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The myth of mitigation and the Gwent Levels

05 Mar 2024 3 minute read
Gwent Levels Photo Neil Aldridge

Mike Webb, Gwent Wildlife Trust planning manager

Anyone involved in planning issues, whether as an objector to a planning application, a local authority planner or an inspector will be familiar with the concept of “mitigation”, and I’m no exception.

There are many definitions of mitigation, but my favourite lay description of it is “making a bad thing less bad”. It stands to reason that if your development is going to damage nature, if there are things that you can do to reduce that damage, then surely you should do them, right?

For many of the hundreds of planning applications throughout Gwent, that is a logical and sensible approach – who wouldn’t want to tweak the design of a development, add a few techno fixes, and chuck some cash at the problem.

Afterall, the Welsh planning system has a presumption in favour of (sustainable) development, hasn’t it?


But with such a fragile and complex wetland ecosystem as the Gwent Levels SSSI, that logic unravels. For starters, “making a bad thing less bad” doesn’t apply, because a less bad thing is still bad! SSSIs such as the Gwent Levels are supposed to be the absolute jewels in our nature crown here in Gwent, in Wales and in the UK.

Would you try to justify tearing a strip out of the Mona Lisa on the grounds that you actually wanted to tear a bigger strip out of it, but a smaller strip is “less bad” ? Or knocking just a small lump out of Stonehenge?

Secondly, so many well-recorded factors conspire against “mitigation” in SSSIs that the surprise is not that it doesn’t work, but that anyone would ever have thought that it might.

The tweaks and techno-fixes don’t work or are unproven, the planning conditions aimed at delivering them are ambiguous, and the authorities tasked with designing, implementing, and enforcing them are underfunded and lack the skills, experience and confidence to challenge large, well-funded developers.

Staff move on, the cash runs out, documents are lost, post construction monitoring methods turn out to be deficient: the list goes on.

And no one cares anyway, because the development cannot be dismantled with a monkey wrench and towed away on castors when it turns out that the mitigation hasn’t worked. The development is sold on, and sold on again: in a few short years, neither the developer nor the authorities can remember or work out what the “mitigation” measures were meant to achieve.

Destroying nature

Life goes on: ecological consultants move on to the next exciting “sustainable” development, with ground-breaking mitigation built in. Staff retire, and all too soon the development seems as if it’s been there forever. And it is there forever – forever polluting the wetland, destroying nature and damaging the SSSI.

Only the community remembers the wheeling lapwings, the shrill carder bees, the glittering dragonflies, the skylarks and boxing hares.

We at GWT think that mitigation should have no place in “delivering” planning applications on the Gwent Levels. In fact, we believe strongly that major development has no place in our beautiful, fragile Gwent Levels SSSI.


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Richard Davies
Richard Davies
4 months ago

A great opinion piece from Mike and I completely agree with the sentiment expressed!

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