Memorandum by English Nature, the Rural
Development Service and the Countryside Agency (Landscape, Access
and Recreation) (AH 19)
NATURAL ENGLAND
1. A new organisation—Natural England—is
being created with responsibility to conserve and enhance the
value and beauty of England's natural environment and promote
access, recreation and public well-being for the benefit of today's
and future generations.
2. The creation of the new organisation,
Natural England, has already begun, with English Nature, the Landscape,
Access and Recreation division of the Countryside Agency, and
the Rural Development Service working together as partners. This
natural partnership is delivering joint outcomes and paving the
way for Natural England, whilst continuing to deliver their separate
and respective statutory duties:
— English Nature is the independent
Government agency that champions the conservation of wildlife
and geology throughout England.
— The Rural Development Service is
the largest deliverer of the England Rural Development Programme
and a range of advisory and regulatory rural services.
— The aim of the Countryside Agency's
Landscape, Access and Recreation division is to help everyone
respect, protect and enjoy the countryside.
3. This evidence has been produced jointly
by English Nature, the Rural Development Service and the Countryside
Agency's Landscape, Access and Recreation division ("The
Natural England partners") who are working to create Natural
England, a new agency for people, places and nature.
4. This evidence is focussed on the following
issue as set out in the invitation to submit evidence:
"The scale of housing development required
to influence house prices and the impact of promoting such a programme
on the natural and historical environment and infrastructure provision"
SUMMARY OF
EVIDENCE
5. The Natural England partners recognise
the need to increase the supply of housing to meet the housing
needs of rural and urban communities. Our concerns about the scale
of development necessary to improve housing affordability are
largely related to where and how this development takes place.
We believe that housing must be provided in ways that avoids harm
to our natural environment, minimises the use of scarce natural
resources and delivers substantial environmental and community
benefits. The spatial planning system has a vital role to play
in ensuring that necessary development takes place in ways that
meets sustainable development objectives.
6. Proper account must be taken of the environmental
capacity of areas proposed for further growth with further work
needed on environmental limits and the cumulative impacts of development.
Sustainable locations for development must be found that avoid
our protected sites and landscapes and consider the impacts of
development on all landscapes, soils and biodiversity. Mitigation
against loss is not always possible or practicable but where appropriate,
full considered and evidence based assessment at the earliest
stage should be a requirement.
7. The planning system should set out the
quality and resource efficiency standards that development must
meet with development delivering economic, social and environmental
benefits for local communities. The infrastructure needed to support
the provision of new housing must be provided as an integral part
of the development. This should include the provision of green
infrastructure. Exemplar developments are needed to lead the way
in demonstrating how new housing can be provided in environmentally
sustainable ways.
GENERAL COMMENTS
8. Housing is a basic human right. The Natural
England partners support Government policy that everyone should
have the opportunity of a decent home and a reasonable choice
of location. As a nation, we should plan to meet the housing requirements
of the whole community, including those in need of affordable
and special needs housing in both urban and rural areas. The factors
affecting house prices are varied and complex, as is the relationship
between house prices and housing supply. We welcome the Committee's
inquiry into these issues. As environmental organisations, however,
we are restricting our evidence to the environmental implications
of increasing housing supply.
9. We recognise the severe shortage of affordable
housing that exists. We believe that emphasis should be placed
on the provision of affordable housing to those in need, rather
than attempting to increase the supply of housing to reduce house
prices across the board, which may not help those most in need
and is likely to have significant environmental implications.
Our concerns about the scale of development necessary to improve
housing affordability are largely related to where and how this
development takes place. Solutions to the lack of affordable housing
must be consistent with sustainable development, and additional
housing in the growth areas must create high quality sustainable
communities and deliver economic, social and environmental benefits
in a resource efficient manner to the people concerned. We are
engaging with those involved in the growth areas to help achieve
these aims.
10. The likely scale of housing development
required to influence house prices would have significant and
far-reaching impacts on the natural, built and historic environment.
These implications must be fully and properly addressed and we
welcome the Committee's consideration of these issues and the
opportunity to contribute to the debate. Large-scale housing development
impacts on all aspects of our natural environment, our landscape,
heritage and biodiversity interests, and affects the use of natural
resources such as energy sources, water resources and water quality,
soils and minerals resources. It affects the character and identity
of settlements and the quality of life of existing residents.
11. The challenge is to find solutions to
our housing needs in ways that minimise environmental impacts,
prevent environmental pollution and congestion and enhance the
quality of life for new and existing communities in both rural
and urban areas. Our view is that the housing needs should be
met in ways that deliver economic, social and environmental benefits
to the areas concerned and the people who will live there. The
level of growth needed to meet housing needs presents a significant
and timely opportunity to improve the quality of development and
ensure it delivers a net gain to the areas concerned.
ENVIRONMENTAL IMPLICATIONS
OF SIGNIFICANT
HOUSING DEVELOPMENT
12. Securing the future, The UK
Sustainable Development Strategy (2005) sets out five guiding
principles to achieve the government's sustainable development
purpose (Living within environmental limits, ensuring a strong,
healthy and just society; achieving a sustainable economy; promoting
good governance and using sound science responsibly). It is imperative
that these principles underpin a sustainable housing policy. The
emphasis on environmental limits (respecting the limits of the
planet's environment, resources and biodiversity to improve our
environment and ensure that the natural resources needed for life
are unimpaired and remain so for future generations) is particularly
relevant to the Committee's deliberations, as is the need for
an integrated policy approach for protecting and enhancing natural
resources.
13. The environmental implications of development
demand detailed and thorough consideration. The Defra Study
into the Environmental Impacts of Increasing the Supply of Housing
in the UK (Entec UK/Richard Hodkinson Consultancy/eftec 2004)
researched a (limited) range of environmental impacts of a number
of housing growth scenarios and concluded that the likely scale
of environmental impacts will be significant if the supply of
housing is increased to the level postulated in the Barker review.[40]
The study recommended that further work should be undertaken to
understand more fully the environmental and sustainability implications
and regional impacts of the different levels of growth set out
in the Barker review. It also identified a number of policy areas
that should be reviewed in order to locate new housing development
to minimise environmental impacts, to mitigate the environmental
impacts associated with the construction and occupation of new
dwellings and to improve environmental performance. We welcome
the recognition that further work is needed on these issues.
14. Moreover, the House of Commons Environmental
Audit Committee report Housing: Building a Sustainable Future
(2005) concluded that the "environmental impacts of the
proposed increase in housebuilding deserve much greater consideration
than they have yet received from Government . . . housing policy
should be set within the overarching context of environmental
limits. All new housing should be built to standards that minimise
environmental impacts . . . Large scale house building demands
prudence, properly joined up government, thorough environmental
appraisals, a respect of environmental limits, local engagement,
and improvement in skills, knowledge and awareness. We need sustainable
communities and new sustainable housing, but unless they are environmentally
sustainable they will never be truly sustainable at all."
15. The Natural England partners recognise
that the environment is an asset that contributes significantly
to the economic and social wellbeing of the UK. Protection and
enhancement of our environment and wise use of our natural resources
is therefore fundamental to the prosperity of Britain.
16. The protection and enhancement of our
nationally and internationally protected landscapes, habitats,
and sites (eg National Parks, Areas of Outstanding Natural Beauty,
National Nature Reserves and Sites of Special Scientific Interest)
as assets for future generations is an important element of sustainable
development. In considering appropriate locations for significant
housing development, the highest levels of protection must be
accorded to our designated areas and sites as well as our protected
species with decisions according with legislation and Government
policy (eg PPS7, PPS9, the Habitats Regulations, Wildlife and
Countryside Act and Countryside and Rights of Way Act).
17. It is also important to protect and
enhance the wider environment, outside of protected areas, and
to consider the impacts of development on natural resources, land
use, landscapes, habitats and species. Biodiversity cannot be
maintained through protected sites alone. Past and present human
activity and human-population pressures have damaged the natural
environment and disrupted ecosystems (the complicated relationship
that exists between animals, plants and their natural environment
which maintains the variety of life). We need to actively manage
our natural environment to help these damaged ecosystems recover
so they can continue to function effectively and support economic
productivity. It is also important to retain and enhance the character
and distinctiveness of our countryside. The character of all landscapes
should be taken into account when making decisions on future development.
Tools such as landscape character assessment should be used to
inform decisions on the location of development and set the conditions
for the nature of development that respect and enhance landscape
character.
18. In accordance with the Government's
Sustainable Development Strategy, we believe that policy makers
need to place greater emphasis on environmental capacity and respecting
environmental limits. We consider that there are particular locations
where environmental capacity to accommodate additional dwellings
has been overreached. In Dorset, Surrey and the Thames Basin for
example, the wildlife communities in the remaining lowland heath
areas are struggling to maintain viable populations due to the
cumulative impacts of adjacent development pressure. Future resource
use, land management and built development must recognise the
limits for using natural resources and prevent irreversible losses
of biodiversity.
19. In making decisions on the location
of future development, it is imperative that the cumulative impacts
of development are addressed. The statutory requirement for appraisal
of development plans throughout Europe marks recognition that
significant impacts can arise from development and land use change
proposed in development plans. Such impacts can occur over time
and space and can accumulate. The impacts of development may result
in the direct destruction of habitats or their loss over time
as a consequence of cumulative changes. Where critical thresholds
are exceeded, such will be the degradation of the habitat that,
from the perspective of biodiversity, the habitat may be as good
as lost. Research undertaken for English Nature[41]
concluded that habitats in the south of England are facing a number
of cumulative impacts caused by development pressures and that
it is likely that the high levels of development that are expected
in the next 10-20 years will adversely affect ecosystem resilience
and result in a direct threat to some species.
DELIVERING HIGH
QUALITY SUSTAINABLE
DEVELOPMENT
20. The planning system has an important
role to play in delivering sustainable development. This is reflected
in the Planning and Compulsory Purchase Act (2004), which requires
regional and local plans to be prepared with a view to contributing
to the achievement of sustainable development and PPS1, which
sets out how the planning system should deliver the four aims
of sustainable development in an integrated way. Sustainability
Appraisal, incorporating Strategic Environmental Assessment, is
an important mechanism to ensure that the environmental implications
of development are properly considered alongside economic and
social considerations. We are committed to the plan-led system
of spatial planning. We believe that more visionary, evidence
based and locally responsive planning policies should inspire
a new approach to high quality sustainable development.[42]
21. We believe that if significant additional
housing development is to take place, far greater emphasis should
be placed on the quality of development. The quality of development
includes its scale, its location, its design, its mix of uses,
its energy and resource efficiency and its long-term flexibility
to adapt to changing needs and circumstances. High quality development
incorporates landscape, greenspace, biodiversity, recreation and
other community benefits, which should be designed into to the
development from the outset.[43]
The planning system needs to go further in setting out the quality
standards that development must meet to enhance local character
and distinctiveness and deliver sustainable development. Area
Action Plans, development briefs, master plans, design codes,
design guides and concept statements[44]
all have a role in setting out detailed development requirements.
22. We believe that in order to be sustainable,
all development should deliver a net gain (or at least a neutral
effect) for the social, economic and environmental interests of
the area, with no significant losses to any of them. This means
protecting our precious natural assets—our finest landscapes
and important heritage and biodiversity interests from the adverse
effects of development. It means avoiding or mitigating harm or
compensating for losses through the use of planning conditions
and obligations which provide for equivalent or greater benefits.
In addition, it means delivering community and environmental benefits
to the people affected by development. In short, it means delivering
the types of development that the Countryside Agency terms "good
enough to approve".
23. New housing development must also show
major resource productivity improvements in water, energy and
materials use. A quantum leap in sustainable design and construction
is needed if we are to create genuinely sustainable communities.
The Building Regulations have considerable potential to improve
the sustainability of individual buildings, supporting and complementing
the planning system's role in influencing the overall design and
layout of developments. The current Building Regulations go some
way to achieving sustainability objectives such as energy conservation
but future revisions must go further. A sustainable development
principle should be introduced to underpin and broaden the scope
of the Building Regulations, which must include water and energy
efficiency measures, construction waste and the wise use of materials,
including packaging.
24. The use of environmental standards such
as BRE "ecohomes" should be mainstreamed to guide higher
construction standards. Private sector housebuilders should be
required to follow the example of English Partnerships and the
Housing Corporation and aim for "very good" or "excellent"
Ecohomes standards. We support the introduction of the national
Code for Sustainable Building and believe that, if consistently
applied, this could lead to considerable improvements in the environmental
performance of buildings.
25. There are currently few examples of
genuinely high quality sustainable communities being built. The
Millennium Communities, National Trust and Joseph Rowntreee Foundation
are leading the way in creating exemplar developments but more
needs to be done to mainstream these types of developments and
encourage the private sector to adopt innovative approaches. Much
of our future housing (and other) development needs will have
to be met within the rural urban fringe as sites within urban
areas are built out. The Countryside Agency has published a vision
of the countryside in and around towns as a multi-functional,
attractive, accessible resource that meets the needs of urban
and rural communities.[45]
Exemplar high quality sustainable communities within attractive
settings will help show how this vision can be turned into reality.
INFRASTRUCTURE PROVISION
26. A key challenge is to provide growth
in housing that is fully integrated with infrastructure, employment
and essential facilities and services, including natural green
space. It is vital that transport and other infrastructure is
delivered as an integral part of new development and provided
at the same time as the housing development, not following on
afterwards. There is a real risk that "sustainable communities"
will become a monoculture of dormitory settlements where extensive
private car use is necessary to reach jobs and services. Achieving
the right public transport infrastructure is probably the single
most critical factor in securing a sustainable functioning community.
27. The new spatial planning system must
deliver greater partnership working and policy co-ordination amongst
the various infrastructure providers and ensure that investment
decisions support spatial strategies. Planning obligations (and
future mechanisms such as the planning gain supplement or planning
tariffs) have considerable potential to be used as a more effective
and positive tool to secure sustainable development.
28. The provision of appropriate infrastructure
at the same time as housing development. should include "green
infrastructure". Green infrastructure, delivered through
a planned network of multifunctional greenspaces, provides multiple
benefits such as sustainable drainage, flood storage, recreation,
access and wildlife, contributes to a high quality natural and
built environment, and enhances quality of life for present and
future residents. The Green Infrastructure concept has been incorporated
within the Milton Keynes South Midlands Sub-regional Strategy[46]
and is also being adopted in the Thames Gateway. Much will depend
on how these concepts are translated into practice on the ground.
40 Review of Housing Supply. Delivering Stability:
Securing our Future Housing Needs. Kate Barker (2004). Back
41
Going, going, gone? The cumulative effect of land development
on biodiversity in England. English Nature Research Report 626.
LUC for English Nature 2005. Back
42
The approach of the Countryside Agency and English Nature to delivering
high quality environmentally sustainable development via the planning
system is set out in Environmental Quality in Spatial Planning
(Countryside Agency, English Heritage, English Nature, Environment
Agency 2005). Back
43
See Biodiversity by design-A guide for sustainable communities
TCPA (2004) Back
44
See Concept statements and Local Development Documents. Practical
guidance for local planning authorities Countryside Agency (2003). Back
45
The Countryside in and around towns. A vision for connecting town
and country in the pursuit of sustainable development. Countryside
Agency and Groundwork (2005). Back
46
Further information is set out in Planning Sustainable Communities.
A Green Infrastructure Guide for Milton Keynes & the South
Midlands (2005). Back
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