Call for Evidence: Environmental sustainability and housing growth

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.

The UK Green Building Council represents the voice of the UK’s sustainable built environment industry. It is a charity powered by more than 700 members from banks, large estate owners, housebuilders, and manufacturers to innovative startups, universities, local councils and government departments - all working to transform the built environment in the face of the climate, nature and cost-of-living crises.

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?

Prioritising previously developed land is welcome as a general approach. To avoid urban sprawl and protect the Green Belt, the Government needs to prioritise building more densely and concentrate development as much as possible on brownfield sites in existing urban areas.

However, many brownfield sites have developed into biodiverse urban habitats that provide greenery that can be enjoyed by local communities for recreation. They can also be important areas to boost resilience to climate change by providing permeable surfaces to combat flooding and heat waves. Therefore, while brownfield sites should be developed as a priority, these should be assessed by the local planning authority and, if appropriate, require an ecological assessment.

Local plans should deliver an overall net biodiversity gain and decisively increase the proportion of green and absorbent surfaces in an area.

To ensure the protection of the areas of the Green Belt that are high value areas of nature, it is vital that ‘grey belt’ land is more clearly defined. Green belt should continue to be protected from new development and only released under grey belt designation as a last resort after ‘shovel-ready’ brownfield sites have been prioritised.

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?

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?

The presumption in favour of sustainable development should be amended as proposed and clear guidelines on when the presumption applies are useful. However, the lack of explicit direction on the weight of each factor may lead to ongoing disputes in planning decisions, especially in subjective areas like the impact on key landscapes. This could delay approvals and development. Providing detailed guidance is essential to ensure that development is genuinely sustainable and to prevent inappropriate construction in unsuitable locations.

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?

We must ensure that every home is fit for a sustainable, resilient future. Crucially, development and communities must be strategically located close to public transport, and walkable and cyclable distances, to key facilities, or have the correct provisions for electric vehicle charging nearby. Simply approving homes without regard for their location, will lock in more unnecessary emissions and exacerbate social and economic deprivation and isolation. Sites should be located close to existing social infrastructure, or ensure that it is integral to the development’s design. Neighbourhood design should promote active travel via safe routes to everyday facilities, including schools and local shops selling healthy food options influenced by local healthy menu schemes, and provides spaces and places for community.

Whilst the government is correct to prioritise a brownfield-first approach, which has the potential to deliver 1.2 million homes, instead of setting housing targets that encourage speculative development, we need ambitious standards for brownfield sites, increasing the number of homes for social rent, and ensuring genuinely sustainable and affordable housing. Local plans should reflect communities’ goals for climate change, nature recovery and community energy.

We support the removal of the explicit requirement for 10% of housing on major sites to be ‘affordable home ownership’ as this can be a barrier to the provision of more social rented accommodation and other much-needed tenures of significant social value. Promoting developments that have a mix of tenures and types is important for social inclusion, layering of different purchase and rental opportunities for life stages, and positive health outcomes.

To deliver more social benefits, social value could be incorporated into planning, as it currently is for procurement, helping local authorities achieve their strategic goals by enhancing community strength, health outcomes, and local economies.

Introducing higher environmental and social standards for new developments is a huge opportunity for skilled, quality jobs in every part of the country and for the sustainable built environment sector. Higher standards will drive innovation and the development of skills and supply chain solutions, which in turn brings down costs and makes faster progress towards meeting climate targets.

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?

Associated planning guidance should be developed to ensure upwards extensions support progress to the UK’s net zero target, including matters such as lifecycle carbon emissions, embodied carbon, sustainable energy, passive cooling and low carbon heating to avoid future retrofitting and to support the UK’s legally binding climate targets.

Complementary changes should be made to Permitted Development Rights to support high quality retrofit of existing buildings to mitigate embodied carbon emissions.

Will the Government's proposals affect the ability of local authorities to implement policies designed to protect the natural environment in their areas?

There are areas where Green Belt land plays a critical role in maintaining local charavyer and preventing high-carbon urban sprawl. A clearer definition of grey belt is therefore vital to ensure the protection of the parts of the Green Belt that are high value areas of nature and play a significant role in reversing our declining biodiversity, storing carbon, producing food and allowing people to access nature.

We are concerned by the limited power proposed for local authorities to refuse plannning permission on non-grey parts of the Green Belt. Additional guidance should be included in the NPPF itself. Local authorities must be able to justify denying development on Green Belt land, which will create ‘adverse impacts’ such as biodiversity depletion, the release of sequestered carbon, and increased climate risk, just as they can now do on the grounds of transport links, design, and affordable housing policies.

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?

How will the revised NPPF operate to promote the Nature Recovery Network and the implementation of local nature recovery strategies by responsible authorities?

Local Nature Recovery Strategies (LNRS) should enhance Green Belt and be prioritised above development to further protect Green Belt land from development and grey belt designation. We recommend making LNRS mandatory in local plans and introducing a new planning designation to protect land designated for nature recovery. This would safeguard areas identified for habitat restoration from land use changes that could hinder nature recovery while allowing sustainable land uses to continue.

In addition, we recommend national policy strengthens smaller-scale nature interventions, which would enhance local nature recovery and act to enhance local areas. The NPPF should set the strategic position for these interventions across Green Belt, Brownfield and Grey Belt categories:

Enhance Policy Requirements: Create more stringent planning policy requirements that mandate small-scale, no-regrets nature enhancement measures to be integrated into the design of proposals in response to local ecological needs as an absolute minimum. This would include the integration of features like bee and swift bricks, hedgehog highways, and bat boxes into new developments. Such measures are necessary for aligning development practices with the goals of the Environment Act and the Environmental Improvement Plan
Promote Holistic Outcome-Based Approaches: Establish national policies that require the realisation of the broader environmental benefits of nature interventions, such as air pollution reduction and urban cooling. This would go beyond biodiversity net gain and encompass overall environmental benefits
Implement Urban Greening Factors (UGFs): Require local planning authorities to adopt urban greening factors that enhance access to nature. UGFs should be used to quantify and deliver green infrastructure requirements, providing flexibility for local adaptation while ensuring consistency across developments

By implementing these measures, national policy can better support local nature recovery strategies and other nature recovery interventions that can contribute to the Nature Recovery Network.

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?

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?

December 2024