The Wildlife Trusts                            ESH0086

Additional written evidence submitted by The Wildlife Trusts

Environmental Audit Committee Inquiry: Environmental Sustainability and Housing Growth

Additional evidence submitted on 31 January 2025.

1. What are the environmental impacts of a shift to a strategic, more regional approach to nature protection rather than a site-specific approach?

In some specific circumstances, a shift to a more strategic approach to the mitigation of specific environmental impacts could improve outcomes for nature by better enabling more, bigger, better and joined up nature recovery actions to go ahead.

We have already seen the benefits of a more strategic approach to nutrient pollution mitigation, and significant progress has been made in recent years to improve processes.[1] For example, the Wildlife Trusts report, Swift and Wild,[2] highlighted how Dorset Wildlife Trust’s 420-acre Wild Woodbury site was purchased with support of grants from Bournemouth, Christchurch & Poole Council and Dorset Council, to mitigate the impacts of nitrate pollution from the development of over 2,000 homes. In the three years since taking on the site, over 1,900 species have been recorded using the site, including 29 Red List birds of conservation concern.

However, strategic mitigation will not be appropriate for every environmental requirement and an evidence-based approach must be taken.

We have significant concerns that a shift to a strategic approach – in particular the removal of project-level environmental assessment - could undermine the mitigation hierarchy. The mitigation hierarchy requires harm to be avoided in the first instance. The proposal may also remove incentives to integrate nature-friendly design measures in the development itself to reduce impact. For example, the nutrient neutrality calculator, which is currently used to determine requirements, has been developed by experts in Natural England and enables site-level impacts to be evaluated in a consistent way.[3] It reflects the site level impacts of the development by incorporating the proposed land use change and the design of development and if it has integrated Sustainable Urban Drainage Schemes (SUDS). The removal of this calculator and replacement with a schedule could reduce incentive to avoid building on key habitats or design development that integrates SUDS.

More broadly, MHCLG and Defra have not presented evidence behind their claims that existing nature protections slow down development. Very few planning applications, for example are captured by legislation protecting our great crested newts.[4] A 2012 Review of the Habitats Directive found “It was clear from the wide range of evidence and views submitted in the course of the Review that in the large majority of cases the implementation of the Directives is working well, allowing both development of key infrastructure and ensuring that a high level of environmental protection is maintained.”[5]

The lack of resourcing has consistently been highlighted as a root cause of problems in the planning and development system, including in the 2012 Review of the Habitats Directive and more recently by the Office for Environmental Protection.[6] Without investing in data and staff capacity and capabilities in Natural England and in Local Planning Authorities, the proposed approach will not work for nature. In a recently published survey by MHCLG, the most cited planning skills gap in LPAs is in ecology and biodiversity.[7]

We would like to see the EAC make several recommendations to the UK Government following the publication of the Working Paper:

• To undertake a review of existing strategic approaches – including district level licencing, the provision of suitable alternative natural greenspace and nutrient mitigation – to ensure lessons are learnt.
• To ensure the mitigation hierarchy underpins the development of the proposal.
• To ensure non-regression of existing legal protections by allowing full scrutiny and debate of any changes to the Habitats Regulations through the Planning and Infrastructure Bill.
• To underpin any changes with scientific evidence, to provide confidence that impacts are appropriately assessed, and the strategic mitigation measures will support the conservation of the protected sites or species in question. Any evidence should be made publicly available.
• To build trust in the system, by avoiding damaging rhetoric that undermines confidence that a new scheme will deliver genuine benefits for wildlife.

2. Can you point to an example—say in planning a neighbourhood, so at neighbourhood level rather than individual property level—an example of something actively delivering better outcomes for nature, the environment and carbon?

The Wildlife Trust report Swift and wild includes description of Goldsmith Street and Kidbrooke Village – both developments have sought to integrate nature into the development.

In addition, Trumpington Meadows, shows the value of local leadership, community engagement and considering nature from the start. Trumpington Meadows was part of a larger strategic allocation of new homes on the southern fringe of Cambridge with the Clay Farm urban extension. Together these two developments have delivered over 3,700 new homes.

At the same time as the land was allocated for development, the local councils (Cambridge City and South Cambridgeshire District) set a framework for development that required the provision of strategic green infrastructure, with green corridors connecting the centre of Cambridge through the new developments to the countryside beyond. This was partly in response to the loss of Green Belt land to make way for this southern expansion of Cambridge, alongside the building on a brownfield site of low nature value.

Trumpington Meadows Land Company wanted to create a high-quality development with its own character and sense of place and viewed a new “country park” as integral to this. It carried out extensive consultation with local communities and stakeholders prior to submitting the planning application, resulting in relatively few objections when the planning application was submitted. The Wildlife Trust for Bedfordshire, Cambridgeshire & Northamptonshire was selected as the organisation to manage the “country park” and engaged along with the landscape architect to design and create the development’s green infrastructure and to help secure better outcomes for wildlife while avoiding future management problems.

Local play areas, swales and tree avenues are included throughout the development. The 58-hectare country park and nature reserve is designed to be both a space for people and for nature. Its staged creation, which includes over 40 hectares of new species-rich meadows, hedgerows, woodlands and restored floodplain meadows, began prior to the building of the first houses to allow the landscaping and habitats time to mature in time for the local community to begin using them. An independent assessment has demonstrated a 43% net gain in biodiversity from the Trumpington Meadows development.

The country park and nature reserve was designed to follow the River Cam and include its floodplain as part of a continuous green corridor into the heart of the city. A river restoration scheme was developed by the local authority ecologist to improve the river habitat and re-connect the river with its floodplain meadows, providing a small reduction in flood-risk downstream. New houses were built away from the flood plain to reduce flood risk and the drainage system is engineered to include a balancing pond with overflow area and open ditch features, to keep runoff to the River Cam at pre-development levels and provide wildlife habitats.

January 2025