some of the site-specific assessment and mitigation measures they currently have to carry out, go too far and amount to a regression in environmental protection?  

First, as a way into the issues, I do recommend my colleague Susannah Herbert’s summary and initial critique of the provisions published the week that the Bill was introduced into Parliament:  PI Bill Guest Post – Some Early Thoughts On The Bill’s Nature Recovery Provisions (13 March 2025)

The government has published a fact sheet.  It summarises the five key phases of the nature recovery fund as follows:

  1. Framing the EDP – EDPs will define the environmental impacts they cover, such as nutrient pollution or the impact development might have on a protected species. EDPs will be spatially specific with clear maps setting out where development is covered by an EDP and what scale of development the EDP can support.
  2. Designing the measures – EDPs will set out the suite of conservation measures that will be deployed to more than address the impact of development across a given area. For example, an EDP covering nutrient pollution will set out how the combined effect of the conservation measures will go beyond the current expectations of nutrient neutrality and lead to an improvement in water quality.
  3. Setting the levy rate – A simple charging schedule, sufficient to cover the costs of the conservation measures, will be payable by developers to meet the relevant legal obligation associated with the impacts addressed by the EDP.
  4. Consultation and approval – in developing an EDP, Natural England will benefit from views captured through consultation before the EDP is submitted to the Secretary of State for approval. When considering the EDP, the Secretary of State will be bound by a new legal test to ensure that the conservation measures outweigh the negative effect of development.
  5. Delivering on the EDP – once the EDP is in place, Natural England will the necessary powers to use funds collected to implement the conservation measures. They will then monitor the impact of the measures to ensure they are working as expected and make any amendments to the EDP that may be necessary.

The Bill is currently at Committee stage. Marian Spain, chief executive of Natural England, gave evidence on 24 April 2025, supportive of the proposals in the Bill. However, there are many who are expressing concern.

Instructed by NatureSpace Partnership, which delivers strategic licensing in relation to great crested newts and other species, David Elvin KC has provided a masterly and detailed (45 page) opinion dated 23 April 2025. He concludes that the proposals as they currently stand would amount to a weakening or reduction in current levels of environmental protection: the proposed test of “overall improvement” in environmental protection is “lax” and “generalised”.

The Office for Environmental Protection’s advice to the government on the Bill  (2 May 2025) echoes this concern: The OEP is “concerned by several aspects of the bill which undermine its potential to deliver intended win-win outcomes. We recognise that the EDP system is intended to be a different approach, not a direct comparator to existing environmental law. There are, though, fewer protections for nature written into the bill than there are under that existing law. Creating new flexibility without sufficient legal safeguards could see environmental outcomes lessened over time. And aiming to improve environmental outcomes overall, whilst laudable, is not the same as maintaining in law high levels of protection for specific habitats and species.

In our considered view, the bill would have the effect of reducing the level of environmental protection provided for by existing environmental law. As drafted, the provisions are a regression. This is particularly so for England’s most important wildlife – those habitats and species protected under the Habitats Regulations.

We summarise two particular concerns below, and provide further detail on these matters and other aspects of the bill in the annex to this letter.

A principal area of concern lies with the framing of the bill’s ‘overall improvement test’ for adopting EDPs. This test rests on a balancing exercise to decide whether negative environmental effects of development are likely to be outweighed by conservation measures taken under an EDP. As drafted at the moment, that exercise would allow considerably more subjectivity and uncertainty in decision-making than under existing environmental law. We advise that the overall improvement test should be strengthened to address this.

The bill as drafted also allows for conservation measures to be located away from the protected sites affected by development. Currently, this is only permissible in limited circumstances and where the overall coherence of the protected site network is maintained. Such safeguards are absent from the bill. Undermining the network of protected sites could affect the Government’s ability to meet its legally binding biodiversity targets and ‘30 by 30’ objectives. We advise that the lack of safeguards for the overall sites network is rectified, given the role they play in efforts to meet statutory nature targets.”

The OEP sets out, in an Annex to the letter, various detailed recommended changes to what is proposed.

More recently, the government has now published its impact assessment  in relation to the Bill (6 May 2025).  Section 7.2 is relevant for our purposes (NPSV = “Net Present Social Value (NPSV) in 2025 prices with 2026 base year across the 10-year appraisal period 2026-35”), EANDCB = “Equivalent Annual Net Direct Cost to Business” and EANDCH = “Equivalent Annual Net Direct Cost to Households”):

Incidentally, some groups and media pieces (eg UK government admits almost no evidence nature protections block development (The Guardian, 7 May 2025)) have misconstrued that reference to “limited data availability”. I agree that the statement is somewhat of a cop-out (and the range given absurdly wide) but the footnote makes it clear that the figure is expected to be a significant underestimate. For the real effects arising from nutrient neutrality alone see eg the work by the HBF and as for water neutrality see the recent failure at examination for instance of the Horsham local plan and many individual stalled schemes.

Is there a middle ground here? Should EDPs and the nature restoration funds, rather than ambitiously seeking to remove the need for developers to assess and address the specific effects likely to arise as a consequence of the species and habitats on their development sites themselves, in fact focus on those off-site issues which have indeed been causing so much delay and uncertainty: nutrient neutrality, water neutrality and issues relating to recreational pressure?  After all it is these aspects which the impact assessment focuses on:

“The Nature Restoration Fund is expected to deliver benefits to areas where particular environmental obligations apply, for example, nutrient neutrality catchment areas. While some urban areas are in nutrient neutrality catchments (Southampton, Portsmouth, Norwich and Middlesborough), the majority of land area covered by nutrient neutrality catchments is rural. In some cases entire LPA areas are within nutrient neutrality catchments, where obligations limit ability to deliver those LPAs’ housing targets. The largest nutrient neutrality catchments (by hectare) are Solent, River Eden Special Area of Conservation (SAC), Somerset Levels & Moors Ramsar. The location of the interventions secured under the NRF will be determined by the scale of the delivery plan area.” (Paragraph 69)

I can see that in some circumstances nature recovery objectives can be secured more efficiently and effectively on a coordinated basis. The impact assessment says this:

“…the Nature Restoration Fund measures aim to improve environmental outcomes by requiring developers to contribute towards nature recovery. By shifting to a strategic approach to addressing environmental obligations, coordinated by a single delivery body, action will be more efficient and effective – achieving more with the same cost to developers. It is therefore expected that these measures will contribute to meeting the Government’s wider environmental targets and help secure the benefits derived from biodiversity and ecosystem services more effectively. For example: wetlands can effectively regulate flow of water which enhances resilience to flooding; forests, oceans and healthy soils sequester carbon, reducing greenhouse gases in the atmosphere; peatlands act as carbon stores; restored vegetation stabilises soils reducing erosion and improving water quality; and natural landscapes offer spaces for outdoor recreational activities like hiking and birdwatching. These activities promote physical and mental well-being and provide benefits through tourism-related revenue. This policy is also designed to speed up the delivery of net zero infrastructure (alongside other development), and in doing so support decarbonisation.” (paragraph 77)

But should any of this replace on-site assessment and on-site mitigation, save where it can be shown that off-site mitigation will in fact be as effective? And wouldn’t this also be fairer, rather than, presumably, some developers having to over-pay to compensate for others seeking to develop more ecologically sensitive sites?

Simon Ricketts, 11 May 2025

Personal views, et cetera

PI Bill Guest Post – Some Early Thoughts On The Bill’s Nature Recovery Provisions

I’m away this week of all weeks but I thought I would share my Town Legal colleague Susannah Herbert’s early thoughts on Part 3 (development and nature recovery) of this week’s Planning and Infrastructure Bill. This is not intended as a full summary – there are plenty of those already.

Part 3 of the Bill sets out provisions to provide for the strategic approach to addressing environmental impacts along the lines set out in the Development and Nature Recovery Planning Reform Working Paper published in December 2024.  This relates to protected sites and protected species under the Habitats Regulations, the Wildlife and Countryside Act 1981 and the Protection of Badgers Act 1992 so it will not affect areas or species not covered by this legislation or other EIA requirements.  It applies to “development” as defined in section 55 of the TCPA 1990 and also development within the meaning of the Planning Act 2008 (section 32) and listed building consent under section 8 of the Planning (Listed Buildings and Conservation Areas) Act 1990.

The principle is that Natural England is to put in place Environmental Delivery Plans (“EDPs”) which set out “conservation measures” to address certain identified “environmental impacts” of development on “environmental features” within a specified area and developers within that area then pay a “nature restoration levy” to fund the implementation of the EDP instead of having to carry out appropriate assessment or obtain protected species licences on a site by site basis. 

The government believes that facilitating a more strategic approach to the discharge of environmental obligations will result in improved environmental outcomes being delivered more efficiently and reduce delays to development caused by lack of mitigation for example in respect of nutrient neutrality. 

Much of the detail about the payment of the levy is to be contained in “nature restoration levy regulations” which would set out details concerning liability, matters that Natural England must have regard to in setting the amount of the levy, appeals in respect of the levy, use of the levy, collection, enforcement and compensation (for loss resulting from enforcement action).   The government may also give guidance to Natural England about any matter connected with the levy.

The implications of these provisions are potentially extremely significant for both developers/ landowners and for nature recovery and whether the impact will be positive or negative will depend very much on the implementation and scope of the EDPs.  The win-win scenario of improved environmental outcomes with lower cost and delay for developers may be achieved if strategic mitigation is effectively identified and implemented and the levy charged to developers is more cost effective than it would be to provide the mitigation on-site.  However, it is also possible that the levy will need to be set at an unviable level, that the conservation measures are not effectively implemented at the same time as removing protections from protected species and habitats and that the loss of flexibility for developers has unintended consequences for viability and deliverability.

The Explanatory Notes include an example of how the proposals are intended to work based on nutrient pollution from residential development in a river catchment affecting a protected water course.  Part of an EDP may be the imposition of a condition on a planning permission which in the example could be that all houses include septic tanks.  The EDP would then provide for conservation measures such as the building of a wetland to be funded by the tariff.  The impact would be monitored and an extension to the wetland may be delivered if the main measures are not sufficient.  The payment of the levy would remove the requirement for an appropriate assessment to be carried out for the specific development.

However, many questions and potential issues remain. 

Cl. 61(4) allows for EDPs to be mandatory in a specified area (although this has to be justified).  This would remove the choice from developers to provide on-site mitigation even if this were preferable in nature recovery terms and more viable for the particular site. 

The charging schedule for the levy will be set for each EDP and for each kind of development to which the EDP applies.  Natural England must have regard, to the extent and in the manner specified by nature restoration levy regulations, to the actual and expected costs of the conservation measures proposed; matters specified in the regulations relating to the economic viability of development; and other actual or expected sources of funding for those conservation measures.  The regulations may permit charging schedules to operate by reference to descriptions of purposes of development; any measurement of the amount or nature of development; the nature or existing use of the site; inflation; by reference to values used for other statutory purposes ; or may allow for differential rates including provision for supplementary charges, a nil rate, increased rates or reductions. 

None of these matters are directly linked to the actual impacts of a particular development.  This may be appropriate where the relevant impact can be sufficiently and fairly estimated on the basis of e.g. the quantum and type of development taking into account the existing use of the land such as the example of residential nutrient pollution given.  However, in other cases such as in respect of protected species, the result may be that a development has to pay the levy to mitigate an impact on a species which was not present on the site in the first place or which would not be impacted by the development because of the design of the development.  It may be that the intention is that surveys are carried out as part of bringing forward the EDP to establish which parcels of land it should apply to but this would potentially result in unnecessary work if surveys have to be carried out over a whole area compared to surveying only those sites where development is proposed.  It is also not clear if the surveys would be kept up to date.  The Secretary of State may make further regulations regarding requirements for Natural England when preparing an EDP which may address some of these questions.

The strategic nature of the mitigation proposed to be provided begs another set of questions.  If a certain number of developments are required to contribute to fund the strategic mitigation, how will the sequencing work?  Will the impacts of the first developments remain unmitigated until sufficient development comes forward to fund the strategic mitigation (in which case how much damage will be done to protected species or habitats in the meantime)? or will the conservation measures be funded by the Government in anticipation of development (which may not materialise and therefore may end up being an unnecessary cost to the public finances)?  Both of these approaches are possible under cl. 66(4)  which allows for expenditure already incurred to be reimbursed and for money to be reserved for future expenditure.

The regulations may also make provision about payment in forms other than money (such as making land available, carrying out works or providing services) (cl 67(6)) which may allow part of the cost of the levy to be offset by on-site mitigation or potentially providing additional mitigation and somehow receiving credit for this although there is no clear mechanism for this to operate.

It should also be noted that Natural England would be given the power to compulsorily acquire land for purposes connected with the taking of a conservation measure (cl. 72).

Public authorities would be required to co-operate with Natural England in connection with the preparation or implementation of an EDP (cl. 75).  Natural England must publish a report for each financial year on the exercise of its functions in respect of these provisions (cl. 73) and the Secretary of State may also designate another person to exercise the functions of Natural England (cl. 74).

The Bill (cl 53- 60) sets out the process for preparation of an EDP, statutory consultation, making of the EDP by the Secretary of State based on an “overall improvement test”, publication, reporting, amendment, revocation and challenge.  There would therefore be opportunities for developers to make representations concerning a proposed plan possibly arguing that a particular allocated site should be excluded if on-site mitigation is proposed or presenting evidence as to viability in respect of the proposed levy.  There is also the potential to challenge a plan by way of judicial review which could potentially introduce a whole new set of delays to development.

Thanks for that Susie. This is now me again in this paragraph. Plenty more to cover both on this subject and the PI Bill itself. Aside from not having read the whole Bill itself yet (I know I know), I also haven’t read the Life of Pi by Yann Martel. I’m told by google that “its main message is that life can and will be difficult. However, people must persevere by any means necessary. Being adaptive and having faith in yourself and a higher power can help a person achieve any obstacle in their path.” How true. As in life so in planning and infrastructure.

Simon Ricketts, 13 March 2025

Personal views, et cetera