Memorandum submitted by Natural England
EXECUTIVE SUMMARY
Natural England believes that necessary housing
growth should be accommodated with minimum impact on the natural
environment while delivering maximum benefits for the natural
environment and people together.
This means:
— the most environmentally sustainable
locations should be found for new housing development;
— the environmental quality of all
new housing development should be substantially improved;
— all development should create high
quality, locally distinctive, resource efficient places where
people want to live. This should include substantial benefits
for the natural environment and people together;
— the provision of multi-functional
green infrastructure should be an integral part of all major development;
and
— eco-towns and new growth points should
become genuine exemplars of sustainable development, leading the
way for other developments.
INTRODUCTION
1. Natural England is a statutory body created
in 2006 under the Natural Environment and Rural Communities Act
by bringing together English Nature and parts of the Rural Development
Service and the Countryside Agency. Natural England has been charged
with the responsibility to ensure that England's unique natural
environment, including its flora, fauna, land and seascapes, geology
and soils are protected and improved.
2. Natural England's purpose, as outlined
in the Act, is to ensure that the natural environment is conserved,
enhanced and managed for the benefit of present and future generations,
thereby contributing to sustainable development.
3. Our evidence is structured in response
to the questions posed by the Committee.
REDUCING CARBON
EMISSIONS FROM
NEW HOMES
4. Although Natural England supports the
Government's target for all new homes to be zero-carbon by 2016,
we do not have the technical expertise to comment on the detail
of this issue. Other bodies are better placed to advise.
ECO-TOWNS
5. Natural England welcomes the Eco-town
initiative and we are actively working with Government and others
to advance the idea.
6. To be worthy of their name, we believe
that Eco-towns must be genuine exemplars of high quality, sustainable
development. A Green Infrastructure strategy (see the definition
below) is the key to securing the stringent environmental standards
required.
7. Eco-towns must take a new approach to
green infrastructure, ensuring that it is factored into their
design as a core element and from the earliest stages in the planning
process. Indeed, without an extensive and strategically planned
and delivered green infrastructure, Eco-towns cannot be truly
successful and sustainable settlements.
8. Green infrastructure networks in and
around Eco-towns will be characterised by their diversity of green
spaces—sport fields, areas of parkland, nature reserves,
small local community green spaces, allotments and linear "greenways",
accommodating footpaths and cycleways and providing a vital sustainable
transport role.
9. The recently published Eco-towns consultation
document (Eco-towns: Living a Greener Future) represents
a welcome recognition by the government of the importance of green
infrastructure (proposing that 20% of an Eco-town could be greenspace).
We will be watching closely and providing advice to ensure that
these good words are translated into appropriate action on the
ground.
10. Natural England is working with the
Eco-town Expert Group (convened by TCPA at the invitation of DCLG)
to produce design guidance for green infrastructure within Eco-towns.
This will include quality standards (such as the Green Flag rating
for parks or the Accessible Natural Greenspace standards, promoted
by Natural England).
11. Whilst the Eco-towns will only represent
a small percentage of the new homes necessary to meet Government
housing targets, the lessons learned in developing zero carbon
developments will be invaluable. They should be shared with planning
authorities and developers elsewhere to inform future development
proposals.
CODE FOR
SUSTAINABLE HOMES
12. Natural England welcomes the Code for
Sustainable Homes as a way of giving homebuyers better information
about the environmental impact of new homes and their running
costs. The Code will also help raise awareness about sustainable
design and construction issues.
13. While the Code might result in increased
costs for developers in the short term (until economies of scale
and expertise are in place) it will also offer a tool by which
developers can compete on sustainability issues. It might also
reduce marketing and other costs by encouraging the quicker sale
of houses.
14. We welcome the inclusion of "ecology"
as one of the rating assessment categories for the Code. We would
like to see the introduction of minimum standards and would be
pleased to help with their development. Furthermore, we see ecological
enhancement as an important component of green infrastructure
provision.
GREENFIELD AND
GREEN BELT
DEVELOPMENTS
15. Planning policy. Natural
England supports Government planning policy that new housing developments
should be located in line with sustainable development principles.[1]
This means that major development should promote sustainable travel
patterns avoiding environmental assets such as:
— Protected landscapes (National Parks
and Areas of Outstanding Natural Beauty).
— Protected sites (Special Areas of
Conservation, Special Protection Areas, Ramsar Sites and Sites
of Special Scientific Interest).
16. In short, sustainable development means
getting the right development in the right place. Natural England's
role as a statutory consultee for spatial plans and many development
proposals helps planning authorities and ministers to achieve
this.
17. Environmental capacity.
Strategic decisions on future development should be based on a
sustainable growth strategy that takes account of the environmental
capacity of the area. The capacity of the environment to accommodate
development will vary from place to place. The search for the
most environmentally sustainable locations for development should
be based on a thorough understanding of the environmental capacity
of the area and the cumulative impacts of development.
18. Natural England intends to carry out
further work on how the concept of environmental capacity can
better inform plan-making and development decisions.
19. Environmental considerations in
plans. Environmental considerations should be embedded
in spatial plans and inform site allocations. To protect valued
environmental assets, it is imperative that plans seek first to
avoid loss or harm to protected sites or species, before then
considering the need for mitigation or compensatory measures.
20. Regional Spatial Strategies and many
Local Development Frameworks are incorporating positive environmental
policies but more needs to be done in ensuring that policies set
high environmental high standards for development. The policies
need to be followed through into high quality development on the
ground.
21. Greenfield and brownfield development.
Decisions on individual sites should take account of the existing
character of the site and its environmental assets. Simplistic
assumptions about greenfield and brownfield sites are unhelpful:
— Many greenfield sites will have limited
biodiversity value, weak or degraded landscape character. Provided
they are well connected to existing urban areas or can be served
by public transport, they will be suitable, in principle, for
development. Indeed, development can provide the opportunity to
enhance the environmental value of such sites.
— Other greenfield sites will be of
high biodiversity, landscape or recreation value or be in floodplains
and will not be suitable for development.
— Equally, many brownfield sites will
be suitable for housebuilding whereas others will have high biodiversity,
geodiversity or recreational value and should not be developed.
22. Environmental evidence.
Available environmental evidence (such as data on habitats and
species from local environmental records centres) should be used
to underpin decision-making. Landscape character assessment is
an additional tool that is used by many local authorities. Greater
use should be made of such assessments to inform the location
and nature of new development and to ensure that local character
and distinctiveness is protected and enhanced.
23. Environmental considerations need to
be taken into account at an early stage in the development process
so evidence should be gathered and any necessary survey work carried
out by the developer before development proposals are finalised.
The lack (or inadequacy) of survey information is, unfortunately,
all too common and leads to delays in the planning process and
missed opportunities for enhancing the quality of the development.
24. Natural England welcomes the opportunity
to engage in pre-application discussions with developers on larger
schemes to discuss environmental issues and solutions. We are
also keen to work in partnership on exemplar developments to put
the natural environment at the heart of development proposals.
25. Green Belt policy. Natural
England believes that Green Belt policy has been effective in
containing urban areas and supporting urban regeneration but there
is a potential danger that it can increase pressure for the development
of more environmentally sensitive sites outside the Green Belt.
26. We believe that all potential options,
including the use of green belt land, should be considered in
the search for the most sustainable locations for future development
to meet the country's long term development needs. In particular:
— we support the valuable urban containment
role played by the Green Belt and believe this should continue;
— we consider that a strategic review
of Green Belt boundaries should form an integral part of the regional
and sub-regional appraisal of development options in regional
spatial strategies (and in future integrated regional strategies);
and
— we accept this might mean that some
Green Belt boundaries should be adjusted to accommodate urban
extensions where this is the most sustainable option for development
in the plan period.
27. Much Green Belt land is also of uninspiring
quality and there is potential for it to deliver more positive
benefits for the natural environment and people's enjoyment of
it, and to play a role in climate change adaptation. A greater
emphasis should be placed on the objectives for land within Green
Belts set out in PPG2 Green Belts.
28. In short, we need to "green the
green belt" and, where appropriate, enhance the quality of
the landscape, its biodiversity value, and its role for informal
recreation, agriculture and forestry. We should also consider
how it can be used to help address climate change mitigation and
adaptation.
INFRASTRUCTURE
29. Natural England believes that multi-functional
"Green Infrastructure" should be an integral part of
the creation of sustainable communities throughout England, alongside
more traditional types of infrastructure such as roads, sewers,
schools and community facilities. The role of greenspace in development
has for too long been a secondary consideration, often delivered
as areas of bland "municipal" grassland of little benefit
for biodiversity or local communities.
30. Natural England is pushing for green
infrastructure to be at the heart of planning proposals, with
all major new development being supported by a Green Infrastructure
Strategy.
OUR DEFINITION
OF GREEN
INFRASTRUCTURE IS:
"... a strategically planned and delivered
network comprising the broadest range of high quality green spaces
and other environmental features. It should be designed and managed
as a multifunctional resource capable of delivering those ecological
services and quality of life benefits required by the communities
it serves and needed to underpin sustainability. Its design and
management should also respect and enhance the character and distinctiveness
of an area with regard to habitats and landscape types.
Green Infrastructure includes established green
spaces and new sites and should thread through and surround the
built environment and connect the urban area to its wider rural
hinterland. Consequently it needs to be delivered at all spatial
scales from sub-regional to local neighbourhood levels, accommodating
both accessible natural green spaces within local communities
and often much larger sites in the urban fringe and wider countryside".
31. High quality Green Infrastructure must
be central to the delivery of the extensive housing developments
planned or already underway, throughout the Growth Areas, in the
Growth Points and across the whole country. The preparation of
green infrastructure guidance in the Thames Gateway and the award
winning River Nene Regional Park show that the Growth Areas are
already leading the way.
13 May 2008
1 Set out in particular in PPS1 Delivering Sustainable
Development, PPG2 Green Belts; PPS3 Housing;
PPS7 Sustainable Development in Rural Areas; and PPS9 Biodiversity
and Geological Conservation. Back
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