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

Memorandum by the Royal Society for the Protection of Birds (RSPB) (AH 54)


  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.


  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.


  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.


  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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