Memorandum submitted by The Royal Society
for the Protection of Birds (RSPB)
KEY POINTS
— The RSPB welcomes the Government's
target for all new homes to be zero-carbon by 2016, but highlights
the importance of location, both for reducing carbon emissions,
and wider environmental impacts.
— Some eco-towns standards, such as
for water neutral development, sustainable urban drainage systems
and multi-functional, high quality greenspace, could be rolled
out more rapidly to all new homes through a revision of PPS3 Housing.
— The approach to the selection of
the most suitable locations for eco-towns is flawed, and the proposed
sustainability appraisal must consider alternative locations.
— Public funding for green infrastructure
in growth locations is welcome, but insufficient for the scale
of growth proposed.
— The proper use of environmental assessment
tools for development plans (particularly strategic environmental
assessment and assessment under the Habitats Directive) is critical
in minimising the environmental impacts of new homes.
INTRODUCTION
1. The Royal Society for the Protection
of Birds (RSPB) is the charity that takes action for wild birds
and the environment. We are the largest wildlife conservation
organisation in Europe with over one million members. We own or
manage 140,441 hectares of land for nature conservation on 203
reserves throughout the UK.
2. 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 1,000 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.
REDUCING CARBON
EMISSIONS FROM
NEW HOMES
3. The RSPB welcomes the Government's target
for all new homes to be zero-carbon by 2016. We believe that it
is an ambitious but necessary target in order to achieve the scale
of reduction in carbon emissions required for the UK. There is
a growing scientific consensus that the scale of the reduction
required is in fact 80%, not 60%, by 2050. The RSPB is not in
a position to say whether the target for new homes is on track
to be achieved, but would urge the Government and the house-building
industry to treat this target as a matter of urgency.
4. We note the recent inquiry on existing
housing and climate change by the Communities and Local Government
Committee and agree with its conclusions. Clearly, action taken
to deliver zero-carbon new homes must not be taken at the expense
of dealing with emissions from the existing stock, and vice versa.
5. Although the Committee is concerned with
the scale of non-site specific impacts (especially carbon emissions),
we note that site location is a key issue not just for natural
resources such as biodiversity, but for carbon emissions too,
due to the travel patterns generated by the residents of new homes.
We deal with this point further under "Eco-towns" below.
6. While we have not made any estimate of
the overall scale of environmental impacts, we consider that central
Government has a critical role to play in minimising them through
regulation, policy and guidance. However, this role is shared
with regional planning bodies, local planning authorities, statutory
agencies (including the proposed Homes and Communities Agency)
and the housebuilding industry. We consider that while existing
planning legislation and policy for biodiversity protection is
generally satisfactory, there is still much to be desired in its
implementation. We deal with this point further under "Greenfield
and green belt developments" below.
CODE FOR
SUSTAINABLE HOMES
7. The RSPB has welcomed the introduction
of the Code for Sustainable Homes, not merely for the high standards
of energy efficiency which it promotes, but also for the emphasis
it gives to water efficiency and the consideration of site ecology.
We also welcome the introduction of mandatory rating against the
Code for all new homes from May 2008.
8. While we cannot comment in detail on
the likely implications for the construction and purchase of new
homes, and of enforcement, we believe that environmental construction
standards are becoming increasingly important for home owners.
Whatever the current difficulties in the housing market, we believe
that the key issue is how far and how quickly the Code can be
rolled out to all new housing.
9. Enabling homebuyers to clearly compare
homes in terms of their sustainability should drive house builders
towards further sustainability. It is also essential to ensure
that homes designed to meet a certain Code level are actually
built to those standards. However, we believe that more is needed
to reduce the environmental impact of new housing. We recognise
that Building Regulations will be progressively tightened over
time, at least for the energy performance of new homes, to reach
the goal of zero carbon new homes by 2016, and we welcome this.
However, the Code is about far more than reducing carbon emissions,
important though that is. Its effectiveness in delivering better
environmental outcomes depends on its widespread uptake by the
industry. The Government should consider as a matter of urgency
what further measures could be taken to ensure this, as well as
extending the Code to existing homes and other types of buildings.
10. We also support regular updating of
the Code, to reflect research and technological progress, and
changing consumer trends in water use. It should serve to keep
the Code relevant whilst also ensuring that standards continue
to improve.
ECO-TOWNS
11. The RSPB supports the concept of eco-towns
because they are intended to achieve very high and demanding standards.
However, support for particular proposals is dependent on their
location and their impact on nature conservation interests.
12. At this stage we are still assessing,
as far as we are able to, the detailed impacts of the shortlist
of 15 eco-towns announced on 3 April by the Government. Our preliminary
view is that two sites cause us particular concern: Bordon-Whitehill
in Hampshire, because of the potential impacts on the Wealden
Heaths Special Protection Area, and Weston Otmoor in Oxfordshire,
because of impacts on the Wendlebury Meads and Mansmoor Closes
Site of Special Scientific Interest.
13. The RSPB's vision for eco-towns is for
exemplar developments which apply the highest environmental standards
and combine the provision of well-designed, appropriately timed
and sufficiently funded green infrastructure, with the protection
and enhancement of existing biodiversity and protected sites.
We are working closely with the Town and Country Planning Association
and Natural England on the preparation of a green infrastructure
worksheet for developers in order to achieve this.
14. In terms of their global impact, we
estimate that the eco-towns will only provide about 5% at most
of the three million homes that the Government plans to build
by 2020. On their own, the eco-towns will therefore only make
a small contribution to reducing the environmental impacts of
new housing in England. It is therefore critical that the design
and techniques developed in eco-towns are rolled out as rapidly
as possible to all new housing.
15. This is particularly pressing for the
design and building of zero-carbon homes on a large scale, in
order to meet the 2016 target for all new homes to be zero-carbon.
Doing this may be challenging for the house-building industry,
but is essential given the urgency of the climate challenge.
16. However, the techniques for delivering
other environmental standards are well-established and could be
rolled out very rapidly given the appropriate policy support,
for example: water neutral development, sustainable urban drainage
systems and multi-functional, high quality, green infrastructure.
We strongly support these aspirations for eco-towns and will expect
to see them delivered, but urge the adoption of similar standards
for all new development without delay. We anticipate that the
proposed Planning Policy Statement for eco-towns will give policy
support to these objectives, but ask the Government to consider
revising PPS3 Housing to adopt similar standards, or to incorporate
the proposed PPS into PPS3.
17. Finally, we note the critical importance
of location for reducing the environmental impacts of eco-towns,
including carbon emissions. The spatial relationship between eco-towns
and employment and service locations will be a key influence on
residents' need to travel. Smaller eco-towns, which cannot sustain
a significant level of business or services, and eco-towns in
remote locations, run the risk of establishing unsustainable travel
patterns, particularly where jobs and services are not available.
It is clearly important to provide good accessibility by public
transport, but the track record of the UK providing this from
the inception of a new development is not good. The priority must
be to reduce the need to travel in the first place through co-locating
homes, jobs and services, and by ensuring that the eco-town is
itself well-related to larger settlements.
18. This raises one of the flaws in the
process of selecting eco-towns; the competition process adopted
has not, in most cases, allowed the rigorous testing of locations
through the development plan process. Except where a proposal
is already included in a Local Development Framework, the proposal
will progress to a planning application without having been considered
in the preparation of the development plan.
19. In addition, although there is to be
a sustainability appraisal, we understand that this is to be a
detailed assessment of individual locations. The Government states
that the shortlist will be tested against "reasonable alternatives"
(which is a requirement of the Strategic Environmental Assessment
Directive), but it is not clear how this will be done without
an assessment of alternative locations within the local authority
or housing market area. Although there are 15 eco-towns in the
shortlist, their wide geographical spread means that they are
not realistic alternatives for each other. The Government must
ensure that the appraisal process deals properly with this issue
and that the methodology is open and transparent.
INFRASTRUCTURE
20. From the RSPB's perspective, the delivery
of green infrastructure is a critical aspect of sustainable communities.
We have been closely involved in the implementation of strategic
green infrastructure in a number of growth areas, such as Thames
Gateway and the Cambridge sub-region.
21. While progress in delivering green infrastructure
has been made in all these areas, the key issue is adequate and
on-going funding. Given the scale of the Government's ambition
for new house-building, it is essential that funding for green
infrastructure projects is similarly ambitious, but this does
not currently appear to be the case.
22. In Thames Gateway, the RSPB is developing
an extensive programme of linked greenspace projects across the
growth area. In South Essex, for example, the RSPB has a vision
for new wetlands covering 15 square kilometres. Our new landholdings
at Vange, Pitsea, Bowers and West Canvey Marshes will create 930
hectares of high quality greenspace rich in wildlife and accessible
to people. However, funding for further greenspace projects is
temporarily on hold until September 2008, when funding under the
Thames Gateway Parklands initiative will finally start. Even this
only provides £35 million for both greenspace and built heritage
projects until 2011, and is nowhere near the scale of what is
required or the 10% of all growth area funding which is desirable.
Neither does it currently include any provision for ongoing management
costs.
23. At Fen Drayton Lakes, in the Cambridge
sub-region, the RSPB has bought 391 hectares of former gravel
workings to develop a new nature reserve of traditional riverside
meadows. The reserve will be a greenspace resource for Cambridge
and the new settlement of Northstowe, and the guided busway being
built will provide an access route to the heart of the reserve.
Although projects at Fen Drayton have received a degree of public
funding, there has been considerable uncertainty about the availability
of funds and, as in Thames Gateway, the allocation for the sub-region
is nowhere near 10% of all growth area funding or what is necessary
to deliver the Cambridge Sub-Region Green Infrastructure Strategy.
24. The Government needs to address these
issues. We also expect to see that in future, the proposed Community
Infrastructure Levy will be made available to fund green infrastructure
alongside other types of infrastructure. It is important that
this is recognised in regulations and guidance when this is produced,
which we anticipate will be in autumn 2008.
GREENFIELD AND
GREEN BELT
DEVELOPMENTS
25. The RSPB supports the current planning
controls over green belt and greenfield land as expressed in PPG2
Green Belts and PPS7 Sustainable Development in Rural Areas, and
considers that these provide an appropriate level of protection.
We welcome the inclusion of nature conservation as an objective
for land-use in green belts, and the Government's commitment to
make no fundamental change to green belt policy. This designation
continues to be an important policy approach to dealing with the
issue of urban sprawl and it should continue to be used for this
purpose. In terms of biodiversity it can be an important resource
and helps provide a link between existing strategically important
greenspaces.
26. Even the strict policies of PPG2, however,
provide a degree of flexibility for the occasional review of green
belt boundaries, in exceptional circumstances, and the RSPB has
no objection to this approach where it is properly considered
through the development plan process.
Brownfield land
27. The corollary of the strict protection
of greenfield and green belt land is to concentrate housing on
brownfield land and in urban areas. Although we support the Government's
commitment to building on brownfield land, there needs to be renewed
appreciation that some brownfield sites develop significant biodiversity
interest of their own accord. For example, Canvey Wick is a 93-hectare
brownfield site in Thames Gateway South Essex and was designated
as a Site of Special Scientific Interest (SSSI) on 11 February
2005, the first brownfield site to be specifically protected for
its invertebrates. The importance of brownfield land, particularly
post-industrial sites, has been recognised in the latest revision
to the UK Biodiversity Action Plan, which includes a new priority
habitat, "open mosaic habitats on previously developed land".
28. The key issue for the RSPB is that biodiversity
should be protected and enhanced wherever it is found, in order
to deliver national and international commitments to halt biodiversity
loss by 2010.
Biodiversity value of undeveloped land
29. For undeveloped land, the question is
how green is the greenfield or green belt? Much of our countryside
has a relatively impoverished biodiversity, due largely to decades
of intensive agricultural use. The RSPB actively supports positive
action which manages or enhances greenfield land for wildlife,
both through our own network of reserves (some 140,000 ha in the
UK) and through advising land owners and managers on the best
use of their land. However, we do not support the development
of green belt land simply to secure environmental improvements
to other areas of green belt. The planning system plays an important
role in regulating the flow of land from agricultural and forestry
uses to built development, but the most effective means of enhancing
environmental quality in the open countryside is through other
mechanisms such as agricultural, forestry and water policy.
Value of planning system
30. For biodiversity, planning control has
two important benefits. Firstly, it provides protection for existing
biodiversity through the statutory protection regime (as expressed
in the Birds and Habitats Directives and domestic legislation);
through PPS9 Biodiversity and Geological Conservation, and through
the development plan system. This legal and policy regime not
only protects biodiversity but is an important tool in delivering
sustainable development and providing solutions that achieve integrated
economic, social and environmental objectives. The RSPB strongly
supports the value of this regime, but in our view it is sometimes
undermined by misinterpretation and poor implementation by decision-makers.
We deal with this further below.
31. The planning system is also useful through
the opportunity it gives to build biodiversity into new development,
an approach which receives policy support through PPS9. As noted
above, eco-towns and new housing generally provide excellent opportunities
to do this, and much good practice is available, such as the Guide
to Good Practice which accompanies PPS9, and the TCPA's Biodiversity
by Design (2004).
Greenfield development and biodiversity
32. However, it is sometimes argued that,
because of the high level of biodiversity supported in urban areas
(in private gardens and other greenspace), and the declining status
of wildlife on intensively farmed arable land, greenfield development
benefits biodiversity. It is certainly true that urban areas,
particularly gardens, support a great deal of biodiversity. The
RSPB also strongly supports making the maximum use of new development
opportunities to benefit biodiversity.
33. However, the biodiversity of arable
land is significantly different from the biodiversity of urban
areas. For example, skylarks are typical birds of arable farmland,
and house sparrows are typical birds of urban areas. Both are
"Red List" species of high conservation concern, and
are on the revised UK Biodiversity Action Plan list of priority
species, but both have specific habitat requirements. Urban development
on arable land, however well designed, might benefit some urban
species of birds, but not those associated with open farmland
such as skylarks, grey partridges or yellowhammers; even if some
species of wildlife are apparently increased, it is not replacing
like for like, and is not necessarily benefiting those species
most in need of help.
34. Biodiversity conservation is driven
by target led approach, based on scientific evidence of needs,
the causes of decline and appropriate solutions, which is encapsulated
in the biodiversity action planning process.
35. Different species require different
solutions: thus skylarks require changes to agricultural practices
(open plots within arable crops where young birds can feed); although
the causes of urban house sparrow decline are not yet fully understood,
it seems possible that the quantity and quality of vegetation
required to provide a source of invertebrate food for young birds
is a contributory factor. This suggests that garden design and
management are important for house sparrows. Building new homes
and gardens does not in itself help either species.
36. There are many compelling reasons for
providing new housing, and the RSPB accepts that Government has
a responsibility to ensure that people's housing needs are met.
We must take every opportunity to "green" new development,
but we are very critical of using the need to enhance biodiversity
as an argument in support of house building.
Protection of existing biodiversity
37. Furthermore, poorly-located new development
can cause problems by placing additional pressure on existing
biodiversity, even where it is not located directly on designated
sites. Impacts may be as varied as additional pressure on water
resources, or disturbance to ground-nesting birds by dog-walkers,
as on the Thames Basin Heaths.
38. The Thames Basin Heaths Special Protection
Area (SPA) is under pressure from high levels of recreational
use by people enjoying its wonderful character. The South East
Plan target to deliver over 40,000 new homes across the 12 local
authorities surrounding the SPA risks exacerbating this situation.
Finding a means to prevent further harm from the cumulative effects
of this new housing has presented complex challenges for developers,
local authorities and nature conservation bodies alike. The RSPB
is working with the affected parties to implement an effective
(and easy to operate) protection scheme for the SPA. This should
assess the cumulative impacts of housing at a strategic level
and ensure that impacts on the heaths are mitigated through the
provision of alternative greenspace and access management measures
that together prevent further recreational pressure on the SPA.
39. A final area of concern is over the
quality of environmental assessment of development plans. Strategic
Environmental Assessment (SEA) is a valuable tool in providing
decision-makers with information about the environmental impacts
of plans and programmes. In England and Wales this is incorporated
within a more general sustainability appraisal under the Planning
& Compulsory Purchase Act 2004. Where Natura 2000 sites are
affected, development plans also require assessment under the
European Habitats Directive, following a ruling by the European
Court of Justice in 2005.
40. The RSPB is concerned that, in some
cases, assessment processes have not been sufficiently integrated
with development plan preparation, have not been properly understood,
or their results have been downplayed. This has been a particular
issue for the current round of regional spatial strategies in
England. The impact of further housing growth imposed on regions
by central Government is likely only to put further pressure on
environmental resources, including biodiversity. The proper use
of environmental assessment tools for development plans is critical
in minimising the environmental impacts of new homes.
April 2008
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