Examination of Witnesses (Questions 40-58)
MR JAMES
MARSDEN, MR
DAVID BROOKE,
DR TONY
GRAYLING AND
MR RICHARD
HOWELL
13 MAY 2008
Q40 Mr Stuart: Concerns have been
raised about so-called "garden-grabbing", going back
to the issue of biodiversity and so-called brownfield sites. Of
course, planning regulations appear to encourage that by classifying
all gardens as brownfield sites. Is this a big issue in terms
of environmental impacts? Going back to your earlier evidence
that where there was biodiversity you were pleased with ecology
being one of the criteria, that building should be resisted, what
should be done about ensuring gardens do not continue to be built
on where that is not appropriate?
Mr Marsden: I think the first
point to make is that gardens are part of the green infrastructure
we are taking about but, by their nature, they tend to be private
so public access is not readily available to them. That does not
distract from their function and the function that they provide.
They provide the same services that green space open to public
access provides. By definition they provide an important and valuable
service, yes, in an urban context.
Q41 Mr Stuart: What should be done
to stop the current garden-grabbing that is going on?
Mr Brooke: We have not actually
taken a view on that.
Q42 Mr Stuart: Why not?
Mr Brooke: It is not on our current
list of needs.
Q43 Mr Stuart: If I looked at your
organisation and I looked at what was happening in towns and cities
right across the country and I would think you would take an interest?
Mr Brooke: As James has said,
we are interested in green infrastructure and gardens are part—
Q44 Mr Stuart: And just said that
gardens are an absolute critical part of green infrastructure
and you have never looked at them, even while they are being concreted
over?
Mr Brooke: Our policy is under
development.
Q45 Mr Stuart: Sadly the development
of your policy seems to be a long way behind the actual development
on possibly bio-diverse land?
Mr Brooke: It is certainly an
area for investigation, that categorising gardens as brownfield
land, previously used land, may be something that needs looking
at.
Q46 Martin Horwood: You have talked
about using planning to avoid making flood risk worse. The current
planning regime certainly allows you to input on planning decisions
in terms of whether area and the site itself is at flood risk.
Do you think it adequately protects or gives you powers to prevent
development where the development of a site would make flooding
worse elsewhere by increasing run-off, by increasing urbanisation
in a particular area? That landscape scale consideration is obviously
now rather important and I speak as a Gloucestershire MP where
this is all rather personal.
Mr Howell: The overall thrust
of PPS25 on flood risk is to reduce flood risk overall, and so
it does allow us to take into account development that would increase
risk to, for example, settlements further downstream, and advise
the local authority if that is the case.
Q47 Martin Horwood: You are happy
with that?
Dr Grayling: One of the difficulties
in this area, as you will know from your own experience, is that
surface water flooding has become a much more prominent issue
and with climate change will become more so. At the moment we
do not have good surface water flood risk maps. We are trying
to get there as an Agency. We are having a first go at them this
year. Fundamentally we need that in place first before we can
give good advice when consulted as a statutory consultee on major
new developments. It is certainly our intention to rapidly get
there, and then we will indeed be using our role under PPS25 to
advise properly on new developments.
Q48 Mr Caton: Following on from that,
is what you are saying that you have not got the information yet
to actually use the planning system to prevent developments on
areas liable to flood?
Dr Grayling: Yes, in honesty,
I am saying to you that it is a very complicated picture because
you need to understand the drainage systems as well as the way
in which the surface water will run off. We are in the process
of putting those maps together this year.
Q49 Mr Caton: Both organisations
have given great emphasis on using the planning system to get
houses in the right place, although you have obviously shown us
a loophole. Are there other problems with the current planning
system that prevent us getting these properties in the right place?
Mr Brooke: The planning system
is pretty robust, in our view, at a regional and local level.
It has got the ability both from a policy point and indeed in
making the decisions. It has the tools at its disposal and policies
at its disposal to make the right decisions. We are very happy
as organisations with statutory responsibilities, advisory responsibilities,
playing our part in that.
Q50 Mr Caton: You in Natural England
have called for planning approval to be based on the environmental
capacity of the area. How is this measured; and is it being followed?
Mr Brooke: Environmental capacity
is a concept that has been around for a long time, decades really.
It has never really been drawn together. Certainly we are starting
a programme as of this year to try and draw what knowledge there
is together to try and get a handle on what it means and, more
importantly, how it could be applied through the planning system.
It is quite easy to understand in concept but quite a tricky thing
to get hold of in practice. Certainly it is a question of looking
at the threshold or the boundary beyond which development would
have an effect on the natural environment so that the environment
would have difficulty in functioning as an ecosystem.
Mr Marsden: We have talked about
some examples of that this morning already: water supply; the
flood plains; minimising harm to acknowledged biodiversity importance.
You factor all those in and you begin to understand in addition
the services that that environment, in which you want to put the
houses down, provides over and above those I have already mentioned:
what is the limit; what is the capacity of a given area. This
can work at a local development plan framework level; it can work
at a subregional level; it can work at a national level.
Q51 Mr Caton: The Woodland Trust
in a submission to us[15]
have stressed that land can be adversely affected by adjoining
developments, even if it is not built upon itself. Can this be
taken into account in the planning system, and is it?
Mr Marsden: It can and there are
some examples where it has been. I would cite the Thames Basin
Heaths as an example. It has not worked perfectly but it has worked
pretty well. Another example would be the Dorset Heaths where
similar agreements and similar approaches have been worked through
the planning system. A third example would be in the Cotswold
Water Park where new development around the lakes created by gravel
extraction has been sited and positioned in such ways as to avoid
environmental harm.
Q52 Dr Turner: Can I just come back
to the activities in relation to the planning system, because
I have personally been involved in doing strategic plans and local
development plans and it was just not a factor—this was
simply not a factor—whereas in retrospect it absolutely
should have been. What steps are you taking to ensure that flood
plain issues are actually an essential part of the strategic and
local development planning process, because without it it is not
going to go anywhere if it is not mandatory?
Mr Howell: With the introduction
of PPS25 a number of measures are mandatory, including the carrying
out of strategic flood risk assessments right down to site-specific
flood risk assessments. When you are doing the strategic planning
level and bringing it down to the local development frameworks
then if there has not been a strategic flood risk assessment we
will ask for one of those. As an example of how things have worked
well, on the existing growth points and, for example, the eco
towns, we have worked closely with the government departments
to carry out high level assessments well before issues enter into
the planning system; to highlight issues that those proposed developments
may give rise to, and point out what studies, such as strategic
flood risk assessments or water cycle studies, need to be undertaken
to fully expose what the implications of those developments are
and identify appropriate solutions. Through things like strategic
flood risk assessments then the specific implications of a development
for flooding are highlighted and then taken into account when
they enter into the development plan.
Q53 Mr Chaytor: The written evidence
from Natural England laid great emphasis on the concept of "green
infrastructure", and you have mentioned this two or three
times already, but it seems a rather vague concept. Could you
give us some practical examples of what well developed green infrastructure
would be in a new development?
Mr Marsden: Firstly, we think
that well planned, multifunctional green infrastructure should
be part of every built development; that is essentially what is
going to make it a sustainable community from the perspective
of the natural environment. What would it look like? Corridors,
networks of green spaces interconnected by access; the warp and
weft of the built environment, connected to its rural hinterland
wherever possible along linear routes.
Q54 Mr Chaytor: How are planning
authorities going to make that a requirement of new developments?
What is the state of play and what progress has been made to build
this into planning guidelines?
Mr Brooke: We have been working
closely with the growth areas—the local authorities and
government departments. The way the green infrastructure is being
applied there are green infrastructure strategies, where the planning
authorities at a very early stage of plan-making would include
a green grid, almost, as a starting point for developing those
areas against this strategy, which sets out the functions, the
practical advice and so forth. Each of the growth areas has got
a green infrastructure strategy in place, although it is a bit
early to see anything practically on the ground yet. The idea,
which we have been pushing and helping with very much, is as an
exemplar: if it works here it will work elsewhere as well. There
are many examples round the country in fairly small areas where
a housing estate has included green walkways and corridors and
so forth in it. The idea of a green infrastructure strategy takes
that into a much bigger dimension.
Q55 Mr Chaytor: In the growth areas
will this be an absolute requirement?
Mr Brooke: Absolutely, it should
be, yes. In view they cannot succeed without it.
Q56 Mr Chaytor: Are there ways in
which green infrastructure and new developments could enhance
the position of existing developments? I am thinking, going back
to the question of flood risk, are there ways that flood risk
of existing developments could be reduced by the introduction
of appropriate green infrastructure for new adjacent developments?
Mr Brooke: I would struggle with
the technical answer to that.
Mr Howell: A lot depends on the
geography of the particular situation, but certainly there is
scope for flood storage areas which would be part of the green
infrastructure to take up flood waters to reduce the flood levels
in a built-up area, yes.
Q57 Martin Horwood: Could I just
pursue the question on growth areas. I have seen some provisional
ideas from developers on a growth point in my area and it includes
very little green space at all. Logically from their point of
view as a business they want to maximise the return on each hectare
of land. Do you have a guideline percentage of green space in
mind that would help local authorities to challenge plans like
that and say, "No, there must be a greater percentage of
green space"? This could be as successful as the percentage
of affordable housing.
Mr Brooke: Yes, we do. With the
ANGSt standards (assessable natural green space standards) which
we published earlier in the year—which essentially set up
principles not for designing a green infrastructure strategy but,
nevertheless, provide the basis for that to be done—no person
should live more than 300 metres from their nearest area of natural
green space; at least two hectares and so forth; and a range of
other standards of that sort of thing. That is a starting point
for local authorities.
Q58 Martin Horwood: What force do
those standards have now?
Mr Brooke: They are our advisory
standards. Our ambition is to get them included in local development
frameworks so they are part of local authority policy.
Mr Marsden: We would add we warmly
welcome the proposal for 20% of an ecotown to be green space;
that is in the consultation document. We think that is a pretty
sensible measure.
Chairman: Thank you very much indeed.
We have covered some useful ground. We are very grateful to you
for coming in.
15 See Ev 108. Back
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