13
Examination of witnesses
David Lowe and Hamish Walke.
The Chair: Welcome back to this evidence session of the Built Environment Committee in our inquiry into environmental regulation and development. Our witnesses in this session are David Lowe, who is the delivery leader for ecology, historic environment and landscape at Warwickshire County Council, and Hamish Walke, who is responsible for water neutrality at Crawley Borough Council. Can we start with our first question, from Lord Mawson?
Q43 Lord Mawson: Good morning. There are two parts to my question. First, do local planning authorities read and fully engage with all the information they are presented with? Secondly, do you have sufficient expertise to take decisions as a competent authority?
Hamish Walke: I will answer that, and if David has something else to add, he can do so. I work in development management, so I deal with planning applications. The first thing to stress about the planning system is how complex it is. There is a lot of information covering a huge range of issues, and there probably is not another system quite like it. The planning system, obviously, is here to balance those issues and come to reasoned judgments, taking account of that variety of issues. It is inevitable, therefore, that it receives an awful lot of information covering a huge range of topics. The short answer to your question is yes, we do read everything that comes in.
The planning officer for an application or someone dealing with a local plan would take a co-ordinating role. So when I deal with a planning application, I read the information that comes in. Obviously, a lot of it is very technical and complex, whether it is on ecology, transport or other issues, so we have a lot of consultees. They may be statutory ones, such as the Environment Agency or Natural England, or more local ones, such as the county council highways team. We are dependent on their technical expert advice on a number of issues, but the short answer to your question is that everything is read and is engaged with through the planning system.
Your second question was about having sufficient expertise within the authority. Obviously, I am here to talk about water neutrality, which is a new issue. I think we are the first place in the country that has been affected by water neutrality, and it is safe to say that it has been a big challenge. I am not sure there are any experts on water neutrality, or at least there were not when the issue arose. I do not think we had the expertise within Crawley Borough Council at the time the issue arose. We have had to go out to external ecologists and water consultants to support us in dealing with applications and moving our local plan forward.
Obviously, that has come at a cost. This issue affects five different authorities; I have spoken to some of my colleagues. Horsham District Council, for instance, has had an additional issue because a number of bore-holes have been suggested there, so it has had to gain geological and hydrological expertise as well.
There has been a lot of use of external consultants for advice on this. Within most local authorities, you were not going to find a situation where they had the expertise in-house. We have had to go outside to get it. Yes, we have gained sufficient expertise, but at a financial cost to the authority in trying to progress the water neutrality issue.
As said in the earlier session, it is worth pointing out the pressure on planning departments in terms of resources. We have struggled to recruit—
The Chair: We are quite aware of that.
Hamish Walke: Fine. My final point is that we have not received financial support from outside—from central government or anywhere else—to address that. I think the nutrient neutrality authorities have all received a £100,000 contribution towards dealing with that, but the authorities affected by water neutrality have received nothing. So this certainly has been a drain on local government resources.
David Lowe: I will answer in reverse order. On whether we have sufficient expertise, Warwickshire County Council is fortunate to have 16 ecologists—which is 16 more than most local authorities—so we do have sufficient expertise on the ecology side, covering mammals and particular species through to habitats. We have service level agreements with the districts and boroughs, so we work, noting previous session, very closely with our districts and boroughs. We have a great deal of trust in giving ecological expertise, which we have been doing in some other local authorities—in Stratford, for example—since 1997. We have built a great working relationship with our districts and boroughs.
Do we read everything? Yes, we do, because humans are very good at interpreting lots of strategies. We read them all through, and we have written some ourselves for districts and boroughs.
The Chair: Do you have a very brief supplementary?
Lord Mawson: I am just checking about reading everything. In the levelling-up debate this week in this House, one colleague pointed out that one of the EU policies on the environment was 146,000 pieces of paper. The question is: are people really reading this amount of information?
Hamish Walke: I am not sure you would expect to receive quite that level of information on an individual planning application, however big it was.
Lord Mawson: No, but in the processes of the EU, in some of the legislation that has been coming down to us, that is the quantum of information we are meant to be absorbing.
The Chair: I do not think we are going to get an answer on that in particular. Lord Berkeley has a question for Mr Walke about water neutrality specifically.
Q44 Lord Berkeley: Thank you, Chair. You have answered some questions on water neutrality, but can you explain for the benefit of the committee what the problem is? I know that it is particularly important for your area, but what is the problem? More importantly, what solutions are available? Who can enforce them? Are you getting sufficient support from central government?
The Chair: I think we got the answer to that.
Lord Berkeley: We did, but the first question is the important one.
The Chair: It is, yes.
Hamish Walke: Can I begin by giving you the agreed definition of water neutrality? The definition is: “For every new development, total water use in the region after the development must be equal to or less than the total water use in the region before the new development.” For example, any proposed new house is obviously going to involve some water consumption by its occupants, but that additional water consumption needs to be off-set somewhere else. That could be through retrofitting devices in existing buildings elsewhere to reduce their consumption; there are other measures that you can achieve it by. The other key thing is that it is important to make sure that the new house is as water efficient as it can be so that the additional consumption, which you then have to off-set, is limited.
I will give you a bit of the background to this. This issue arose through the local planning processes for the five affected authorities. Natural England’s advice at the time was that it should be dealt with in a strategic, co-ordinated way through the local plans by developing a strategy to address it. I think that was initially back in early 2020. That work was progressing; the five authorities were working together on their local plans and on the water neutrality strategy.
The current situation, where there is a problem in delivering development, arose around a year later, in September 2021, when we received a position statement from Natural England saying that all new development needed to be water neutral. That then affected planning applications, so rather than Natural England working with us to deliver a policy-based strategy, we had to ensure that all planning applications were water neutral.
As I said, that was the first time that had happened in the country, so at the start we simply did not know what to do and there was quite a lot of head-scratching. Initially, it meant that we did not issue any planning permissions at all for about two months. What we were able to do after that period was to screen out small-scale things such as house extensions and minor developments. They were then able to proceed on the basis that they did not increase overall water consumption. The tricky part is dealing with bigger developments, even from a house upwards. That has taken a considerable period of time.
There are now various things progressing. The water neutrality strategy is progressing, with support from Natural England, Southern Water and various other organisations. In Crawley, we have started retrofitting the council’s own housing stock. We are fitting devices to reduce consumption within those houses, thereby effectively creating a bank of water through which we can help developers to off-set their new developments. That is the goal: to come up with those sorts of schemes that can enable development to take place. The five affected authorities are working closely on that.
Since September 2021, in Crawley we have been able to approve only one house. Normally, we would approve probably 300 or 400 houses in that kind of period. We have now got to the stage where we are about to issue permission for about 200 houses and flats in Crawley because of this retrofitting scheme within the council housing stock.
So the situation has moved on quite positively, and within Crawley we are now able to deal with this. The other affected authorities are not quite in the same position because they do not control their own housing stock, so they do not have the immediate ability to tackle that. They are perhaps a little way behind on that.
Lord Berkeley: Is there any ability to encourage private sector housing stock to make the changes?
Hamish Walke: That is the other thing: there are other ways to do this. You can look at commercial buildings. It is probably best done at scale. In terms of planning applications, it is very difficult to deal with individual householders, but if you can do it at scale, that is certainly another way forward.
Lord Berkeley: Who pays?
Hamish Walke: The way that the systems work in Crawley is that the council delivers the savings—it is beginning to do that up front—and will then claim that cost back from the developer, probably through Section 106 agreements.
The cost of delivering water neutrality is not that high. Obviously, any cost on the developer is unfortunate, but for one house you are looking at perhaps only a few hundred pounds to off-set it elsewhere. It is not a huge impact. For most of the developers who are in the queue of applications waiting to come forward, when we give them an idea of the likely cost, they do not throw their hands up and say, “We can’t do this”. They want to get on with the developments. We have found that solution, and there are a whole range of other things in the longer term that we can perhaps come on to later.
The Chair: Going back, the root of the problem is specific to the Crawley area, is it not? Can you explain why there is a shortage? There are presumably lots of parts of the country where water is abundant and so this should not be an issue. It is not a general principle of planning that new developments should not consume water.
Hamish Walke: The south-east of England is an area of water stress, so all the affected authorities and other authorities have policies in their local plans to use the optional level in the building regulations to reduce water use. There is a higher level of 125 litres per person per day; all the affected authorities have reduced that to 110 litres per person per day in new houses.
The problem has arisen because of an abstraction point where Southern Water takes out the water to serve what is known as the Sussex North Water Resource Zone. The abstraction point is a long way from Crawley; it is down on the south coast, near Pulborough. The abstraction serves most, if not all, of Horsham district, a large part of Crawley and parts of Chichester. The South Downs National Park and West Sussex are the other affected authorities.
The problem is that Natural England fears that the amount of water being abstracted is leading to some protected wetland habitats—they are used by waterfowl and migrating birds, and there are species there that are endangered or threatened—effectively drying out because of the amount of water being taken out. The whole idea is that by not increasing the overall consumption, you are not increasing the abstraction from that point in Pulborough.
Q45 The Chair: On Natural England’s authority in this respect, it describes itself as an advisory body. What is its legal authority for the moratorium it imposed on you?
Hamish Walke: I guess it is an advisory authority. Crawley Borough Council and the other authorities are the competent authorities under the habitats regulations to deal with the issue, so we have to take the final decision on whether a development is acceptable and whether it is demonstrating water neutrality. Obviously, we take Natural England’s advice generally as an expert on ecological issues.
The Chair: But you clearly did more than that. You were developing a policy to deal with this, and when you got a purely advisory note from Natural England, all of a sudden you started imposing a moratorium on applications. It is not just that you take its advice but you make the decisions. It looks like complete compliance with what it says—that Natural England is making the decisions.
Hamish Walke: There is an area of, not conflict—but Natural England is the expert in this field. It has the people who have done the survey work in the affected area.
The Chair: But let us be clear, because we are going to see Natural England later, and it will claim that this was your decision.
Hamish Walke: Yes, it is our decision, because we—
The Chair: So, to be clear: it was your decision, which you did not have to take, to introduce this moratorium to give up a plan-based and policy-based approach and switch over to an applications-based moratorium.
Hamish Walke: I do not accept that that is what we have done.
The Chair: Well, that is how you described it—for two months you issued no planning applications.
Hamish Walke: Yes, but I do not think that that was an abandonment of the local planning process.
The Chair: Sorry, I agree; you did not abandon it. Forgive me—of course you did not say that you abandoned writing a policy while you were doing it, but you introduced a moratorium. That was the decision of the executive of your council, presumably.
Hamish Walke: I would not say that we introduced a moratorium. What we said is that a development needs to demonstrate that it is water neutral in order to proceed. That is still the case now. Effectively, there is no ban on development, but that development needs to demonstrate that it is water neutral. That is difficult to do.
The Chair: I am interested in accountability.
Hamish Walke: We are the accountable authority. Say we were to decide to grant planning permission, we are the authority that could be challenged should someone wish to challenge us.
The Chair: A decision to grant or not grant a planning application should be rooted in your local plan, which is consulted on. The fairly dramatic decision was taken not to grant any planning applications for two months—it has been alleviated somewhat subsequent to that, but initially it was for two months. Was that decision not to grant planning permissions rooted in your local plan, and had it been consulted on?
Hamish Walke: No, because we do not have a policy on water neutrality. Crawley is continuing to progress a new, emerging local plan, which will include a policy on water neutrality.
The Chair: So if a developer had simply challenged this and gone to the Planning Inspectorate, you would have had no documents to offer except an advisory note from Natural England.
Hamish Walke: We would have argued that the developer had not demonstrated water neutrality.
The Chair: But you had no basis for requiring water neutrality.
Hamish Walke: We did, because developers needed to comply with the habitats regulations. That is the reason for it. It is not a local plan issue; it is a habitats regulations issue. They could not comply with the habitats regulations without demonstrating water neutrality. I think all the developers lost in the appeals that did go ahead, both in our borough and in the other affected districts, on water neutrality grounds because of the habitats regulations.
The Chair: I interrupted Lord Berkeley, and I want to make sure that we can move on.
Lord Berkeley: I think we have covered my question, Chair.
The Chair: I think we have—thank you. I come to Lady Eaton.
Q46 Baroness Eaton: I rather think that Lord Berkeley kindly asked the question for me about the challenges in achieving water neutrality in your area and the solutions. You have explained quite a lot about that, but can you tell us what your relationship is with the local water company and, if it is important, why? What role has it played in your policy development?
Hamish Walke: It would be fair to say that we initially had quite a difficult relationship with Southern Water. This is the one area where we have, I guess, a lack of control. It has its own water resource management plans that it needs to produce. We do not have any direct control over its actions. We initially found it quite difficult to get information from Southern Water in both preparing the local plan and even getting a map of the affected water resource zone. It took around a year to get a finalised map. That was difficult, because not the whole of Crawley is affected by this issue, so we did not know which parts of it were affected and which were not.
To be fair to Southern Water, part of that was because it was working to rezone parts of Crawley so that they were taken out of the water resource zone and the issue did not then apply. So there were some benefits to it, but there was a lengthy period of time before we had a definitive map that showed the affected area within Crawley. Relations certainly have improved since then. There has been engagement at chief executive level and at officer level to work more closely with Southern Water.
One of the problems we face in the longer term is that the emerging local planning strategy requires significant works by Southern Water to find alternative means of delivering water, rather than through abstraction from the Pulborough area. They are not going to come on stream very quickly; 2025 is the earliest that Southern Water will be contributing to the water neutrality strategy. The more significant infrastructure improvements will be later than that, in around 2027 or 2028. They are some time off.
On delivery of development, the retrofitting programme and things like that in Crawley homes will take up the shortfall and enable things to happen in the short term. But there is a fear that if Southern Water does not deliver by 2027-28, we will effectively come back to this hiatus and ask how we can issue permissions when the infrastructure has not been improved.
Baroness Eaton: What are you going to do? Do you have plans—a plan B, if you like?
Hamish Walke: Not that far ahead yet, no. Crawley has 5,500 homes that can be retrofitted, so we could—and are planning to—do all of those, but that will not solve the whole problem, so further things will have to happen. You can look at things such as leisure centres and golf courses, which use quite a lot of water. As I said, Horsham has quite a number of bore-hole applications, with people trying to find alternative sources of water. There are various ways in which this can be addressed, but we are heavily reliant on Southern Water delivering what its new draft plan says it will.
Q47 Lord Faulkner of Worcester: My question, for David Lowe, is simple: what do you understand by biodiversity net gain? Do you feel that your council has adapted to meet the requirement that it implies?
David Lowe: We started off calling biodiversity net gain “biodiversity off-setting”, so excuse me if I get the terminology wrong here and there. To put it into basics, you measure the biodiversity value of the habitats you have on a development site and then measure that post development. You minus one from the other, and you get either a gain or a residual loss. You can deliver biodiversity net gain either more on-site, depending on what habitats you have on-site in the first place, or off-site. In essence, the calculation for a development site is to measure the biodiversity value of the habitats before and after, which gives you a gain or a loss.
On your second question about how we have adapted to meet the requirements, we were in a pilot in 2012 and 2014. We built the Defra metric as it is now—or 90% of it—is Warwickshire’s. Defra adopted our metric. We had lots of barriers to get over in that sense, but we were a pilot. We tested it out. We made what you could call some howlers in the first few years, but we persevered with it through the planning system and pretty much made it pseudo-mandatory in 2012 and 2014, and we have been pursuing biodiversity net gain ever since.
Lord Faulkner of Worcester: You have quite a lot of the High Speed 2 rail line going through your county. Did that pose a particular challenge for you?
David Lowe: Yes.
Lord Faulkner of Worcester: Can you say more?
David Lowe: The last time I was at a Select Committee was the HS2 Select Committee in the Commons in October 2014, and I am still shaking after that one.
Basically, HS2 has produced a challenge, but there is a hybrid Bill, so we are in negotiations about what the no net biodiversity loss and biodiversity net gain aspirations are or will be. I am actually advising Natural England on its ability to produce biodiversity net gain at this time. HS2 is a challenge, yes.
Lord Faulkner of Worcester: What impact did the pilot have on meeting your new housing targets?
David Lowe: We had very little kickback from the developers’ side—they actually like the certainty. I presented to a Natural England and Defra working group in about 2014, and I was surprised to hear that the development industry was for biodiversity net gain. For that purpose; it delivered ‘certainty’. Developers knew why they were doing it and how to do it. it provided a metrics system. In Warwickshire we showed that it actually worked, and it reduced ecological negotiations, shall we say, within a planning application. I call it a framework for discussion. It enables people to have a dialogue on minus 28 of a planning system, before the planning application is submitted, so it actually aids the process.
Lord Faulkner of Worcester: So you reckon you are in a pretty good place on this?
David Lowe: Yes. We have been doing it for 10 years, so we are pretty good at it.
The Chair: Putting the other case, if biodiversity net gain is achieved through off-site provision, is it not just a case of developers paying farmers in some distant part of the country to encourage the butterflies, at the expense of putting extra costs on to house development when we need homes for people? I am not saying that is my view; it is something that people might ask.
David Lowe: And it was asked in 2013-14. There were discussions on licence to trash—are you able to just buy your permission, in a sense, by off-setting with butterflies elsewhere in a county or in the country? The point is that the National Planning Policy Framework has a mitigation hierarchy that you have to follow, so you have to try to avoid first, then mitigate, and then compensate as the final option. It is the final mechanism you have to deliver a biodiversity net gain from your development.
In that sense, what the biodiversity off-setting metrics did, and do, is to demonstrate that you have delivered that mitigation hierarchy. There is no licence to trash: you come up with how you are going to build a development in a sustainable manner almost on day 1. You are considering it up front. In Warwickshire, Coventry and Solihull, I think Stratford-on-Avon District Council got more planning applications last year than any other district. Therefore, it has not slowed housebuilding in Warwickshire.
Lord Mawson: Do you have any understanding of how that might play into—
The Chair: Sorry, but I was going to switch to something else. I wanted to ask about value—
Lord Mawson: What is the point in being here if you cannot ask questions?
The Chair: You can ask questions, if you let me call the people who are asking questions—there are others ahead of you now. David, you talked earlier about the value of biodiversity. How do you measure value? Is it simply the number of species?
David Lowe: The species are kept separate; this is a habitat value. An arable field has a low value, but a species-rich grassland has a higher one. It is based on what are called distinctiveness values. You also have condition values—is the grassland, for example, in poor, medium or good condition?
The Chair: I see—so it is not actually what is living on the land that you count.
David Lowe: No—it is the habitat value.
The Chair: It is the habitat; I understand. Very quickly, let us deal with Lord Mawson’s question—we have to get to Lord Greenhalgh, Lady Cohen and Lord Best.
Q48 Lord Mawson: It was just on whether you have made any comparisons of what happens with the quality of the built environment or the development when money is invested in this. There is only so much money in the pot, so have you looked at what the implications are for the quality of the buildings that are then built?
David Lowe: Local plans have separate policies. They have to conform to the build quality. The biodiversity value just meets that part of that policy for a local plan.
Lord Mawson: Are there any comparisons or connections laterally in how one thing affects another?
David Lowe: I am sure there will be—that would probably be a question for the House Builders Association to answer.
Lord Mawson: But you do not know.
David Lowe: In our case, I have found that Defra and Natural England policy is to deliver as much biodiversity net gain on-site as possible. I work on the principle that it depends on what habitat you have in the first place. If you have a lot of arable land or low-value habitat and you fulfil your public open space strategies, you can actually fulfil a lot of biodiversity net gain on your open space, so your social justice is built into that design. You could also have your green roofs, possibly. All these aspects can be built on so that your policies are all met.
Planting more houses, as I call it, on a site may mean that you pay more for biodiversity net gain. But if you are starting with a low habitat base, you can actually maximise your profits as well as maximising putting the right biodiversity in the right place elsewhere in the county—not elsewhere in the country, to go back to the previous question. Ideally, the biodiversity is placed in a strategic area within the borough. It is about putting the right habitat in the right place to deliver your local nature recovery strategy or your green infrastructure strategy. It is a good tool in planning, and that is why developers like it. They can see how their development actually increases biodiversity in a local area as well.
Q49 Lord Greenhalgh: I will pick up two things that have come out in this evidence. First, I was struck by the muscle that Warwickshire County Council has in ecology. Having 16 ecologists is pretty impressive, really—it is like an army of ecologists.
Another thing you said was “ecological negotiations”, which indicates a lot of toing and froing between the person who has made the application and a flotilla of advisers. My question to you both is about what impact all this policy intent around biodiversity net gain and water neutrality has had on the cost of planning from the point of view of the applicant. Obviously, that is a material thing that influences whether they want to proceed.
David Lowe: On the biodiversity net gain element, I have been doing planning applications since 1991, at Derbyshire Wildlife Trust, so I have seen a lot of legislation come through in its different forms. That is a separate question.
In those days, as you rightly said, biodiversity used to be a matter of, “Do we have to consider it? Yes. Let’s do a report”—and they would do a report, but we often found that developers did not read that report. They just handed it in because it was necessary for planning. That is where we had a lot of kickback in the early years—“Oh no, we’ve suddenly found a newt in a bucket”, as people used to say, or they had found a rare habitat. But if you do your homework at the beginning, we often have those discussions at minus 28 of a planning application process—before it gets submitted—so you have dealt with all your ecological issues, sometimes a year or two before a planning application comes forward, and you are less likely to suddenly find that you have an SSSI in your railway station.
Lord Greenhalgh: The impact then is on speed, because what you are describing is years to application.
David Lowe: Yes.
Lord Greenhalgh: One thing that struck me when I was a local authority leader—Baroness Eaton will remember this—was the length of time from having a plan you all understand to getting it through the planning application process. It is more than the life cycle of most leaders of most councils, and that is why you guys are always in charge, frankly. I did six years, so some of the major schemes that I started on day 1 had not been finished by the time I left. That is appalling. No one is denying the cost, but there is also the sheer amount of time associated with this. Is there not a simpler system to achieve these policy objectives without this delay, delay, delay?
David Lowe: I suggest that it does do that, and it has been proven to do that. Because we have those discussions very early on, we deal with biodiversity pretty much before it gets to the planning application stage and something is submitted. Through the pre-application advice that we offer, for example, we can set those habitat values, so they know which are the important bits and which ones they need to avoid; they know their areas of constraint, as it is generally termed; they know, therefore, the area they can build upon; and they can start with that knowledge on day 1. What happened in the past was that they realised how much value they had only on day 28, maybe, once the application had been submitted, and it would therefore be withdrawn and resubmitted—and so the years go by. But you can now project manage from day 1; that is what this has done. It gives that framework—
Lord Greenhalgh: Understood—it front-loads the problem so that you deal with it up front.
David Lowe: It front-loads not only problems; “problems” sounds like there is something wrong. I would say “concerns”—
The Chair: I am keen that we should finish at 12.30, so I will move on to Lady Cohen of Pimlico, who is joining us remotely.
Baroness Cohen of Pimlico: I will skip my question, which has been answered in various ways by various people.
The Chair: That is very generous of you.
Q50 Lord Best: I am not going to sacrifice mine. We are trying to end up with some solutions to the problems that people clearly face. Prefacing the problems before tackling the solutions, we have not said much in this session about nutrient neutrality.
The Chair: That is not their expertise or why they have been called.
Lord Best: It is not their special expertise, but this is a new kid on the block that is causing a lot of havoc. Do either of you have any comments on the way in which that is now playing out—the need for nutrient neutrality leading to a moratorium on activity in some areas?
Hamish Walke: I cannot comment on that, but the critical point is that all these issues tend to affect a very focused geographical area. Crawley is affected by water neutrality but not by nutrient neutrality. In Crawley, it is not an issue.
Lord Greenhalgh: Can I declare my interests?
The Chair: You did last time.
David Lowe: North Warwickshire has a very small area affected by nutrient neutrality, so it has been hit by this. However, because it is in the Mease special area of conservation European site, it goes back in a similar sort of way to water extraction, et cetera. If there is a causal link—
The Chair: Which site is that?
David Lowe: The River Mease, which is a SAC—special area of conservation—site. Therefore, if any development in North Warwickshire impacts directly or indirectly on that European site, the developer needs to ensure that there is neutrality. However, I have done the habitats regulations assessment of minerals plan, so I know where the area of influence is in Warwickshire and the tributaries that could flow into the Mease. It is only a very small part, so this does not really affect Warwickshire much.
What we are doing in Warwickshire is looking at natural capital solutions and nature-based solutions generally. For example, the biodiversity gain of a pond or watercourse could help alleviate an impact—something like reducing the amount of water, in the case of water neutrality. We could look at sharing those ecosystem services so that you could get gains from biodiversity or nutrient neutrality. Therefore, habitat creation could help you resolve any moratorium, as it would be, on development. Those nature-based solutions could help speed these applications forward.
Lord Best: That is really helpful. I wanted to make sure that we have not overlooked any potential solutions to the problems that are outstanding.
The Chair: I do not think Mr Lowe is agreeing that there is a problem—I think he regards himself as the solution.
Lord Best: Do you have any final thoughts on recommendations we should be making to make a difference? That would be really helpful.
David Lowe: My final comment is about nature-based solutions as a way to front-load. On natural capital investment, if you start loading up habitat biodiversity in the right place, it can help with flood alleviation, nutrient neutrality, biodiversity net gain, carbon from trees, soil carbon, et cetera. It is about the development of those codes, so that everyone knows the playing field. If you front-load that into the system, you have built up a bank, as it were, for any issues or problems—whatever you wish to call them—so that they can be sorted. I would say the same thing for species such as great crested newts or bats: it is about front-loading stuff and thinking about a forward strategy. Local nature recovery strategies could help that outcome.
The Chair: Thank you both very much indeed. That brings our evidence session to an end. We are very grateful.
