Dr John Martin (University of Plymouth)                            ESH0089

Supplmentary written evidence submitted by Dr John Martin, Associate Professor, School of Geography, Earth and Environmental Sciences, University of Plymouth

Environmental Audit Committee - Environmental Sustainability and Housing Growth - Evidence related to Protected Landscapes

Protected landscapes can play an important role in environmental sustainability and housing growth. The following points highlight ways in which protected landscapes can support housing growth:

• Evidence suggests that Protected Landscapes (National Landscapes and National Parks) are not anti-development, but their reason for being is to conserve and enhance natural beauty, and therefore only want to champion the best development for the long-term.  
• A strategic approach, which also includes local, bottom-up decision-making will be the most constructive way forward – risk-based and sensitivity mapping approaches should be part of this, as should the government’s land-use framework. The Protected Landscape teams are valuable convenors in the landscape, enabling solutions that bridge local decision-making and national priorities.  The Protected Landscape (PL) Matrix management, PL lateral and vertical partner links including Wildlife Trusts, Local Nature Partnerships (LNPs), Local Environment Record Centres (LERCs), other NGOs, and Local Authorities will play a key role. Also see Evidence summary document: Evidence_Summary_LANDSCAPE_MONITORING_Martin_Guy_and_John_Martin.pdf
• The National Landscapes teams are generally hosted by a local authority but work with all the LAs inside their designated boundary. One of the challenges in balancing environmental sustainability and housebuilding growth, is that the NLs do not have statutory consultee status, and there is no formal procedure that Local Planning Authorities use to consult the teams, or to take into account natural beauty. Consultation between NL teams and LPAs varies greatly; when it occurs at all, it often happens too late to make a meaningful impact. As a result, developments may be insensitive to natural beauty and environmental sustainability.
• The Protected Landscapes duty (Levelling up and Regeneration Act 2023), if implemented strongly, has big potential to galvanise the public bodies in a landscape to deliver more for nature, in the course of delivering their functions. The secondary legislation has started to be drafted by government. Making these regulations strong and substantial, and creating an adequate monitoring and compliance regime will be important to balance environmental sustainability and housing growth. Strongly implement the duty to ‘seek to further the purposes’, through secondary legislation, government guidance and sector-specific advice. Use the duty to align decision-making and investment, achieving greater momentum and coherence for national, legally binding objectives and targets.
• BNG is one of the main tools LPAs use to balance housebuilding and nature, but the mechanism of BNG focuses the majority of attention on the mitigate/compensate steps – without giving enough attention or the tools to avoid harm in the first place (in the mitigation hierarchy). This is why implementing a strategic framework approach is so important.
• National Landscapes teams in LAs are not currently resourced to provide or process the data required to produce environmental sustainability or deliver against their purposes. Often, the data used by government are those that already exist, rather than the data that would measure the right thing. Some existing data are also inaccessible (e.g. paywalls), and the small NL teams tasked with stewarding natural beauty of Protected Landscapes do not have the staff capacity to do any monitoring or processing of the data that do exist. A review of resourcing which could a link to BNG and house building targets is required. Also see Evidence summary document: Evidence_Summary_LANDSCAPE_MONITORING_Martin_Guy_and_John_Martin.pdf
• Natural beauty is not only about visual beauty – it has many of the same, varied components as environmental sustainability, and is similarly holistic. LVIAs are not sufficient to judge impact on natural beauty – better assessments that capture impact on natural beauty are needed to be embedded in the planning decision-making process.  

March 2025