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Call for Evidence

Environmental sustainability and housing growth

Call for Evidence

The Environmental Audit Committee is seeking views on how the Government’s proposed reforms to national planning policy and housebuilding targets might affect environmental protections and current approaches to sustainable development.

Background

On 30 July the Government published a consultation paper on its proposed changes to the National Planning Policy Framework (NPPF) “in order to achieve sustainable growth in [the] planning system [in England]”.[1] The proposals in the consultation, which closed on 24 September, can be categorised broadly as an element of the Government’s overall ‘mission’ to deliver economic growth.

The Government plans amendments to the National Planning Policy Framework in order to release more land for development. Included in the Government’s proposals are changes to the current ‘standard method’ for assessing housing need in each local authority area.[2]

The Government explains that the purposes of the proposed changes are (among others) to:

  • amend current methods of calculating planned housing supply to ensure that local plans can be ambitious enough to support the Government’s manifesto commitment for 1.5 million new homes in this Parliament;
  • broaden the existing definition of brownfield land, set a strengthened expectation that applications on brownfield land will be approved and that plans should promote an uplift in density in urban areas;
  • identify ‘grey belt’ land within the existing Green Belt, which is to be brought forward into the planning system through both plan and decision-making to meet development needs;
  • improve the operation of the planning presumption in favour of sustainable development, so as to ensure that it acts as an effective support to housing supply, and by introducing safeguards against poor-quality development;
  • set so-called “golden rules” for development on land released in the Green Belt to ensure that such developments are in the public interest;
  • support economic growth in key sectors, aligned with the Government’s industrial strategy and future local growth plans;
  • deliver community needs to support society and the creation of healthy places; and
  • support clean energy and the environment.

Biodiversity net gain

Since February 2024 developers in England have been under a statutory requirement to deliver at least a 10% increase in biodiversity when major building projects, including housebuilding projects, are undertaken. The then Government committed £10.6 million ‘to help local authorities recruit and expand ecologist teams, investing in green jobs and increasing capacity to create new wildlife-rich habitats alongside developments’.[3]

Reducing the use of embodied carbon in construction

In March 2022 the Climate Change Committee drew attention to the lack of a Government strategy to address the use of embodied carbon in new developments: “The Government’s strategies do not address the issue of embodied carbon associated with constructing new buildings.”[4]

The Environmental Audit Committee in the 2019 Parliament made a number of recommendations in respect of the use of embodied carbon in new build developments, specifically recommending the introduction of mandatory whole life carbon assessments in developments which create more than ten dwellings.[5] The then Government responded to this report, issued in May 2022, by indicating that it planned to consult on the use of embodied carbon in construction in 2023, but no such consultation appears to have been undertaken.[6]

The Nature Recovery Network and local nature recovery strategies

The Government’s aims for the Nature Recovery Network for England, launched in October 2020, include “aligning policies, delivery levers and funding streams […] to better achieve priorities, including [in] planning policy and practice”.[7]  Responsible authorities have been designated to lead on the preparation of local nature recovery strategies across England: these strategies are to be prepared for each of the 48 local nature recovery areas which between them cover the whole of England. Local planning authorities have a statutory duty to have regard to these strategies in complying with their duty under the Environment Act 2021 to consider what they can do to protect and enhance biodiversity and to act to deliver those policies.[8]

Housing development and land use

The Government is piloting a National Land Data Programme “to demonstrate how […] complex decisions around land use can be supported by spatial data and modelling, to enable better and more informed decision making”.[9] The Government has recently undertaken to issue a consultation on land use “to inform the publication of a Land Use Framework for England. The land use framework will support […] nature recovery, based on an evidence base and spatial analysis”.[10]

Defra review of environmental regulation and growth

On 15 October 2024 it was announced that the economist Dan Corry had been asked to lead an internal review into the regulation and regulators overseen by the Department for Environment, Food and Rural Affairs.[11] The overall purpose of the review is “to develop recommendations to ensure that regulation across the Department is driving economic growth while protecting the environment.” It is to explore whether the Department’s regulators “are equipped to drive economic growth, secure private sector investment and protect the environment”.

The Department explains that the review is part of work to position itself as “a key economic growth department”, reforming regulation to “develop pragmatic solutions that are needed to build the homes and infrastructure [the] country needs, while protecting and improving environmental outcomes.”

The regulatory reform agenda is also intended to promote the development of the circular economy “by reusing more existing materials, driving down waste across key sectors such as construction and packaging, reducing import costs for businesses and cutting carbon emissions.”

Recent Committee work

The House of Lords Built Environment Committee reported in September 2023 on the impact of environmental regulations on development. The Committee found that two Government policies— “a drive for development—particularly of housing—and the promotion of new infrastructure; and a commitment to protect habitats and halt the decline of species”—ought to be achievable in a mutually reinforcing way. In practice, the Lords found that this objective had been “hampered and sometimes completely blocked by lack of co-ordination in policy-making and haphazard and unbalanced implementation.”[12]

“Throughout this inquiry it has become clear that until the Government reconciles its own policy goals, it will continue to constrain new housebuilding in the name of improving the environment without delivering that goal either. There is a real risk that necessary homes and vital environmental protections will not be delivered.”

That Committee is currently concluding its inquiry into the proposed ‘grey belt’, examining how ‘grey belt’ land within current Green Belt boundaries is likely to be defined, and the tests proposed for releasing such land for development.[13]

The Environmental Audit Committee plans to work collaboratively with the Lords Built Environment Committee and with any other parliamentary committee with an inquiry touching on the topics covered in this call for evidence.

The Committee plans to hold an initial standalone oral evidence session on Wednesday 20 November to gauge concerns expressed about how the Government’s plans for housing growth can be balanced with its environmental commitments.

Environmental sustainability and housing growth

Terms of reference

The Committee invites written submissions addressing any or all of the issues raised in the following terms of reference, to be received through the Committee’s inquiry portal by 5.00 pm on Friday 20 December 2024:

General

  1. What provisions will the National Policy Planning Framework, as revised under the Government’s proposals, make for protection and enhancement of the environment? Are these provisions likely to be adequate?
  2. What policy levers does the Government plan to use to ensure that local authorities deliver the development which the revised NPPF ‘standard method’ requires? Do the Government’s plans result in local planning authorities being penalized if delivery falls short? What policy levers will be available to local authorities to ensure that developments which have received planning approval are delivered in accordance with consents?
  3. To what extent is the current planning presumption in favour of sustainable development compatible with the environmental objective of the planning system? To what extent will the proposed ‘streamlining’ of the sustainable development presumption work to deliver developments which will meet this objective and be compatible with the Government’s environmental targets and obligations?
  4. How will the revised NPPF work to deliver the social and environmental objectives of the planning system? To what extent will it promote outcomes which deliver sustainable social and environmental benefits together, such as access to essential amenities, to public transport and to active travel routes?
  5. What contribution can the NPPF make to meeting Government targets for the reduction of greenhouse gas emissions? What account does the NPPF take of advice from the Climate Change Committee on reducing the use of embodied carbon as well as operational carbon in the built environment?
  6. Will the Government's proposals affect the ability of local authorities to implement policies designed to protect the natural environment in their areas?
  7. What (if any) trends are observable in (a) delivery of environmental improvements (b) the purchase and trading of credits arising from the Environment Act requirement for developments to yield biodiversity net gain (BNG)? How are planning authorities using BNG in the planning process to deliver environmental improvements from housing development?
  8. How will the revised NPPF operate to promote the Nature Recovery Network and the implementation of local nature recovery strategies by responsible authorities?
  9. What use can planning authorities make of the data analysis and modelling being developed under the National Land Data Framework to support planning decisions which lead to better environmental outcomes? How should the NPPF be integrated into the forthcoming Land Use Framework?
  10. What environmental regulatory arrangements within Defra’s remit which relate to the planning process are likely to be under review as potential inhibitors of growth? What effect on environmental protections would reform of these regulations be likely to have?

Footnotes

[1] Ministry of Housing, Communities and Local Government, Proposed reforms to the National Planning Policy Framework and other changes to the planning system, 30 July 2024

[2] MHCLG consultation paper, chapter 4: ‘A new Standard Method for assessing housing needs

[3] Department for Environment, Food and Rural Affairs news story, ‘New housing developments to deliver nature boost in landmark move’, 12 February 2024

[4] Climate Change Committee, Independent Assessment: The UK’s Heat and Buildings Strategy, March 2022

[5] Environmental Audit Committee, Building to net zero: costing carbon in construction, First Report of Session 2022–23, HC 103, 26 May 2022.

[6] Environmental Audit Committee, Building to net zero: costing carbon in construction: Government Response, Third Special Report of Session 2022–23, HC 643, 30 September 2022.

[7] Department for Environment, Food and Rural Affairs, The Nature Recovery Network, October 2020 (updated February 2024)

[8] Department for Environment, Food and Rural Affairs, Local nature recovery strategy statutory guidance, March 2023, and Complying with the biodiversity duty, May 2023

[9] Department of Science, Innovation and Technology, National Land Data Programme: Pilots and projects overview, May 2023

[10] Answer by Mary Creagh CBE MP (Minister for Nature) to written question from Ellie Chowns MP, 1 November 2024, UIN 10879

[11] Department for Environment, Food and Rural Affairs news story, ‘Dan Corry appointed to lead Defra regulation review’, 15 October 2024

[12] House of Lords Built Environment Committee, The impact of environmental regulations on development, Second Report of Session 2022–23, HL Paper 254, 21 September 2023, summary

[13] Details of this inquiry are available on the House of Lords Built Environment Committee’s pages at https://committees.parliament.uk/work/8503/the-grey-belt/

This call for written evidence has now closed.

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