Memorandum submitted by Wildlife and Countryside
1. INTRODUCTION
1.1 Wildlife and Countryside Link (Link)
brings together 40 voluntary organisations concerned with the
conservation and protection of wildlife and the countryside. Our
members practice and advocate environmentally sensitive land management,
and encourage respect for and enjoyment of natural landscapes
and features, the historic environment and biodiversity. Taken
together, our members have the support of over eight million people
in the UK.
1.2 We welcome the Committee's inquiry into
the environmental aspects of the Government's house-building policies
and the opportunity to submit our concerns and suggestions. Our
submission to this inquiry focuses primarily on eco-towns, and
is taken from Link's recent position paper on the subject[26].
1.3 Link's vision for eco-towns is for well-located
exemplar developments which apply the highest environmental standards
and combine the adequate provision of well designed, appropriately
timed and sufficiently funded green infrastructure, with the protection,
restoration and maintenance of all existing designated and undesignated
wildlife sites.
1.4 This document is supported by the following
15 member organisations:
— Buglife—The Invertebrate Conservation
Trust
— Campaign to Protect Rural England
(CPRE)
— Council for British Archaeology
— Friends of the Earth England
— Herpetological Conservation Trust
— Plantlife International
— Royal Society for the Protection
of Birds (RSPB)
2. SUMMARY OF
KEY POINTS
ON ECO-TOWNS
— Eco-towns must be properly planned
through the regional and local planning process including extensive
consultation and evidence gathering.
— Eco-towns must give due regard to
the issue of environmental capacity and seek ways in which to
reduce their impact in those areas where environmental capacity
is already diminished.
— They must make every effort to conserve
natural resources and raise the bar for future housing development.
— Green infrastructure must be provided
to a high standard and be of sufficient quality including that
which provides ecological function.
— Eco-towns must as an absolute minimum
protect existing wildlife and make every effort to enhance it
for the future.
3. RATIONALE
3.1 Link welcomes the aspirations of the
eco-towns initiative which aims to contribute to meeting the nation's
needs for new housing whilst meeting the requirements of sustainable
development. Housing has a considerable environmental footprint—it
is the single biggest cause of countryside loss to development
and generates demand for other development pressures.
3.2 Since the 1990s over 300 square miles
of countryside have been affected by urban development each year.
Housing also consumes other critical natural resources in the
form of construction materials, energy and water. It is vital
that as we respond to the need for new housing we dramatically
reduce its environmental impact.
3.3 We welcome the commitment to make all
new homes zero carbon by 2016, all public sector buildings (including
hospitals, schools and townhalls) carbon neutral by 2018, and
all new offices, shops and other commercial buildings zero carbon
by 2019. Whilst we encourage the focus on the environmental implications
of new housing, it should be remembered that eco-towns represent
less than 5% of the three million new homes Government is seeking
to build by 2020.
3.4 The best climate science shows that
to keep the impacts of climate change within manageable levels,
we need to achieve an 80% reduction in carbon emissions (on 1990
levels) by 2050. Urgent consideration should therefore be given
to improving the environmental performance of all development,
be it new or existing. Since 70% of existing homes will still
be with us in 2050, the gains to be achieved from improving the
environmental performance of existing housing is arguably of greater
importance than that of new build.
3.5 The environmental performance of individual
developments will depend on where they are located, what form
they take, and how they are developed, managed and maintained.
We welcome schemes that will genuinely secure a step-change in
environmental standards and serve as transferable exemplars of
environmentally sustainable development. For eco-towns to succeed,
they must be well integrated with existing settlements and agreed
with, not imposed on, local communities. There is a real opportunity
for planners and developers, working with communities, to inspire
and set high standards for others to follow, provided the right
approach is taken.
3.6 Eco-towns have the potential to showcase
the role that good quality green infrastructure can play in helping
wildlife adapt to the effects of climate change. Well designed
and managed green infrastructure can provide ecological connectivity
through the creation of a network of interconnected green spaces
which will enable wildlife to traverse urban areas, and will help
meet the need for mobility and resilience for wildlife habitats
in the face of climate change.
4. MEETING PLANNING
REQUIREMENTS
4.1 In order to provide inspirational and
achievable developments, it is vital that eco-towns are properly
planned. Key to this is how decisions on eco-towns relate to existing
local and regional plans. Eco-towns should still be subject to
extensive public consultation and testing of evidence that provides
the basis for securing consent on the level and location of new
development.
4.2 Some communities felt sidelined by the
eco-town debate with the bidding process for developers seemingly
circumventing the normal planning processes. The need for a new
settlement should be considered in preparing a local plan and
the final scheme approved by the local council via a planning
application.
4.3 The Government must not undermine the
planning system. In order to secure public support for an eco-town
and to retain public faith in planning, it must spend considerable
time, effort and expense to ensure communities have input drawing
up local and regional plans. Eco-towns should be subject to the
same tests as any other new settlement proposal, as well as adding
value by achieving the highest environmental standards.
4.4 All schemes should be tested through
Regional Spatial Strategies (RSS) and Local Development Framework
(LDF) reviews, including adequate Strategic Environmental Assessment
(SEA) and Appropriate Assessment (AA) where necessary. These will
ensure that decisions take full account of evidence on environmental
effects and housing need, plus alternatives for meeting these.
All decisions on eco-towns should be accompanied by evidence that
demonstrates a new settlement to be the most sustainable option
for accommodating housing growth compared with other options,
such as redeveloping an existing urban brownfield site or an urban
extension.
5. ENVIRONMENTAL
CAPACITY
5.1 Link is concerned that the majority
of new developments pay little attention to impacts on environmental
limits. Decisions on ecotowns should include a full consideration
of the impact on environmental capacity and measures to reduce
this. As part of the RSS and the LDF process, the impact of an
eco-town should be assessed through the SEA process. Where impacts
on environmental limits are too high or cannot be sufficiently
mitigated against, such as impacts on designated wildlife sites,
legally protected species, or Biodiversity Action Plan (BAP) habitats
or species, the proposed scheme should be rejected.
5.2 Some areas of the country are considered
to be virtually at their environmental limit. Where this is the
case, ecotowns should not be considered in these areas unless
their impact can be fully mitigated and reduced to virtually zero.
5.3 In prioritising previously developed
land for eco-town development, care should be taken to ensure
that the biodiversity value of many brownfield sites is planned
in to the way an eco-town is taken forward so that any potential
loss of UK BAP priority species and habitats is avoided.
6. CONSERVATION
OF NATURAL
RESOURCES
6.1 Housing has huge implications for the
consumption of natural resources. Fossil fuel for energy and transport
generates pollution and greenhouse gases, which contribute to
climate change. Eco-towns should raise the bar for housing development
by showcasing environmental techniques that conserve natural resources.
They should include measures designed to conserve water and other
natural resources, source food and fuel for energy locally, minimise
soil, air, noise and light pollution and achieve zero-waste.
6.2 All eco-town housing should be built
to Level 6 of the Code for Sustainable Homes. The highest energy
efficiency standards available should apply to all community buildings
including use of locally generated combined heat and power, for
example, micro biomass power plants using locally grown wood.
6.3 Water-saving and water efficiency measures
should be used on all new housing. This should include measures
to trap and store wastewater that can be re-used for other purposes.
Sustainable Urban Drainage Schemes (SUDS) should be used as the
norm rather than the exception. SUDS help alleviate flooding impacts
of urban development and can be a basis for new wildlife habitats
and an amenity greenspace for new communities, as well as contributing
to an eco-town's green infrastructure network.
6.4 Buildings should be constructed from
sustainably and locally sourced materials, for example, through
use of low carbon materials such as wood obtained though legal
and sustainable sources as part of a strategy of product substitution.
Where materials have been quarried locally, consideration should
be given to restoring minerals sites to biodiversity rich greenspace,
which will add to the Green Infrastructure (GI) network of the
development.
6.5 Eco-towns should be well connected to
their surroundings with high quality well funded public transport
providing good access to nearby settlements and local supply networks.
The provision of sustainable travel choices, with a strong emphasis
on and incentives for the use of walking and cycling, should include
extensive improvement of any existing public transport infrastructure
and reliable funding streams to maintain quality services.
7. GREEN INFRASTRUCTURE
7.1 Green infrastructure (GI), a term which
encompasses the network of green spaces and other environmental
features, is as essential to all new development as traditional
"grey" or "hard" infrastructure such as roads,
schools and hospitals. High quality green infrastructure promotes
ecological connectivity through the creation of a network of interconnected
spaces, enabling wildlife to traverse urban areas and meet the
need for mobility and built in resilience for wildlife habitats
to adapt to the effects of climate change. If sympathetically
designed, eco-towns—with high levels of good quality green
infrastructure—may be more appealing to wildlife than land
which is intensively farmed.
7.2 Eco-towns provide a unique opportunity
to develop new approaches to creating and maintaining high quality
GI. Link suggests that GI should cover at least 40% of the development
area for it to qualify as "an eco-town". This should
include new informal and formal greenspace along with existing
wildlife habitat such as areas encapsulated within developments,
nature reserves, country parks, historic sites and landscape features,
road verges and roundabouts, linear habitats along watercourses
and hedgerows, SUDS and ponds, green roofs and private gardens.
7.3 Link further suggests that GI should
incorporate wooded and non wooded greenspace and that it should
be located throughout eco-towns such that no one lives more than
300m from an area of accessible greenspace of >2ha, and no
further than 500m from an area of accessible woodland greenspace
of > 2ha. We also would wish to see larger areas (20ha+) of
accessible greenspace located within 4km of all residents.[27]
7.4 It will be essential to link the new
eco-towns sensitively with the surrounding countryside, in the
case of rural areas, or into existing GI networks within the green
belt around existing urban areas, where appropriate.
7.5 To plan for GI it is essential to:
— Masterplan and design it from the
outset. Even before land prices are agreed between landowners
and developers, or building or transport is considered, each eco-town
should have a GI Strategy detailing where it will go, when it
should be completed, sources of funding and who will carry out
long-term maintenance.
— Create networks of sites that "fill
the gaps" between existing greenspaces and sites of importance
for biodiversity.
— Make the best use of existing resources
and create GI before residents move in. Eco-towns should not be
seen as a "blank canvas" where existing greenspace and
biodiversity is stripped away to start afresh.
— Plan to shape the development of
the built environment in eco-towns. GI should also not be a "bolt
on" that is added at the end of the development process.
— Ensure that it accessible to all
and it is seen as a community resource, whilst recognising that
access may need to be controlled at ecologically sensitive times
of year. Research shows that access to quality greenspace improves
physical and mental health[28].
— Make new communities aware of what
GI exists. Using appropriate information, help people make the
most of it and feel responsible for it.
— Ensure it is of high quality, not
just amenity grassland with lollipop trees. Ecological function
should be considered at the planning stage with every aspect of
the GI used for an ecological purpose, eg habitat creation, flood
alleviation.
— Design to integrate the historic
landscape character of the area and to respect the distinctiveness
of local built heritage.
— Be consistent with Planning Policy
Statement 17: Planning for Open Space, Sport and Recreation.
— Design it to include features and
species which contribute to local Biodiversity Action Plan targets
for the area. Key to this is the involvement of relevant stakeholders
to provide expert advice on its creation and maintenance.
— Acknowledge that whilst multifunctionality
of new greenspaces is important, sites which perform ecological
functions in their own right, such as designated sites, should
not be undermined by a desire to use them for other purposes,
for example, increased recreation.
— Ensure adequate funding is available
to create and maintain it in the long term. Section 106 agreements
and the forthcoming Community Infrastructure Levy could be potential
sources of funding. Link suggests that 20% of all funding for
eco-towns should be allocated for specific GI creation and improvement.
8. PROTECT AND
ENHANCE LANDSCAPE
AND WILDLIFE
8.1 Eco-towns should be subject to an independent
landscape character appraisal, be sympathetic to their setting
and clearly enhance the local landscape, built and natural heritage,
including through the designation of new Green Belt, where appropriate.
They should also seek not just to protect existing on-site biodiversity
but also enhance it for future generations and showcase best practice
if they are to genuinely be worthy of the title "eco-towns".
8.2 In summary, eco-towns should:
— Characterise the local ecology and
landscape as part of the master-planning process. This is essential
to ensure that any new GI is in keeping with the local landscape
and uniqueness of the area.
— Be consistent with Planning Policy
Statement 9—Biodiversity and Geological Conservation and
its accompanying Good Practice Guide, and the Planning and Climate
Change Supplement to PPS 1.
— Be consistent with the National Brownfield
Strategy.
— Ensure both the protection of all
biodiversity interest currently on site and opportunities for
habitat creation in order to build in species resilience to climate
change.
— Where new habitats are created, ensure
they contribute to locally agreed, spatial habitat targets and
wherever possible contribute to national Biodiversity Action Plan
(BAP) targets. Every eco-town should have its own BAP based on
local priorities against which monitoring can take place and further
habitat creation be facilitated.
— Be consistent with the Horticultural
Code of Practice to help prevent the spread of invasive non-native
species.
— Provide homes for wildlife such as
nest boxes, bats bricks, swift and house martin nests. Suitable
locations and existing populations of species that might colonise
these features should be considered whilst guarding against attracting
non-target species of both fauna and flora.
— Seek to ensure that gardens and small
communal spaces add to the quality of the GI network through the
promotion of wildlife gardening principles[29].
Gardens, both private and communal, will be a key aspect of eco-town
design. Residents and community greenspace guardians should be
encouraged and assisted—through information provision, practical
advice and support—to manage gardens for wildlife as an
integral part of the overall GI network.
8.3 Every eco-town should be an exemplar
that sets high standards which are translated into other development
practice and techniques, leading to dramatic improvements in the
entire approach to housing and built development. Eco-towns should
not exist in isolation from mainstream approaches to planning,
design and construction.
April 2008
Bird, W. for RSPB (2007) Natural Thinking—investigating
the links between the natural environment, biodiversity and mental
health.
26 See http://www.wcl.org.uk/downloads/2008/Link_position_paper_on_ecotowns_23_Apr08.pdf Back
27
Based on Natural England's Accessible Natural Greenspace Standard
and the Woodland Trust's Woodland Access Standard. Back
28
Bird, W. for RSPB (2004) Natural Fit-can greenspace and biodiversity
increase levels of physical activity? Back
29
For example, RSPB's Homes for Wildlife-see www.rspb.org.uk/hfw Back
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