Drawing on input from across our membership, the response supports the direction of reform while identifying key areas where further strengthening is needed to support effective delivery.

Key recommendations from NIPA:

• Clearer, more directive guidance to reduce ambiguity and improve consistency in how HRAs are applied in practice
• Stronger alignment across regimes to ensure consistency with NSIP guidance, marine planning frameworks, and National Policy Statements
• More proactive engagement from authorities and SNCBs, with clear expectations for early, solutions-focused collaboration
• A more proportionate approach to evidence and precaution, clarifying how ‘reasonable scientific doubt’ and best available evidence should be applied in practice
• Better support for delivery including clearer guidance on reuse of HRAs, in-combination assessment, and securing compensatory measures

NIPA also highlighted the need for specific attention to offshore development and the importance of ensuring the guidance is practical, consistent, and aligned with the Government ambitions for infrastructure delivery and environmental protection.

NIPA is committed to working  collaboratively with DEFRA to support the next stage of developing the guidance, including testing how proposed approaches will operate in practice.

We would like to thank the volunteer members from across our membership who generously contributed their time, expertise, and thoughtful insights: Imogen Dewar, Matt Fox, Alex Tresadern, Jan Bessell (Pinsent Masons), Ifeanyi Chukwujekwu (WSP), Sarah Drljaca (Ørsted), Paul Maile (Eversheds), Kevin Gibbs (Charles Russell Speechlys LLP), and Peta Donkin (Arcadis).