Memorandum submitted by the Wildlife Trusts
INTRODUCTION
1. The Wildlife Trusts welcome the opportunity
to submit comments to the Environmental Audit Committee Inquiry
Sustainable Housing—A Progress Report.
2. The Wildlife Trusts are a unique partnership
of 47 local Wildlife Trusts covering the whole of the UK and the
Isle of Man and Alderney. The partnership campaigns for the protection
of wildlife and invests in the future by helping people of all
ages to gain a greater appreciation and understanding of nature.
Collectively, The Wildlife Trusts have more than 600,000 members
including 100,000 junior members. In addition, we manage almost
2,500 nature reserves, covering more than 80,000 hectares of land.
These include some of the UK's finest wildlife sites in both inner
city locations and rural areas.
3. We are active participants in the planning
system throughout the UK from the national to the local level.
Over the years our staff and volunteers have dedicated considerable
time and resources in many reviews of Structure Plans and Local
and Unitary Development Plans. Last year alone they reviewed over
88,000 planning applications, responded to 7,400 and believe they
influenced the decisions on over 1,900 cases to the benefit of
biodiversity. We are also engaging fully in the development of
Regional Spatial Strategies, Local Development Frameworks and
Community Strategies.
4. The Wildlife Trusts also play a leading
role in advocating the cause of environmentally sustainable development
at a local, regional and national level. Our extensive knowledge
of the natural environment and biodiversity resource of this country
combine well with our strong local partnerships allowing us to
bring a uniquely informed perspective to bear on how development
affects biodiversity and how the natural environment can contribute
to the achievement of social and economic objectives.
GENERAL COMMENTS
5. The Wildlife Trusts recognise how important
sustainable housing provision is in the face of increased development
pressures. If this can be successfully delivered it can enhance
both the environment and the quality of life in local communities.
A good example of this, and one in which the Wildlife Trusts have
been involved, is the development at Cambourne in Cambridgeshire,
which has also enhanced biodiversity in the local area.
SPECIFIC COMMENTS
Issue A: The Code for Sustainable Buildings
6. The Wildlife Trusts welcome the principle
of a new Code for Sustainable Buildings (CSB). We believe that
improved guidance on sustainable building practices could help
to improve standards in the built environment and act as a driver
to achieve better energy and water efficiency, limit waste and
provide more sustainable developments than the majority of those
currently undertaken. However, we also believe that the code should
include more specific measures to promote biodiversity conservation
and enhancement.
7. The Wildlife Trusts have used best practice
in sustainable building for new visitor centres and offices across
the country which provide exemplars of sustainable standards.
Examples include the new Attenborough Nature Centre in Nottinghamshire
and the Lancashire Wildlife Trust Headquarters.
Can a Voluntary Code possibly deliver the degree
of change needed in the building industry to achieve well designed,
energy efficient sustainable buildings which have minimal impact
on the local environment?
8. Unfortunately, we do not believe that
a voluntary code will deliver the degree of change necessary within
the building industry to ensure that the scale of development
proposed by government is carried out sustainably. The reason
for this is two-fold.
— Firstly, we do not believe the uptake
of a voluntary scheme will be wide enough to offset the damaging
impacts of those developments undertaken outside the CSB. Indeed
we find that the existing, and most welcome, BRE Eco-Homes scheme
does not appear to be used as widely as we would hope. This can
perhaps be attributed to the fact that it is voluntary and is
therefore only used by the enlightened or those forced to use
it for other reasons. We see no reason for the situation to be
different with a new voluntary code.
— Secondly, we note that the initial
outline for the code does not extend beyond energy efficiency,
water use and waste. It therefore fails to take account of wider
issues such as the impact of design, siting, massing, location,
access, and ecological impact and enhancement without which it
cannot deliver truly "sustainable" new buildings. This
must be rectified for the Code to be effective in helping to deliver
truly sustainable housing.
9. We do not believe that problems are isolated
to building design. We note for example that in the experience
of the Association of Wildlife Trust Consultancies (AWTC[26])
the ecological section of the Eco-Homes scheme is used largely
as a "bolt on" to gain points rather than to provide
significant environmental benefit. As a result the associated
surveys and recommendations often come too late in the process
to provide more than window-dressing to development. This is extremely
unfortunate and undermines an otherwise laudable voluntary code.
It is our belief that a similar scheme will be no more likely
to achieve a better level of success.
10. We would welcome further comment from
the Government regarding the use of the Eco-Homes assessment on
publicly funded housing. In particular we would be interested
to know why it requires these developments to meet only "good"
(or from 2006 "very good") standard when there is an
"excellent" standard that would presumably offer more
sustainable results. If the Government's own housing stock does
not meet the most stringent guidelines we do not think it likely
that the rest of the construction industry will either, especially
if the code remains voluntary.
11. Moreover we are concerned that this
lack of stringency could undermine the good works of local authorities,
for example Guildford Borough Council, that have already produced
Sustainable Development Supplementary Planning Documents designed
to guide developers towards the "excellent" standard
for the Eco-Homes and BREEAM schemes.
12. It is interesting to note also that
the initial outline for the CSB published by the Senior Steering
Group for the project suggests five "Guiding Principles"
for the code, none of which are related to sustainability but
all of which are geared towards making the scheme easy to manage
and easy to comply with. In our opinion this does not bode well
for the future and we are extremely concerned that the code might
be an opportunity missed.
13. The Wildlife Trusts recognise that there
are already many examples of good practice in sustainable building
design across the country and we would be keen to see these exemplars
used to inform the new code in a more positive way. Examples include
the London Borough of Enfield, where an authority-wide sustainable
building code offers useful advice to developers and others, and
the soon to be published technical guide to implementing Sustainable
Drainage Systems in "Kent Design".
14. With this in mind we are concerned that,
as proposed, the CSB, which the Government has made a key part
of its commitment to the sustainable delivery of its housing agenda,
will fail to be effective. We therefore urge the Senior Steering
Group responsible for the code to reconsider its terms and detail
and we would ask the Government to seriously consider making the
code mandatory for all new developments. In that way developers
and the building industry as a whole will be able to operate on
a level playing field with an agreed standard for all.
Is the Government doing enough to promote the
code, with the industry and the general public, ahead of its imminent
introduction early in 2006?
15. It does not appear so from our experience.
We have found few references to the code away from the technical
building press and it does not appear to have been widely reported
amongst our local planning contacts. This is worrying and we would
suggest that the Government do more to raise the profile of the
code, especially at the RSS and LDF level within the growth areas
in particular.
Issue B: Sustainable Communities: Homes For All
Does the ODPM Five Year Plan, Sustainable Communities:
Homes For All demonstrate a greater recognition of, and greater
commitment to tackling, the impact of increased house building
on the environment or does it merely pay lip service to it?
16. We do not believe that the ODPM's Five
Year Plan, Sustainable Communities: Homes for All demonstrates
a real recognition of, or commitment to tackling, the impact of
increased housing provision on the environment. The document appears
to be largely economically driven and fails to deal adequately
with the environmental impacts inherent in the Government's ambitious
development agenda. In particular we note that the headline pledges
made by the ODPM in Chapter 8: Enhancing the Environment place
significant weight on techniques and indicators which are unlikely
to be sufficient to tackle the wider issues, such as biodiversity
enhancement, which are associated with large-scale development.
In addition we fear that the consultation on delivering the housing
growth agenda (Planning for Housing Provision) and the Government's
reliance on economic drivers and speedy delivery of homes, apparently
with limited regard to the environmental consequences, call into
question the commitment given to making the Five Year Plan truly
sustainable.
17. We remain concerned that Sustainable
Development does not appear to be at the heart of government proposals
for housing, but rather seems to be seen as an add-on to be dealt
with once economic and social growth have been achieved. We fear
that this undermines Government's commitment to delivering sustainable
development in Planning Policy Statement 1 (Delivering Sustainable
Development) and to promoting planning policies and decisions
which maintain, enhance, restore or add to biodiversity and geological
interests (Planning Policy Statement 9—Biodiversity and
Geological Conservation).
Planning for Housing Provision.
18. In order to illustrate this we have
attached our response to the Planning for Housing Provision consultation
in Appendix 1 to this memorandum [not printed]. We feel that the
consultation document and our response to it provide a useful
example of why it appears to us that the Government lacks real
commitment to delivering sustainable housing development.
The new Green Belt Direction 2005
19. The Government has made much of its
increased commitment to protecting the Green Belt and we welcome
the increase in area that has so far been achieved. However we
remain concerned that the New Green Belt Direction does not go
far enough to protect this valuable urban fringe environment.
20. We commented more fully on the new Green
Belt Direction as part of the open consultation earlier this year
and we have attached our response in Appendix 2 [not printed]
of this memorandum. It is however pertinent to make clear the
fact that we do not share the Government's confidence in the likely
success of the proposed new measures to protect the Green Belt.
21. We would therefore welcome further clarification
from the Government on the new Direction and in particular how
the stated preferred option would contribute to the sustainable
development agenda.
To what extent does the Five Year Plan address
the environmental implications of the geographical distribution
of demolition verses new build?
22. We do not feel that the plan tackles
this important issue directly enough. However, our experience
suggests that reliance on the south east and midland growth areas
as the main locations for development is already leading to unsustainable
pressure on biodiversity and the environment. For example heathlands,
including those designated as SPAs and therefore of international
importance, are increasingly coming under pressure from, and suffering
the adverse effects of, increased house building both directly
in terms of habitat degradation and indirectly through increased
public pressure. The pressure on these delicate sites, including
Wildlife Trust reserves, has already reached a critical level
and we do not believe that this can be reconciled with the Government's
commitment to Sustainable Development.
Issue D: Infrastructure
23. The Wildlife Trusts recognise that the
timely provision of essential infrastructure is vital if the significant
planned development in the four major growth areas is to be sustainable.
We are particularly concerned however, that "Green Infrastructure"
(GI) is at risk of being missed out of the growth agenda in spite
of the absolutely crucial role it plays in embedding new development
within a sustainable and ecologically functional environment.
24. Green Infrastructure has been described
as "the sub-regional network of protected sites, nature reserves
and greenway linkages. The linkages include river corridors and
floodplains, migration routes and features of the landscape which
are of importance as wildlife corridors [and stepping stones].
Green Infrastructure should provide for multi-functional uses,
ie wildlife, recreational and cultural experience as well as delivering
ecological services such as flood protection and microclimate
control. It should also operate at all spatial scales from urban
centres through to the open countryside." (TCPA—Biodiversity
by design: A Guide for Sustainable Communities. TCPA 2004)
25. It is essential that strategic provision
is made for GI at the earliest stage of planning for new development
and that it is implemented as an integral part of all the growth
area plans. Failure to recognise the needs of the environment
and the benefits of GI to new communities will significantly undermine
the sustainability of planned growth and would appear to run contrary
to the Government's own sustainability agenda.
26. Examples of good practice already exist,
for example Planning Sustainable Communities: A Green Infrastructure
Guide for Milton Keynes and the South Midlands, and it is vital
that the Government commits further funding to help deliver GI
projects in all the growth areas.
27. We welcome the Government's commitment
to this through documents like "Greening the Gateway"
and we would hope to see continued support and promotion of this
important agenda. We believe that unless steps are taken to promote
GI and sustainability issues in general the very significant planned
growth will inevitably result in damaging developments that fail
to take proper account of the local environment. This would appear
to be at odds with the Government's stated position on Sustainable
Development and guidance given in PPS1 and PPS9.
28. Of particular concern is the effect
of damaging developments on Local Wildlife Sites, which are recognised
in PPS9 (paragraph 9) as having a fundamental role to play in
meeting overall national biodiversity targets. Yet unlike the
statutory sites they rely almost solely on the application of
strong planning policies to protect them from loss or damage.
Is the Government doing enough to secure sufficient
funds for the timely provision of infrastructure, such as transport
links, schools and hospitals in the four growth areas?
29. We anticipate that others will provide
more information regarding the typical infrastructure needs but
we believe that the government must do more to provide funding
for green infrastructure as well.
30. We welcome the fact that the ODPM's
Growth Area Fund has begun earmarking significant funds for green
infrastructure projects and that there are already projects under
way to deliver GI in growth areas. However, we fear that this
has not gone far enough to provide for this most important feature
of sustainable development.
31. We are concerned that short-term funding
of projects will not be sufficient to offset the significant GI
deficits in the current growth areas. Long-term commitment is
needed and we would welcome assurances from Government that this
will be forthcoming. Failure to provide joined-up and realistic
delivery mechanisms for GI projects would risk undermining their
value to the extent that they could become "window dressings"
for individual development rather than an important and integral
part of the wider sustainability agenda.
Are the water companies doing enough to secure
the supply of water resources to the four growth areas and is
concern about the south east of England a valid one or a knee
jerk reaction to a few hot dry summers?
32. We do not believe that the water companies
are currently doing enough to secure the sustainable supply of
water resources for the growth areas. However, we recognise that
they are hampered in their role by their statutory responsibility
to provide water if requested to. It is therefore extremely important
that the Government recognise and act on the environmental limits
associated with the growth areas and take action to ensure that
the developments proposed can be accommodated sustainably.
Is there sufficient effort being made by the Government
and the Environment Agency and water companies to educate people
about water efficiency?
33. We believe that more can, and should,
be done to educate the public but it is also important to recognise
that more can be done to promote water efficiency through Government
policy, the new CSB and Environment Agency responses to development
as well as through awareness-raising campaigns. Obviously the
vast majority live in homes that have already been built and for
these people better awareness is vital. However, it is also incumbent
upon policy-makers to drive standards up in new dwellings. This
is particularly relevant given the huge predicted growth in areas
that are likely to have significant water availability constraints.
We believe that the underlying message from Government should
be that if water resources cannot be sustainably secured significant
development should not be promoted.
November 2005
26 The AWTC is the association of Consultancy practices
attached to individual Wildlife Trusts. They offer a range of
professional ecological, landscape and planning services covering
the whole of the country. Back
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