Memorandum by the Royal Society for the
Protection of Birds (RSPB) (AH 54)
INTRODUCTION
1. The RSPB is Europe's largest wildlife
charity with over one million members. The RSPB's policy and advocacy
work covers a wide range of issues including planning and regional
policy, climate change, energy, marine issues, water, trade and
agriculture. As well as commenting on national planning policy
issues, the RSPB's professional conservation and planning specialists
make representations on around 600 items of planning casework
each year throughout the UK, including regional planning, development
plans and individual planning applications and proposals. We have
considerable planning experience, particularly in the area of
biodiversity planning.
2. The RSPB is particularly concerned about
the potential environmental impact of a significant increase in
the supply of housing. Our submission concentrates on the following
two issues identified by the Committee:
— How the planning system should respond
to the demand for housing for sale.
— 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
3. The RSPB is concerned about the impacts
that the location and quality of house building will have on wildlife
and the environment, and therefore on the achievement of sustainable
development. The planning system must provide for legitimate development
needs whilst ensuring that the environment is properly protected
and enhanced. To do this requires a strong plan-led system in
which development plans are subject to robust strategic environmental
assessment and in which decision-makers treat social, economic
and environmental objectives in an integrated way without resorting
to trade-offs. Recent Government proposals for planning the provision
of housing appear to threaten the plan-led system.
4. A significant increase in the supply
of housing may be seriously damaging to the environment unless
adequate measures are taken to mitigate the impacts, through giving
careful attention to the location and quality of house building.
In particular, plans need to deliver green infrastructure, respect
environmental capacity, conserve natural resources and protect
and enhance wildlife.
THE PLANNING
SYSTEM'S
RESPONSE TO
THE DEMAND
FOR HOUSING
FOR SALE
5. The RSPB is a strong supporter of the
plan-led planning system, as is now enshrined in the Planning
and Compulsory Purchase Act 2004. We welcome in particular the
new duty on plan-making bodies to contribute to the achievement
of sustainable development, and the guidance on how this is to
be achieved in Planning Policy Statement 1 Delivering Sustainable
Development (February 2005). We welcome recent statements from
the Government stating its continuing commitment to sustainable
development and the recognition that sustainability appraisal
(incorporating the requirements of the Strategic Environmental
Assessment Directive) provides the key means to reconcile competing
demands.
6. We believe that the planning system must
provide for legitimate development needs whilst ensuring that
the environment is properly protected and enhanced. To do this
requires a strong plan-led system in which development plans are
subject to robust strategic environmental assessment and in which
decision-makers treat social, economic and environmental objectives
in an integrated way without resorting to trade-offs.
7. We have also supported existing planning
policy on housing in Planning Policy Guidance Note 3 Housing since
its publication in 2000. It has been an important tool in encouraging
urban renaissance, protecting the countryside from unnecessary
development and generally promoting more sustainable patterns
of development.
8. In particular, we support the use of
"Plan Monitor Manage" rather than "Predict and
Provide"; making good use of land through higher densities;
the sequential test, favouring previously-developed land over
greenfield sites (with the caveat of protecting significant biodiversity
resources as expressed in PPS9), and the emphasis on creating
sustainable residential environments.
Plan-led or market led?
9. We have therefore been concerned by recent
Government proposals which appear to weaken elements of existing
policy in PPG3. In particular, we are concerned about the degree
to which the allocation of housing land will be market-driven,
rather than purely driven by the interests of good planning and
sustainable development.
10. We welcome the fact that the Government
does not seem to favour the recommendation of the Barker review
for allocating a substantial buffer of additional housing land
in local development frameworks and relying on housing market
indicators to trigger its release. This option would have been
extremely environmentally damaging.
11. We have no objections to improving the
evidence base for planners as they prepare and review development
plans, and to including market information within this. However,
we question whether a move towards a more market-led approach
is consistent with other areas of planning policy, for example
retail development. Since the out-of-town retail boom of the 1980s,
when planning policy was largely market-led, Government policy
has become firmly plan-led and focussed on town centres, overriding
market forces and driving changes to the way the retail sector
operates, with beneficial consequences for urban regeneration.
PPG3 has begun a similar process for the housing sector, and its
policy commitment to the sequential test must not be diluted.
Housing market areas
12. We support a collaborative approach
to planning for housing markets rather than administrative areas,
but are concerned about the degree to which stakeholders and members
of the public would have the opportunity to comment on or challenge
the areas defined by regional planning bodies.
Housing numbers—floor or ceiling?
13. The ODPM's consultation paper Planning
for Housing Provision contains proposals for tailoring the management
of delivery in different housing markets, which involves treating
the housing trajectory in an individual local authority or sub-regional
housing market area as either a "floor" or a "ceiling".
The current approach is to treat housing trajectories as a ceiling,
but in areas of high demand the proposal is that the housing trajectory
could be treated as a floor, which would mean the ability to meet
housing numbers earlier than planned, whilst triggering a partial
review of the regional spatial strategy.
14. We oppose this proposal because housing
numbers distributed to local authorities in particular markets
will already reflect decisions about whether to promote or limit
new provision. This decision will have been subjected to a sustainability
appraisal as part of the plan preparation, which is the appropriate
place to make it. The proposal also appears to be an open-ended
commitment to housing growth in high demand areas, as discussed
further below.
The sequential test
15. Our concerns with the proposed approach
to identifying land for housing centre on its apparent weakening
of the sequential test, which seeks to ensure that sites on previously
developed land are developed before greenfield sites. As mentioned
above, this policy has made an important contribution to urban
renaissance and the protection of greenfield sites around settlements.
16. Although the proposed approach retains
elements of the sequential test, its general emphasis is to identify
sites which are developable in the short term. Although developable
urban brownfield sites are to be allocated first, their very nature
means that greenfield sites are more likely to be developable
in the short term, thus leading to a bias in favour of greenfield
sites. This effect will be exacerbated by the ability of developers,
in high demand areas, to bring any sites in the five year land
supply forward for development at any time.
17. This approach does not give local authorities
and other public agencies the necessary encouragement to tackle
the constraints which may exist on previously-developed land and
to bring this land forward for development in preference to greenfield
sites.
Monitoring and managing housing supply
18. We are very concerned with the proposal
in the ODPM's paper that "in areas identified for high levels
of new homes local authorities will roll forward land through
a Supplementary Planning Document (SPD) and a parallel partial
review of the RSS will be triggered. Housing numbers may need
to be revised or the market area designation changed." (paragraph
45).
19. Firstly, this appears to be an open-ended
commitment to housing growth in high demand areas. If, faced with
faster than expected take-up of housing land, local authorities
are to bring forward sites identified for later phases and at
the same time the overall scale of development is revised (presumably
upwards), the likely outcome is to concentrate more and more development
into certain housing market areas. This could have serious consequences
for the local environment, regional imbalances and more sustainable
patterns of urban development.
20. Secondly, it is not clear whether the
roll forward of land in the SPD merely concerns the timing of
release (paragraph 42) or the allocation of sites which were not
previously identified in the site allocation Development Plan
Document (DPD). Although SPD is subject to sustainability appraisal,
changes to the development plan such as these must be dealt with
through a review of the site allocation DPD, in order to provide
an opportunity for the full and proper public scrutiny of emerging
housing sites before they are allocated or released.
THE SCALE
AND IMPACT
OF HOUSEBUILDING
ON THE
NATURAL ENVIRONMENT
21. The Government's proposals for increasing
the supply of housing draw to a large extent on the review of
housing supply carried out by Kate Barker for the ODPM and the
Treasury. Our comments on the scale and impact of housebuilding
on the natural environment must be set in the context of our general
concerns about the Barker Review, which are summarised here.
22. Firstly, Kate Barker's Review, by her
own admission, did not properly consider the environmental implications
of a step change in housing supply or of the mechanisms for achieving
it. Although joint ODPM/Defra research was commissioned in late
2004 on the sustainability implications of a proposed market housing
affordability target and a large increase in house building, this
has still not yet been published. There has, therefore, been no
opportunity for this research to influence public debate on this
issue, and the proposals contained in the ODPM's consultation
paper appear to be premature.
23. Secondly, if the implementation of Barker's
recommendations is seen as the means of tackling affordability
problems, we are not convinced that it will succeed on its own
terms, notwithstanding sustainability issues. The Barker Review
focussed its attention on market housing, largely ignoring social
rented housing and the interactions between the two sectors. We
believe that publicly-funded and accessible housing must be a
key element of any long-term solution to affordability problems,
independent of any attempt to deliver it through planning obligations
linked to the release of land for market housing. Furthermore,
the Barker Review itself accepts that its proposed step-change
in market housing supply would only slow the rate of housing price
inflation, not actually reduce prices. It also concedes that this
would not necessarily make market housing more affordable to those
in greatest need of affordable housing.
24. The proposed increase in housing supply
is essentially an economic development strategy, to fuel the growing
South East economy by removing the constraint on labour that the
current high cost of housing is believed to create. Not only is
this questionable as to whether this will work in the short-term,
as discussed above, but also in the long term. Housing capacity
in growth areas cannot increase infinitely, so at some stage an
alternative economic approach will be needed. It would be better
to introduce that alternative now (alongside changes such as increasing
the element of social provision), rather than rely solely on increased
market housebuilding.
25. Whatever the scale of the increase in
the supply of housing, we are concerned that there is likely to
be serious damage to the environment unless adequate measures
are taken to mitigate the impacts, through giving careful attention
to the location and quality of house building. In particular,
plans need to deliver green infrastructure, respect environmental
capacity, conserve natural resources and protect and enhance wildlife.
Thus our concerns are not about growth per se, but about the relationship
between the scale of development, its location and the quality
of its design (particularly in terms of its environmental performance).
26. We believe that all decisions about
development, whether at regional or local level, should follow
the following five-point approach:
Information—decisions should be based on
relevant and up-to-date environmental information.
Avoidance—adverse environmental effects
should be avoided wherever possible.
Mitigation—where adverse effects are unavoidable
they should be minimised by the use of mitigation measures.
Compensation—where, despite mitigation,
there will be residual adverse effects that mitigation cannot
reduce further, they should be compensated by measures that try
at least to offset the harm.
New benefits—where there are opportunities
to provide new environmental benefits, these should be taken.
27. This approach was originally applied
to planning for biodiversity, but is equally applicable to planning
for environmental issues more generally. Similar principles have
been included in PPS9 Biodiversity and Geological Conservation.
Deliver green infrastructure
28. The debate over infrastructure provision
in growth areas has largely ignored the need to deliver "green
infrastructure". Green infrastructure is "a network
of multi-functional greenspace | It is set within, and contributes
to, a high quality natural and built environment and is required
to deliver `liveability' for new communities". Having access
to natural places near to your home is key to better health, as
researched in the RSPB's report Natural Fit, which attempted to
quantify the financial value of urban parks in terms of savings
to the National Health Service. A quality environment also attracts
businesses to an area and makes a significant contribution to
local economies.
29. The RSPB believes that green infrastructure
is essential to the development of sustainable communities. It
is as vital to us as any traditional infrastructure such as roads,
schools and hospitals.
30. A strategic approach to providing green
infrastructure has been taken in the Milton Keynes and South Midlands
growth area. A partnership of government agencies, local authorities
and environmental groups, including the RSPB, has developed a
set of principles for green infrastructure. For example, green
infrastructure should provide a focus for social inclusion, community
development and lifelong learning. It should also maintain and
enhance biodiversity to ensure that green infrastructure results
in a net gain of Biodiversity Action Plan habitats.
Respect environmental capacity
31. Even if green infrastructure is fully
designed into new communities, there are still serious questions
about the environmental impact of new development. An important
principle of sustainable development is to recognise the limits
of the environment to accept further development without irreversible
damage.
32. Nationally, decisions have been taken
with only a limited understanding of environmental impacts, or
the environmental capacity of particular regions to accommodate
additional development. For example, much development is planned
for the south east of England, which has many areas valued for
their beautiful landscapes and rich wildlife. It is also the driest
part of the country, and predicted to get drier due to climate
change.
33. Problems are already arising in the
south east growth areas. For example, the draft regional spatial
strategy for the East of England (RSS14) proposes 23,900 new homes
each year, a 15% increase on the previous planned rate. The appraisal
report on the strategy warns: "the scale of growth is likely
to be highly environmentally damaging" unless significant
measures are taken to mitigate the impacts. The RSPB has objected
to a number of policies, including the policy on the distribution
of housing provision, on the grounds of potential harm to internationally-designated
wildlife sites.
34. The RSPB believes that much more must
be done to assess and avoid impacts at national and regional levels.
To do this, we need a national spatial strategy, subject to a
robust strategic environmental assessment.
35. At the local level, decisions about
the location of development should be informed by a full understanding
of local environmental capacity. Although environmental capacity
is not always easy to define, planners should follow the five-point
approach described above.
Conserve natural resources
36. Proposals to increase house building
in the UK, and particularly South-east England, potentially have
massive implications for the consumption of natural resources.
Fossil fuel consumption, to provide energy for houses and fuel
for transport, generates pollution and greenhouse gases that contribute
to climate change. More houses also means more demands on water
resources.
37. The RSPB carried out an analysis of
the costs and benefits of building all new homes to BRE's EcoHomes
"excellent" standard, using reports from Defra, UKWIR
and the Housing Corporation. To build a home to EcoHomes excellent
standard, in terms of water and energy saving actions, additional
costs are estimated at as little as £160 per home—a
small amount in the overall build cost of a new house. These measures
also continue to provide monetary and natural resource savings
during the life of the home.
38. The EcoHomes "excellent" standard
could save 10,000 megalitres of water per year, implying savings
of £1.6 billion on new water resources infrastructure, and
10 million tonnes of carbon emissions per year, potentially worth
£2.9 billion over the next 30 years. The costs of building
to the EcoHomes "excellent" standard are clearly worthwhile
for society and would help keep new development within environmental
limits.
Protect and enhance wildlife
39. The proposed growth areas contain areas
of important wildlife habitat, such as the wild marshes of North
Kent, which provide refuge for up to 200,000 wintering wild birds.
They are protected by the strongest international conservation
laws. Carefully planned development reduces the risk that these
special areas and the wider countryside are damaged.
40. However, potential adverse impacts from
transport projects associated with housing and economic growth,
such as a Lower Thames Crossing in the Thames Gateway or the M6
Expressway in the Midlands are still a major threat. Increased
numbers of people in new housing development near sensitive wildlife
sites must also be carefully managed to avoid indirect impacts
from more intensive recreational pressure, such as in the Nene
Valley, Northamptonshire, part of the Milton Keynes South Midlands
growth area.
41. As well as protecting it, sustainable
communities should also enhance wildlife, for example by erecting
swift nest boxes, installing green roofs, and creating new habitats
at every scale. All work should complement and help achieve the
UK's biodiversity action plan targets.
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