Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by English Nature, the Rural Development Service and the Countryside Agency (Landscape, Access and Recreation) (AH 19)


  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"


  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.


  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.


  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.


  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.


  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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