House of Commons - Environmental Audit Committee

Adapting to Climate Change - Environmental Audit Committee Contents

Memorandum submitted by Natural England

EXECUTIVE SUMMARY

— Natural England believes that climate change is the most serious long term threat to the natural environment and human well-being. Our natural environment is our greatest asset, the basis on which we must build a future in a rapidly changing climate.— To secure a comfortable lifestyle in a world which is likely to warm by between two and four degrees, we must act to protect the long term health of the environment and the ecosystem services which it provides.— Consequently, enabling the natural environment to adapt to climate change is not an optional extra alongside the pressing need to safeguard homes, infrastructure, livelihoods and human life. It must be at the core of adaptation and future growth.

with

— This is a responsibility of all Government departments, not just Defra.

— Natural England has taken a lead in sustainable adaptation, embedding it throughout its operations, establishing demonstration projects to examine appropriate land management responses to a changed climate.

— Assessing the costs and benefits of adaptation solely within individual departments exposes the Government to the risks created by perverse incentives, resulting in unintended consequences. Far more needs to be done towards ensuring the right incentives are put into place. Additionally, there is a great deal to be done to ensure that the costs of adaptation and savings from sustainable adaptation are properly understood and accounted for across the whole of Government, rather than within departments alone, to prevent inappropriate short term or otherwise ill-informed decisions on investment.

— In the future, assessments of value for money, and reporting of these, must be based on sustainable adaptation and a healthy, resilient natural environment, if only to safeguard present and future taxpayers.

— There are practical mechanisms for sustainable adaptation, drawing on expertise and departmental responsibilities from across Whitehall. One of the most effective of these is green infrastructure, and we have drawn the committee's attention to this as a specific example of the cross-Whitehall (and cross sectoral) issues which we must address.

— Sustainable adaptation, predicated on a healthy and resilient natural environment is a responsibility which is shared across Government departments.

1. INTRODUCTION

Natural England is a statutory body created in 2006, charged with the responsibility to ensure that England's unique natural environment is protected and improved.

Natural England's purpose 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.

In our capacity as a statutory adviser to Government, we offer advice on the making of national public policy through our analysis, evidence, and lessons drawn from delivery experience. As an NDPB, we then implement national public policy throughout its own activities via the development of organisational policy (specific to the activities of Natural England), guidance for local delivery, and forward programmes of evidence gathering.

2. ADAPTATION—A NATIONAL IMPERATIVE

2.1 Current efforts to address the causes of climate change are to be welcomed. Natural England supports the actions set in train through the Climate Change Act, and we support the Government's commitment to the creation of a low carbon economy.

2.2 Measures taken must continue to work towards reducing the severity of future changes to our climate. Because it also supplies economically vital ecosystem services, we cannot afford not to conserve the natural environment, and the policy framework needs to be built upon this inescapable truth.

2.3 Despite collective efforts in recent years, substantial change is already "locked" into our climate, resulting from emissions made over many decades. Government and civil society must plan and act to adapt to unavoidable climate change in the short and medium term.

2.4 To fail to adapt, adapt poorly, or simply adapt too late, will be more expensive, and less effective. It is also far more likely to result in unintended consequences than a planned programme for sustainable adaptation enacted now.

2.5 We still have an opportunity to adapt sustainably, efficiently, effectively and towards well planned outcomes. Adaptation remains largely a matter of political choice, not a question of technical capability.

2.6 Enabling the natural environment to adapt to climate change is not an optional extra alongside the pressing need to safeguard homes, infrastructure, livelihoods and human life. It is at the core of sustainable adaptation and future growth.

2.7 Working with—not against—natural processes, affords protection to homes, infrastructure, livelihoods and human life without substantial long term maintenance costs, rising year on year, and without damaging the essentials for life provided by a healthy environment. Future monitoring and reporting arrangements on progress towards successful adaptation must include measures which enable Government and others to scrutinise the degree to which adaptation is leading to a healthier and more resilient natural environment. At present, these are not evident.

2.8 Ecosystem services—unnoticed until they fail—include soil fertility; fresh water catchment and storage; flood prevention and management; and summer cooling in cities. The continued provision of ecosystem services depends on a healthy and resilient natural environment, for which sustainable adaptation is necessary.

2.9 Where ecosystem services can be brought back into production, the costs are likely to be exorbitant—far in excess of the costs associated with damage prevention, particularly in the face of a rapidly changing climate. Where damaged beyond repair, costs of replacement with man-made engineering alternatives are likely to be beyond the reach for many economies, including some in the developed west.

2.10 Current research indicates that the climate may become four degrees warmer, not two which is the target towards which our mitigation efforts are aimed.

2.11 It is responsible to aim at cutting emissions so that the climate does not warm by more than two degrees. It is equally responsible to plan for sustainable adaptation in a world four degrees warmer. Sustainable adaptation offers a solution addressing all the challenges faced in a changing climate, at a potentially much lower cost than some traditional measures.

2.12 Achieving sustainable adaptation will require exactly the sort of cross-Government response of interest to the Committee, enabled by appropriate policies, funding, monitoring and reporting arrangements.

2.13 In Annex 1(a), there are five examples which illustrate the importance of natural systems and sustainable adaptation in tackling some of the risks facing society and the economy.

3. EXAMPLES OF NATURAL ENGLAND'S WORK ON ADAPTATION

3.1 Since our inception in October 2006 we have placed sustainable adaptation at the heart of our own operational policy, decision making and advice.

3.2 Adapting to climate change is necessary to protect ecosystem services, and the best way to secure adaptation is working at landscape scale. In March 2009 we published landscape scale climate change adaptation strategies for the Norfolk Broads,[1] Cumbria High Fells, Shropshire Hills and Dorset Downs.

3.3 The reports illustrate how climate change may affect some of England's most iconic landscapes, and their wildlife and habitats, and suggest the practical measures needed in each place to improve the resilience of the natural environment to climate change whilst retaining its intrinsic value, and ability to provide economic and social benefits. While the different areas require a range of specific adaptation responses, there are some broad actions common to all areas. For example:

— improving the condition of existing habitats;

— restoring lost and degraded habitats;

— extending existing habitats into new areas; and

— adopting sensitive farming methods—for example, leaving vegetated buffer strips around fields and not leaving fields bare.

3.4 The results from these studies will inform Natural England's approach to adaptation at a landscape scale across England, and will inform the advice we will provide to our partners, in particular, the risk assessments and adaptation response strategies that are required by the Climate Change Act. We are working with partners to implement these strategies, and during 2009-10 the project is being extended across England into five more study areas: London, South East Northumberland Coastal Plain, Humberhead Levels, Sherwood, and a regional scale study in the South East of England.

3.5 Natural England plays a pivotal role in the delivery of adaptation on the ground. We administer approximately £0.5 billion per annum of agri-environment monies and have integrated climate change considerations into Environmental Stewardship schemes so that adaptation is increasingly well delivered by private land managers and landowners.

3.6 We have opted to report voluntarily under the new reporting power under the Climate Change Act and are undertaking a risk assessment with regard to our business and climate change, sharing lessons learned and data gathered with other reporting bodies, Defra and stakeholders.

4. THE NATIONAL POLICY FRAMEWORK

4.1 An effective, efficient and up-to-date national framework for policy and delivery is needed if we are to successfully contribute to timely and sustainable adaptation. Experience to date suggests that there are a number of areas where the existing policy framework warrants review and improvement.

4.2 The themes used by the National Audit Office (NAO) usefully set the scene for a cross-cutting approach to the assessment of adaptation policy across Government. The themes are business and the economy; infrastructure; agriculture, food security and the natural environment; homes and buildings (including government estate); and public health.

4.3 The NAO report earlier this year suggests that the natural environment, which underpins the security and sustainability of the other themes, is too easily regarded as the primary responsibility of Defra and not the responsibility of other government departments. But, it is other government departments which are responsible for the development of policy levers which directly deliver and enable adaptation. For example:

(a) DCLG is responsible for measures on planning and development control (including green infrastructure), spatial planning, local government and its regulation, communities, and housing. DCLG are already working closely with Defra.

4.4 The departmental approach to considering climate change risks and adaptation needs is the first, and welcome, step in the Government's overall task.

4.5 Persisting with a consideration of the costs and benefits of adaptation on a departmental basis, however, runs very significant risks to both the goals of sustainable adaptation and good value for money across Government.

4.6 A potential solution is for the assessment of costs and benefits to be undertaken on a whole-Government basis in the future. This would also serve to improve inter-departmental communication as well as practical collaboration toward the Government-wide goal of adaptation, while reducing the risk of unintended consequences across the Government's programme.

4.7 There are some adaptation options which, because they are based on sustainable adaptation, address risks apparent in several of the NAO's themes and draw upon the expertise from across Government departments. Green Infrastructure[3] is one such measure towards sustainable adaptation.

4.8 DCLG, for example, are making progress toward safeguarding homes, communities, infrastructure, business and economic interests, and the natural environment through the increased importance attached to "green infrastructure".

4.9 A changing climate means that the majority of our plants and animals will have to move inland, uphill and north to find new, viable homes. They need green spaces and healthy waterways to move through and to move to—ie connectivity—if they are to succeed. Green infrastructure provides this.

4.10 We particularly welcome the recent announcement by the Secretary of State for Environment, Food, and Rural Affairs on the forthcoming review of the ecological network. The work will provide for greater connectivity, by ensuring landscape around and between protected areas is ecologically coherent, improving vital "wildlife motorways" as a cornerstone of adaptation.

4.11 Green infrastructure has enormous potential to be a vehicle for effective and efficient adaptation of the built environment. But it is a potential not yet realised.

4.12 The existing green space network was designed primarily for amenity, recreation and conservation purposes. Consequently much of it may not be entirely fit for purpose with respect to optimising its adaptation functions—although green space still has a value as a "wildlife motorway" linking urban and rural habitats.

4.13 In future, adaptation functions need to be built into green infrastructure, rather than green spaces being continually rebadged, assigning climate-change functions to them that are incidental rather than deliberate.

4.14 Within the existing policy framework, there are a number of barriers to its potential being fully realised, for example:

(a) Green infrastructure, the environment, and climate change do not yet enjoy a high profile in any single conversation.

(b) None of the existing standards and codes covering the built environment cover green infrastructure or factor in its benefits to incentivise take-up; targets for delivery apply only to new Ecotowns, a fraction of the potential and the need.

(c) The planning system does not look at whole-site functionality and the contribution of green infrastructure to immediate and future goals, leaving the underlying health of the environment unprotected and undervalued.

(d) A fundamental worry for local authorities regarding GI and green space, and a barrier to embracing adaptation, is long term funding. There is no statutory duty on them to manage green spaces and so funding is subject to regular cuts, especially during a downturn.

4.15 There are developments on the national policy front which are beginning to break down barriers to green infrastructure delivery (see Annex 1(c)). Perhaps most importantly, they will help to counter the culture within parts of the planning and development sector which views green space as an optional extra.

4.16 Considering green infrastructure, climate change and health costs together may present fresh opportunities for understanding and managing the costs and benefits of adaptation in the long and short term.

4.17 For example, the currency used in healthcare is the QALY (quality adjusted life year). The accepted cost to add one year of life with good quality is about £30,000. So it would be possible to calculate the number of QALY's saved by increasing the amount of green space that offsets the urban heat island and reduces heat related deaths.

4.18 The multiple benefits offered by some otherwise simple-sounding measures like green infrastructure cannot be realised for the community without understanding and valuing the full range of its benefits to society, the economy, and the natural environment.

Rural "green infrastructure" (fully operational, multi-functional landscapes)

4.19 Reducing the incidence and severity of flooding in the long term rests on a mixture of measures according to the needs of each geographic (not just administrative) area.

4.20 At present, much fluvial flood risk management addresses the symptoms (often at very great cost) and not the causes. If continued, it is likely that expenditure will continue to rise in real terms.

4.21 To address the causes, we need adaptation to climate change in the upper rather than catchments, and for catchments to be understood properly as part of a living, fully functional landscape.

4.22 The inclusion of catchment schemes in the 2009 Price Review (PR09) has been welcome, but the scale at which adaptation and functionality is optimised is at the full landscape scale, not just at the catchment scale.

4.23 The policy framework needs to demand and enable catchment wide planning and decision making, which will require that the multiple agencies involved collaborate effectively on goals of joint importance, working across existing administrative boundaries. EFRAComm's recent report on their pre-legislative scrutiny of the Draft Floods and Water Management Bill made related comments.[4] Effective and transparent collaboration needs to be built on open sharing of data between relevant agencies, also commented on by EFRAComm.

4.24 Linking the benefits of urban, rural, coastal and green infrastructure can be aided and embedded into local practice through the establishment of area wide "adaptation partnerships" similar to those which operate in some other countries.

4.25 These may emerge from existing arrangements to facilitate the requirements of the Water Framework Directive or they may be entirely new.

4.26 Adaptation is not just the responsibility of Government, although Government leadership will always be required. Private land owners and home owners also have a responsibility to enable the country to adapt sustainably.

4.27 The delivery of green infrastructure is currently (and properly) a responsibility shared across several departments of Government. A mechanism to ensure the delivery of green infrastructure (securing the many benefits it offers) across departmental boundaries could be usefully explored.

4.28 Defra have convened two groups drawn from across Whitehall and statutory advisers on aspects of the environment, one which co-ordinates the Domestic Adaptation Programme, and the other which has acted as a stakeholder group to shape the reporting power on adaptation. Both groups have underlined the usefulness of cross-Whitehall collaboration and the need to monitor progress on joint endeavours.

5. THE FUTURE POLICY FRAMEWORK

5.1 There remain many other policy levers, eg agri-environment schemes, CAP reform, regulation of the water industry, which also play a vital role in translating national adaptation policy into the delivery of adaptation. These policy levers should be reviewed to ensure that they support and not undermine sustainable adaptation.

5.2 Achieving our renewable and low carbon energy targets must not run counter to the needs of sustainable adaptation, and adaptation and mitigation must not be treated as competitive or counter-weighted alternatives. Done well, adaptation aids and speeds efforts on mitigation.

5.3 Future assessments of value for money should be based on sustainable adaptation and a healthy, resilient natural environment if the nation is to maximise the value of Government investment and retain the use of naturally produced ecosystem services.

5.4 Payment and grant schemes, such as regeneration grants and European regional development funds, should in future require applicants to plan for and report on sustainable adaptation.

5.5 In addition to reporting on financial probity, government departments and the wider public sector should be required to report on non-financial measures, which indicate the extent to which their actions add up to sustainable adaptation, eg the impact of policy and delivery on the capacity of the natural environment to adapt successfully.

5.6 The regulatory frameworks overseeing key sectors, eg the water industry, should also be reviewed to ensure that they send the right signals, requiring sustainable adaptation.

5.7 Annex 1(b) provides two examples of issues to be addressed in the water industry sector. These examples illustrate the need to ensure that "second tier" policy making—whether through policy guidance or regulatory and financial levers—is fully aligned with sustainable adaptation, part of the Government's overall policy objectives. At present, this is far from the case, as the examples in Annex 1(b) illustrate, and it is in the misalignment of policy objectives and second tier policy levers where failure is most likely to occur.

5.8 Future legislation—domestic, European, environmental and non-environmental, first and second tier—therefore needs to be designed to ensure that it doesn't unintentionally run counter to the needs of sustainable adaptation.

Annex 1(a)

6. THE ROLE PLAYED BY THE NATURAL ENVIRONMENT IN ENABLING ADAPTATION FOR HUMAN SECURITY

The role of woodlands

6.1 England is one of the least forested countries in Europe, with only about 9% tree cover compared with 37% in the EU as a whole (Forestry Commission 2008). Tree planting and appropriate woodland management is an effective and sustainable contribution to achieving a wide range of climate change objectives.

6.2 Woodlands can manage important environmental risks, which will increase with climate change, such as soil erosion, agricultural runoff, rise in water temperature and consequent declines in water quality, and flooding (Caissie 2006; Conlan et al 2007; Sudgen et al 2008). Trees also regulate the local climate and provide shelter from wind and storms to protect crops, livestock and soils, as well as supporting important pollinating insects (Sugden et al 2008; Escobedo et al 2009; Merckx et al 2009a, 2009b). Growing trees to produce timber or wood fuel help farmers spread the social and financial risks from climate change (Sugden et al 2008). All these services are likely to become even more important to society under the extreme climatic changes that four degrees would bring especially as flooding, water pollution, heat waves, droughts and unpredictable conditions become more frequent and severe (Murphy et al 2009).

6.3 Trees play an increasingly important role for human health and recreation in a 4+ degree world. In cities, there would be vital shade and temperature regulation benefits for people by increasing the number and area of trees in urban landscapes (Gill et al 2007; Escobedo et al 2009). In the countryside, woodland areas may become increasingly important as cool places where people can enjoy the outdoors, away from the summer heat.

6.4 In addition to its adaptation benefits, woodland provides a major carbon sink by sequestering carbon within its timber and maintaining soil carbon stores (Choudrie et al 2008); in some cases mitigation may be best achieved by sustainable timber harvesting for fuel and materials (Nabuurs et al 2007). Even where such wood is used for fuel it saves carbon by substituting for fossil fuels, and where wood is used in construction there is a double saving—stored carbon in the timber, and the savings arising from reduced use of steel.

Keeping blanket bog in good condition tackles both adaptation and mitigation

6.5 Blanket bog is found across the UK, including in the English uplands where high rainfall and poor drainage frequently result in waterlogged conditions; the largest areas are in the Pennine Hills.

6.6 Blanket bog provides a number of ecosystem services with a direct bearing on the quality of human life (O'Brien et al 2007); two of the most important are carbon storage and water supply.

6.7 The peat is a substantial store of carbon, which has built up over thousands of years and healthy bog continues to steadily remove carbon from the atmosphere, although there may be small releases of methane through decomposition (Thompson 2008).

6.8 Catchments covered with blanket bog are a major source of water supplies for large numbers of people in the Midlands and north of England. They are also areas which can support low intensity sheep grazing and contribute to a highly valued landscape with a well developed tourist industry (Usher & Thompson 1988).

6.9 Blanket bog can be degraded by a range of factors including drainage, over-grazing and air pollution (O'Brien et al 2007). In a degraded state, soil erosion leads to the release of carbon and a changed hydrology with poorer quality and more variable water supply and increased risk of flooding downstream, increasing the costs borne by householders, water companies, water bill payers and local authorities.

6.10 Climate change is likely to exacerbate this degradation particularly if summer droughts become more frequent.

6.11 The solution, restoring blanket bog, safeguards service provision and increases resilience of these services to climate change as well as protecting conservation interests. There are already efforts being made to block grip drains and increase water levels in some moorland areas to improve bog condition in order to maintain carbon storage and water resources.

Management of rivers and catchments to safeguard homes, communities, infrastructure and economically vital ecosystem services

6.12 Appropriate management of rivers and catchments is crucial to both the provision of clean water and the management of flood risk, along with a range of associated services.

6.13 Climate change projections (Murphy et al 2009) suggest that we will see both an increase in summer droughts and in extreme flooding events and these are likely to be increasingly severe as we approach a 4+ degree world.

6.14 Where rivers and their catchments have been degraded by channelisation, pollution, excessive water abstraction and destruction of riparian vegetation, they will be less able to provide the services society requires.

6.15 Restoration of floodplains with healthy natural ecosystems which naturally regulates flow will greatly improve their ability to store and absorb large flooding events. This affords protection to built-up areas and greatly reduces the scouring impacts of large water flows down rivers (Wheater 2006). Restoring riparian vegetation can also guard against water pollution, the risk of which is likely to increase with climate change (Caissie 2006; Sugden et al 2008)

6.16 Elements of natural floodplain ecosystems such as wetlands also have the potential to store water at times of excess and gradually release it back into the environment, reducing the frequency and impact of local drought and flooding.

Managed realignment of coastlines to protect communities and infrastructure long term

6.17 In a 4+ degree world, sea-levels may rise substantially, threatening large parts of England's coastal areas with inundation, particularly those on the eastern and south-eastern coasts. Hard defences, such as sea-walls will be very expensive, become increasingly costly to maintain, and potentially unsustainable, against the continued erosive forces of the sea.

6.18 Working with nature, using salt marsh and other coastal habitats to create more storage space for high tides and to reduce the energy of the sea before reaching such defences, can cut costs and greatly increase sustainability (Defra 2005).

6.19 Managed realignment involves breaching sea walls and letting the sea advance to cover the land behind it. In most cases, new flood banks are constructed behind the wall that is breached; the sea covers the land between the old and new defences and intertidal habitats are gradually established (Dixon et al 2008).

6.20 The techniques are neither new nor untested. There have been over twenty realignment projects in the UK designed either for habitat conservation or flood risk management or both, the largest of which, at Alkborough on the Humber estuary, protects 90,000 hectares of land and 300,000 properties from sea level rise. In addition, it has produced new recreation opportunities to benefit the local community both directly through increased tourism, as well as significant conservation benefits (Environment Agency undated; Dixon et al 2008).

Maintaining and increasing biodiversity to increase resilience and protect ecosystem services

6.21 Living with extreme climate change will demand our leaders to make some very difficult decisions about society, our economy, and the environment on which are lifestyles are based. The natural environment performs a number of functions and provides multiple benefits through these, but in advocating the role of nature conservation as a way of ensuring the continuation of a fully multi-functional natural environment, we accept that this presents decision makers with many hard choices.

6.22 If policy makers use the existing language of trade-offs, they will need to better understand the costs and benefits (not just monetary, but ecological and social) of the likely trade-offs between different services and to develop decision-making models to help make the optimal choices.

6.23 If the trade-off debate persists, then the evaluation of trade-offs must fully recognise the cost-effective benefits that natural environments provide and will increasingly provide in a 2+ and 4+ degree world.

6.24 Sustainable adaptation will ensure that while safeguarding life, property, and economically vital ecosystem services, the intrinsic value of the natural environment is protected for future generations too.

Annex 1(b)

7. OFWAT'S—REGULATORY REGIME—THE PRICE REVIEW PROCESS

7.1 Ofwat have tried to set up a longer term 25 year framework in this current price review (PR09) through introducing a requirement for water companies to produce 25 year Strategic Direction Statements.

7.2 This process has helped water companies set out longer-term adaptation/mitigation needs, but investment is still constrained within the five-year process and is dependent upon cost benefit analysis and must be supported by customers.

7.3 In reality the costs and benefits of longer term planning are not always easy to describe and customer priorities tend to focus on the immediate provision of good quality drinking water. At this current stage in the PR09 process a number of water companys Strategic Direction Statements are no longer consistent with Ofwat' draft decisions (Draft Determinations).

7.4 The Price Review five year investment cycle is not alignment with the Water Framework Directive (WFD) cycle—which runs over six years and made an attempt to align with the statutory Water Resource Management Plan (WRMP) cycle introduced this time—but so far only 10 (out of 22) company WRMPs have been approved by the Secretary of State—the remainder are going to inquiry, appeal or need to provide further information, therefore will not complete in time to inform Ofwat's final determinations on PR09.

7.5 The WRMPs are 25 year plans—and once signed off by the Secretary of State companies need to deliver them—but they only have commitment through the Price Review process to investment for five years.

7.6 Suggested remedies:

(a) Need to align the Periodic Review process with River Basin Management Plans and Water Resource Management Plans.

(b) There needs to be a more flexible approach to investment within the 5 year cycle to enable longer term adaptation/mitigation.

7.7 An EfraComm report into PR09 (July 2009)—set out a recommendation that Defra provide Ofwat with clear guidance on the application of CBA and that Ofwat's guidance should be clear and unambiguous. The report also included a recommendation that Defra should consider if changes are needed to the regulatory regime to ensure that water companies have incentives to take early action to adapt to climate change.

7.8 OFWAT's current regulatory focus has been said to discourage green infrastructure solutions in favour of hard engineering solutions which have an asset value and so are better able to boost shareholder value than "soft" engineering solutions. Yet in many instances "soft engineering" measures may be far more sustainable and increase the resilience of our natural systems, in contrast to the consequences of some hard engineering alternatives.

Annex 1(c)

8. GREEN INFRASTRUCTURE—BARRIERS WITHIN THE POLICY FRAMEWORK

8.1 The existing green space network was designed primarily for amenity, recreation and conservation purposes. Consequently much of it may not be entirely fit for purpose with respect to optimising its adaptation functions—although green space still has a value as a "wildlife motorway" linking urban and rural habitats.

8.2 In future, adaptation functions need to be built into green infrastructure, rather than green spaces being continually rebadged, assigning climate-change functions to them that are incidental rather than deliberate.

8.3 Within the existing policy framework, there are a number of barriers to its potential being fully realised, for example:

(a) Green infrastructure, the environment and climate change do not yet enjoy a high profile in any single conversation, so the synergies are unrecognised and so undervalued.

(b) Although the Code for Sustainable Homes standard for new homes includes "ecology" in the mix of criteria at the higher levels, this is not framed in a way which fully acknowledges the contribution of green infrastructure to climate change adaptation. This is a weakness because it fails to make the social and economic case for sustainable urban adaptation and deprives home owners of those benefits as design features when they make a purchase.

(c) The zero-carbon homes standard is largely about insulation standards, and doesn't allow developers to factor in the climate change benefits of green infrastructure—so do not count towards the zero carbon targets. This is a weakness because it does not encourage developers to retain or create adequate areas of green infrastructure.

(d) The planning system does not currently look at whole-site functionality and the contribution of green infrastructure to immediate and future goals. Therefore the assets, eg natural watercourses and drainage patterns, boundary and shade trees, encapsulated areas of mature woodland, wetlands, and the underlying health of the environment is not protected and its functionality is too often compromised.

(e) Accessible Natural Greenspace Standards (ANGSt) is the only widely promoted standard, but it is not about adaptation, and only has advisory status at present. Green infrastructure provision within "Accessible Natural GreenSpace" Standards' has been largely related to accessibility for health and recreation. As such, the standard is not related to the area of GI needed to provide climate change adaptation benefits, for which there is no standard available, but one we believe is required.

(f) The evidence base on how much green infrastructure is needed remains weak and incomplete, exacerbating the problems with developing and setting any improvement to the ANGSt.

(g) Although Government policy provides general support for green infrastructure (eg PPS 9, PPS 17, Ecotowns prospectus) there is no binding national policy requirement nor statutory standard for the provision of green infrastructure associated with new housing development. Consequently, developers and local planning authorities may not understand Government expectations in terms of provision for green infrastructure.

(h) Furthermore, with pressures on budgets for infrastructure, and the removal of ring-fenced funding for green space in the Growth Area Funding programme for 2008, local authorities may be unwilling to prepare green infrastructure strategies; and developers unwilling to pay for habitat creation, enhancement, or long-term management.

(i) A fundamental worry for local authorities regarding GI and green space (and therefore a barrier to them embracing adaptation) is long term funding. There is no statutory duty on them to manage green spaces and so funding is often described as hand-to-mouth and subject to regular cuts, especially during an economic downturn. Vesting green spaces in not-for-profit Trusts (as per Milton Keynes) is one alternative but not appropriate or achievable everywhere.

8.4 There are developments on the national policy front which are beginning to break down barriers to green infrastructure delivery (see below). Perhaps most importantly, they will help to counter the culture within parts of the planning and development sector which views green space as an optional extra.

(b) Planning Policy 12 (Spatial Planning) now references GI alongside other infrastructure needs that should be addressed in Local Authority Core Strategies.

(c) The Government's Quality of Place Strategy published earlier this year committed Government to producing new Planning Policy Guidance for GI. This should be included in the new Planning Policy Statement which will combine PPSs 7, 9 and 17.

5 October 2009

1 Formed by peat excavation over many centuries past, which at the time released of green house gases and reduced that region's carbon sink capacity-but long before either became an issue. Back

2 The costs of non-adaptation, mal-adaptation and delayed adaptation were detailed at a global scale in the report from Sir Nicholas Stern. Back

3 Green infrastructure refers to a suite of urban and rural land engineering measures such as porous paving and sustainable urban drainage; sub-surface flood attenuation; public and private buildings orientated to benefit from summer shade and winter wind breaks; water catchment and storage; carbon capture and storage; as well as the more familiar elements such as more tree cover, enriched biodiversity, and more open green space. Back

4 EFRAComm Report on the draft Floods and Water Management Bill September 2009 Back

5 References:
Defra's Social and Environmental Guidance for Ofwat (August 2008)
http://www.defra.gov.uk/environment/quality/water/industry/review/documents/ofwat-guidance080922.pdf Back

6 The 49 areas where local planning authorities are willing to pursue housing numbers over and above what they are obliged to deliver. Back



© Parliamentary copyright 2010	Prepared 25 March 2010