Think Global, Act Local, Reckon Regional

"Think global, act local" has been environmentalism's working instruction for half a century. The problem is that local decisions are usually judged locally: does this particular project, mitigation, or restriction make sense on its own?

Often it does.

A bat crossing is better than no bat crossing. A solar farm is better for the climate than no solar farm. Protecting a patch of habitat is better for the species using it than not protecting it.

But none of those answers tells us what all the individual decisions add up to.

To reckon regional is to keep that running total somewhere between the individual decision and the global goal — land taken, money spent, habitat affected, disruption imposed — and compare the next decision with what has already happened.

A defensible decision, an indefensible result

Start with the result.

A kilometre of railway track in Buckinghamshire runs beneath a curved mesh structure, ten metres high at its tallest, built so that one of Britain's rarest bats can cross safely overhead. The Sheephouse Wood Bat Mitigation Structure — the now-infamous "bat tunnel" — cost around £100 million in 2019 prices.

Natural England, the body responsible for protecting the Bechstein's bat, says it never required this particular structure. The UK's environment secretary called the spending "ludicrous." The Chancellor singled it out as a symbol of everything that makes British infrastructure too slow and too expensive to build.

And the tunnel was only one decision inside a much larger process. HS2, the high-speed railway being built between London and Birmingham, required 8,276 separate consents.

That leaves a larger question than whether £100 million was too much to spend on one bat crossing: how does a process made up of individually defensible decisions produce a result that even many of the people responsible for the system have struggled to defend?

Bechstein's bats are rare and protected by law. The railway crosses their woodland. Mitigation was warranted; HS2's own ecologists identified the need in 2013, long before the cost became controversial.

Nobody needs to have lied, acted in bad faith, or made an obviously irrational decision for the outcome to go wrong. Each participant can make a reasonable decision about the issue immediately in front of them while nobody decides whether all those decisions still make sense together.

That gap — between decisions that make sense individually and outcomes that do not make sense collectively — appears again in a very different argument over solar farms in New York.

What happened next

As the Planning and Infrastructure Act passed through Parliament, becoming law in December 2025, ministers cited the bat tunnel at least ten times in making the case for reform.

Among the Act's provisions is a new Nature Restoration Fund. Instead of every project designing its own mitigation in isolation, Natural England can draw up an Environmental Delivery Plan (EDP) covering a protected site or species. The EDP sets a maximum level of development that the site or species can absorb. Developers can then carry out their own mitigation or pay a levy that funds conservation measures under the plan.

That is close to the missing ledger: define the cumulative impact, set a limit, and judge each new project against what has already happened rather than as though it were the first.

Whether it will work that way is disputed. Conservation groups describe the system as "pay-to-destroy." Developers worry that it will not be established quickly or broadly enough to remove the delays it is supposed to address. The argument now includes a second question: once a cumulative number exists, what power should it actually have?

New York shows the same underlying problem at an earlier stage — over solar farms rather than trains and bats.

One column of the ledger

New York's Climate Leadership and Community Protection Act, passed in 2019, gave the state two headline targets: 70% of its electricity from renewable sources by 2030, and 100% zero-emission electricity by 2040.

Those targets are written into the Public Service Law, and the Public Service Commission must report on progress against them annually. Renewable generation therefore has an official running total: how much has been built, how much remains, and how quickly the gap is closing.

For years, one obstacle was local permitting. A town board could delay a utility-scale solar or wind project for years on grounds of disruption during construction, and subsequently appearance and land use.

In 2020, New York created the Office of Renewable Energy Siting (ORES) to remove that bottleneck. For projects of 25 MW or more, ORES can set aside local zoning it finds "unreasonably burdensome" relative to the state's climate targets, and it must decide each application within a fixed one-year timeline.

ORES has substantially accelerated state-level approvals. As of June 2026, it had permitted more than 30 large-scale projects and denied only one. Every approved project adds a known number of megawatts to a target the state is already required to measure.

One side of the ledger therefore has an official running total.

The column that's missing

The same permits contain numbers for the other side too.

Every ORES application includes an agricultural resources exhibit. Among other things, it records how much of the site falls within Mineral Soil Groups 1 through 4, which New York's Department of Agriculture and Markets describes as generally "Prime Farmland." The department's guideline is that no more than 10% of a project's area should fall into those categories.

Nobody at state level appears to add those figures up across projects.

The closest thing to a cumulative figure is a running tally kept by Roger Caiazza, an environmental analyst who blogs as the Pragmatic Environmentalist of New York. He built it by going through each permit's agricultural exhibit by hand.

At the time of writing, his tally covers 25 approved facilities with published data. Twelve meet the 10% guideline, including two with no prime-farmland impact at all. Across the others, he counts 6,650 acres of Prime Farmland converted to solar.

New York has started building something that addresses part of this problem. The New York State Energy Research and Development Authority (NYSERDA) is developing a Smart Solar Siting Scorecard intended to weigh these kinds of trade-offs.

By Caiazza's reading, though, the scorecard does not appear to set a threshold at which a project fails. More importantly, it still scores one project at a time. It can say whether a particular site is comparatively well chosen. It does not say how much prime farmland New York has used in total to get this far.

The agricultural exhibits are public and filed with every application. The information exists. What is missing is an official cumulative total used in the permitting process.

The figures above — 12 of 25 projects, 6,650 acres — are a 2026 snapshot and will change. New York's renewable target is statutory, official, and updated on a schedule. The farmland total exists because one analyst decided to compile it.

One number is part of the decision system. The other is not.

Neither a side nor a motive

There is another objection to consider: perhaps the numbers are only being demanded because somebody dislikes the project.

Environmental concerns are sometimes raised only after a particular project is proposed nearby.

But that is a different question from the one here.

A claim can be opportunistic and still point to a real accounting gap. Equally, a campaigner can be completely sincere and still be relying on a poorly defined or irrelevant number. Sincerity tells us something about the person making the argument. It tells us nothing about whether the cumulative total exists, whether the unit is well defined, or whether the number has any formal consequence once it is known.

The same applies to labels such as pragmatic environmentalism. Roger Caiazza, whose farmland tally was cited above, uses that description for his own approach: accept that development and protection both matter, and try to measure the trade-offs rather than argue from slogans. That is close to the argument being made here.

But a philosophy is not a mechanism. Caiazza can build a careful running total and publish it, yet the figure still has no formal role in New York's permitting system. Better analysis can identify the gap, but it cannot make the result part of the decision. That step is institutional: some body has to be required to keep the number, define what counts, and decide what happens when the total reaches whatever limit has been set.

Whether somebody is sincere is a question about the advocate. Whether the system keeps a cumulative account is a question about the system — and the answer does not change with the motives of whoever asks.

A test, not a verdict

The same four questions, applied to both cases:

• Does a cumulative number exist?
• Does the number have consequences?
• Who defines the unit?
• Is any body positioned to keep asking?

The Nature Restoration Fund

Start with the UK, where the response is furthest along.

Does a cumulative number exist? Yes, at least in principle. An Environmental Delivery Plan defines a "maximum level of development" for a protected feature. That creates an aggregate ceiling rather than treating each project as though nothing had happened before it.

Does the number have consequences? The Bat Conservation Trust objects that the Planning and Infrastructure Act never references the mitigation hierarchy — the principle that impacts should first be avoided and minimised before they are offset. Britain Remade, arguing from the opposite direction, wants the Secretary of State to be able to bypass the Habitats Regulations when mitigation is judged poor value for money. Both arguments turn on whether the ceiling actually constrains decisions.

Who defines the unit? Natural England draws up EDPs; the Secretary of State approves them. The institutions applying the limit therefore also help define it. Change what is measured, or what "maximum" means, and the apparent headroom can change without the underlying environment changing.

Is any body positioned to keep asking? Yes. The Bat Conservation Trust is already campaigning, publishing rebuttals, and briefing Parliament. That did not prevent the Act passing in December 2025. Having a constituency with standing doesn't guarantee the outcome that constituency wants. It does ensure that the rules themselves can be contested.

New York's farmland

Now New York, several steps further back.

Does a cumulative number exist? Partially. Caiazza's tally exists, but it is one person's spreadsheet rather than a regularly updated state total. Making the figure official would not predetermine what New York should do with it. The total might show ample headroom, or it might show a problem. An official total would not determine the policy. It would tell the state what cumulative position it was making that policy from.

Does the number have consequences? No. Caiazza's running total has no formal role in permitting. ORES already has the authority to make binding decisions and already considers project-specific agricultural impacts. What it lacks is a cumulative rule: given everything already approved, what does this next project do to the total? New York does not need a new permitting body to do this. ORES already makes the decisions; its remit would need to include cumulative impact as well as project-specific impact.

Who defines the unit? The 6,650-acre figure cited earlier is built on New York's Mineral Soil Groups 1 through 4 — a state agricultural-assessment classification that New York's Department of Agriculture and Markets describes as generally "Prime Farmland." The USDA has its own national Prime Farmland designation, covering a different set of land. The two definitions can produce different acreage totals. A future accounting system could reduce the reported loss simply by changing which definition of "Prime Farmland" it uses, without a single acre on the ground changing.

Is any body positioned to keep asking? New York is not starting from zero. State legislators have formally written to ORES asking for comprehensive data on projects affecting farmland and protected land — the asking stage. What is missing is a standing process that requires the cumulative total to be published, kept current, and considered when the next permit arrives. There are people asking the question. The system does not yet have to answer it.

One gap, two timetables

The two cases are at different stages of the same problem.

New York has project-by-project data but no official cumulative measure. Britain has created a cumulative mechanism and is now debating how strongly it will constrain individual projects.

That distinction matters. Producing the number is only the first step. Then come the harder questions: what counts, where the ceiling sits, who can change it, and what happens when it is reached.

If New York eventually creates a cumulative farmland measure, the British dispute points to the questions likely to follow: who defines the total, who sets the limit, and what happens when a project reaches it?

Reckon regional

Reckon regional does not mean splitting the difference between development and environmental protection.

Sometimes an agreed limit may mean development has to stop. Sometimes the running total may show ample headroom for another project. The point is not to force every decision toward the middle. It is to know the total, the limit, and what the next decision would do to both.

The two cases show what happens when that accounting is missing in opposite directions.

HS2 shows what happens on the development side of the ledger. Mitigation can become extraordinarily expensive when each requirement is justified separately and no programme-wide test asks whether the cumulative burden remains proportionate.

New York shows the opposite failure: cumulative environmental loss can remain invisible when every project is assessed individually but nobody keeps an official total of what all those approvals have consumed.

A regional ledger gives both sides the same starting point: how much has already been committed, what limit has been agreed, how much headroom remains, and what the next proposal would use.

Some body with authority has to keep that ledger, and the rules have to say what happens when the total approaches the limit.

Think global, act local — and reckon regional before the next individually defensible decision becomes part of an indefensible total.