APPENDIX 24
Memorandum from the Woodland Trust
The Woodland Trust welcomes the opportunity
to feed into this inquiry. The Trust is the UK's leading woodland
conservation charity. We have four main aims: no further loss
of ancient woodland, restoring and improving woodland biodiversity,
increasing new native woodland and increasing people's understanding
and enjoyment of woodland. We own over 1,100 sites across the
UK, covering around 19,000 hectares (47,000 acres) and we have
300,000 members and supporters.
Are the conclusions of the Barker Review
compatible with the general principles of sustainable development
and the Government's own sustainable development objectives?
The conclusions of the Barker Review do not
go any where near far enough in emphasising the need for environmental
enhancement and protection to be central to the house building
agenda. Being primarily concerned with economic and then social
issues it ignores two of the four central pillars of the Government's
own concept of sustainable development: effective protection of
the environment and prudent use of natural resources. Additionally,
the conclusions also seem to be at odds with the ODPM's new PSA
target following its SR 2004 settlement which emphasises the need
to link affordability with protection of valuable countryside
along with an enhanced focus on liveability and the importance
of green spaces.[42]
We believe that if the Barker Review were to be implemented without
change this would be incompatible with the Government's sustainable
development objectives.
In view of the Barker Review is there are
need for an overarching national strategy to ensure that the environment
is at the heart of any building programme?
We believe that it is vital that any building
programme does contain the environment at its heart. A move towards
better integration of objectives from the ODPM and Treasury with
those of Defra and the Sustainable Development Commission is essential.
ODPM, the Department for Transport and the Treasury should all
have environmental protection and enhancement at the centre of
their objectives and policies. A national strategy for environmental
protection would be a welcome addition to Government policies.
However, a simpler and quicker first step would be to ensure that
any house building programme has sustainability at its heart as
a key principle.
Sustainability is not just about sustaining
development or providing affordable housing it must be about environmental
protection and enhancement. A key outcome of having sustainable
principles at the heart of any house building strategy would be
that higher proportions of houses would be built on brown field
land and that loss of irreplaceable habitats such as ancient woodland
would be avoided. The Barker Report should not be taken forward
without regard to these principles which are firmly anchored in
sustainable development.
Is the current planning system robust enough
to ensure that the environmental implications of building projects
are fully taken into account?
We are concerned about the recent reforms to
the planning system enshrined in the Planning Act. Although there
is now a strengthened purpose to planning that planners must pursue
their tasks with the objective of achieving sustainable development,
moves to scale back the scope of planning and speed the system
up may well result in weaker environmental protection. It is essential
that key pieces of planning guidance such as PPS9, which is currently
being revised are sufficiently robust to protect irreplaceable
habitats.
How can the planning system be used to increase
the building of more sustainable housing? Would the proposed changes
to the planning system in the Barker Review have a positive or
negative effect on the environment?
The proposals in the Barker Review for reforming
the planning system would almost certainly have a negative effect
on the environment as the Review focuses very heavily on economic
concerns. In fact the reform proposals are contrary to the principles
of sustainable development in that they suggest that the planning
system should be more market led. While this may the case for
ensuring provision of housing, this approach would not provide
for strong environmental protection. Planning should be about
placing necessary development in the optimum location from an
environmental point of view. The Review does specifically state
that all restrictions on land use should not be removed, however
it does not adequately address the need for environmental protection
to be at the heart of planning. The Royal Commission on Environmental
Pollution's report on Environmental Planning[43]
showed how the planning system could be an extremely valuable
tool for sustainability. The Government so far does not appear
to have understood this to be the case and the Barker Review confirms
this suspicion.
Where will the proposed new housing be built?
What are the implications for land-use and flood risk of the large-scale
proposed building projects?
We believe that it is essential that new housing
be built in such a way that it avoids destroying valuable semi-natural
habitats. Ancient woodland is land that has been continually wooded
for at least 400 years. Once it is lost it cannot be replaced.
Planners and policy makers must be aware of the fact that promoting
new planting of trees, welcome though that is, will never be a
substitute for protection of the irreplaceable. This is critical
to fulfilling the ODPM SR 2004 statement that: "It is important
that new housing development is sustainable".[44]
Is it possible to ensure materials and resources
used, and waste produced, during building do not have a harmful
impact on the environment?
There should be move towards use of sustainable
materials such as certified timber. Timber is a more sustainable
material to use than steel or aluminium for building, however,
there must be clear guidance that all timber must be FSC certified.
How will it be possible to ensure a sustainable
infrastructure, including transport and water supply, which will
be necessary to support any extensive house building, is put in
place?
Again careful strategic planning is essential
to ensure that supporting infrastructure does not destroy valuable
habitats. The Trust has become aware of over 300 cases of ancient
woods under threat over the past three years and the majority
of these cases are from roads. It is vital that a holistic strategic
view of new developments is taken to ensure that not only is the
main development placed in a sustainable location but that supporting
infrastructure is sustainable too.
July 2004
42 HM Treasury 2004 Spending Review p.110 ODPM Box
10.2. Back
43
Royal Commission on Environmental Pollution (2002) Twenty Third
Report Environmental Planning. Back
44
HM Treasury 2004 Spending Review p 109 ODPM para 10.8. Back
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