Benjamin Brace, Rachel Harris, Gloria Lo, Mina Samangooei, and Kat Scott                            SBE0115

Written evidence submitted by Benjamin Brace, Rachel Harris, Gloria Lo, Mina Samangooei, and Kat Scott

Ben Brace MCIHort CMLI is a Chartered Landscape Architect, Qualified Horticulturalist, volunteer Tree Warden, committee member of his Local Parks' "Friends of" Group and Associate Member of the Arboricultural Association.  He is also a Trustee Board Member for The Garden Classroom, a charity focussed on providing nature based experiences for children.  He has a specific interest in the successful integration of large and long lived trees into the built environment and currently works for the Royal Horticultural Society, project managing the delivery of their £130m Strategic Investment Program.

Rachel Harris is a Chartered Architect and Certified Passive House Designer, with well over a decade of professional practice experience in both the UK and Australia.  Rachel is an Architectural Tutor at the University of Sheffield and Manchester School of Architecture and is passionate about developing an ecological approach to design, both through teaching and in practice.

Gloria Lo is an Architect, Certified Passive House Designer, BREAM Accredited Professional, and Principal of OiSA Architects, with a wide range of experience. Her current PhD research at University of Strathclyde, part funded by Engineering the Future Scholarship and affiliated to University of Edinburgh, is cross-disciplinary between material science, soil physics and building physics, on sustainable retrofit methods using hygroscopic materials. She is a guest lecturer and studio tutor in various Universities on environmental design, circular economy, construction, health and well-being in built environment, BPE and POE monitoring, with technical expertise in conservation and sustainability.

Dr Mina Samangooei is a Senior Lecturer, Researcher at Oxford Brookes University and Architect at Sow Space.  She adopts an ecological, integrative and holistically sustainable approach to both teaching and practice, utilising energy efficient design and retrofit, including Enerphit.  She has worked closely with co-housing  and community led housing groups both as designer and design facilitator.  Mina’s research focuses on the role that food production in and on buildings plays for the future of cities.  Her PHD looked at behaviour theory in relation to people cultivating edible plants on buildings, which has been brought into practice through workshops and other live projects. 

Kat Scott is Sustainability and Regenerative Design Manager for dRMM Architects.  She sits on the Architects Declare UK steering group and also volunteers for the London Energy Transformation Initiative.  She is an expert on carbon and sustainability for the Design South East Oxford Design Review Panel and is a guest critic at the Bartlett School of Architecture and Nottingham University.


1               Introduction

1.1         We are individual members of the independent and voluntary Architects Climate Action Network: Where the Wild Things Aren’t (ACAN : WTWTA).  

1.2         ACAN’s three main aims to address the twin crises of climate and ecological breakdown are:

  1. Decarbonise Now:  We seek to radically transform the regulatory, economic and cultural landscape in which our built environment is made, operated and renewed in order to facilitate rapid decarbonisation of the built environment.
  2. Ecological Regeneration:  We advocate the immediate adoption of regenerative & ecological principles in order to green the built environment, prioritise communities and ecosystems at threat and promote the recovery and restoration of natural environments.
  3. Cultural Transformation:  We call for a complete remodelling of our professional culture. We must challenge and redefine the value systems at the heart of our industry and education system. We seek to create an open network to share resources and knowledge to aid in this transition.

1.3         WTWTA is a working and thematic group within ACAN, specifically focused on the challenges facing “wild things” in a time of critical biodiversity decline and habitat loss. We are working to raise awareness of the impacts of the architectural profession and wider construction industry on nature, and to support the vital shift towards a new form of professionalism dedicated to ecological regeneration. 

1.4         Towards these aims, we promote multidisciplinary knowledge sharing by collaborating with experts and professionals with a greater understanding and appreciation of natural systems. From these collaborations, we campaign for the betterment of wildlife and ecosystems, and seek to move away from damaging Anthropocentric practices.

1.5         This response on behalf of WTWTA looks to ensure that in reviewing the ‘sustainability of the built environment’, the Environmental Audit Committee, Climate Change Committee and ultimately the Government must equally consider BOTH the climate AND ecological crisis in the development of future legislation.  It is vital that Government policy should assess issues of embodied carbon within construction (whole life carbon), but must consider Biodiversity as an equal measurable target for all future development. We call for a focus on nature-based solutions to assist in the creation of a sustainable built environment that prioritises long term ecological value through recovery and regeneration of the whole instead of short term economic gain and reactionary solutions in part.

1.6         WTWTA and ACAN offer an invaluable network of experience and expertise and welcome further opportunity to collaborate and assist with future legislation development, for example as part of a relevant all-party parliamentary group (APPG).  We welcome any further correspondence on this issue.


Key areas of concern for WTWTA

2               How can materials be employed to reduce the carbon impact of new buildings, including efficient heating and cooling, and which materials are most effective at reducing embodied carbon?

2.1         We are concerned that, although important, construction materials are not evaluated purely on their whole life carbon credentials.  We need to also consider any impacts to nature and biodiversity when ranking the environmental impact of materials.  How does a material’s production affect ecosystems?  This may be through extraction or land clearance for growth and harvesting, water use or contamination when processing.  We must continue and strengthen our pursuit of robust traceability and responsible sourcing of all materials.

2.2         It should also be remembered that plants themselves should be considered as an important living material with great potential to improve the performance and quality of the built environment.  It is vital to implement and promote nature-based solutions (Austin et al, 2021) to enhance and promote carbon storage in combination with decarbonisation.  For example:

-          The careful and well orientated planting of deciduous trees adjacent to buildings can provide summer shading but allow winter solar gains, contributing to a reduction in operational carbon. 

-          Trees can reduce temperatures around them by providing shade and cooling through evaporation and transpiration processes and represent a vital tool in tackling the issues of urban heat islands and heat sinks, lessening the need for artificial cooling. However, it is the largest, longer lived species that offer the biggest benefits to the built environment. They require long term commitment, funding and maintenance to ensure they reach maturity. It is only then that they offer the greatest level of ecosystem services to the built environment.

-          Appropriately selected and placed plants can improve the performance of mechanical and electrical systems by creating cooler microclimates under photovoltaic panels or adjacent to air handling units. In certain cases reduce the load or even need for mechanical services.


3                What role can the planning system, permitted development and building regulations play in delivering a sustainable built environment? How can these policies incentivise developers to use low carbon materials and sustainable design?

3.1         The planning system must develop legislation that addresses biodiversity in parallel with whole life carbon to achieve a truly ‘sustainable’ built environment.

3.2         We must require all developers by mandatory and enforceable means, (not just incentives) to improve biodiversity in addition to considerations and targets concerning Whole Life Carbon.  Robust policy must protect existing biodiversity, ensure future gains and prevent biodiversity loss. Planning policies must be considered from the view point of creating a symbiotic relationship between humans, built environment and nature, without which the future of our species and many others would be compromised. Planning system ought to start from considerations for nature first and progress onto how any development may impact it, rather than development led.

3.3         Existing carbon-rich and biodiverse habitats need better protection in the planning system by closing loopholes that allow the destruction of woodlands, hedgerows, semi-natural grasslands, heathlands, wetlands, peatlands and saltmarshes for housing and infrastructure. (Austin et al, 2021: 6)

3.4         We welcome proposals in the upcoming Environment Bill that call for 10% biodiversity net gain in all future development, but must call for higher targets at this critical time.  We are concerned about the current delays for this important bill and possible dilution in delivery and enforceability across all development scales.  This legislation must be ingrained within the planning and regulatory system rather than supplementary to it.  Like embodied carbon, nature recovery and biodiversity must be the responsibility of all development, not just strategic projects.

3.5         We are wary of a shifting baseline syndrome that measures future success of biodiversity at a present time when decline is the fastest that it has been in human history (Dasgupta, 2021). We propose that through a model utilising incentives to encourage improvement far beyond the enforced minimum standard, we can avoid condemning ecologically deprived areas to remain so in the future.

3.6         We must voice our concerns toward short sighted planning reforms that promote build, build, build at the potential damaging expense of long term recovery of both climate and biodiversity.  Societal success can simply no longer be measured purely on short term economic gain.  Long term ecological and environmental impact should be the measure against which all potential development is assessed and the only important growth target within the delivery of our built environment should be that of our most precious asset: Nature.  Natural assets need to be taken as economic value to inform decision making at planning/national level as to whether built projects go ahead (Dasgupta, 2021).


4                How well is green infrastructure being incorporated into building design and developments to achieve climate resilience and other benefits?

4.1         ‘Green’ Infrastructure is a vital nature-based tool in the fight to improve both climate and ecological resilience.  We must empower local authorities and developers to be ambitious in their incorporation of green infrastructure by celebrating existing successes (eg. Grey to Green, Sheffield) that can quash often unsubstantiated concerns about maintenance and assign accountable, realistic, holistic value to project outcomes that help to offset upfront development costs and incentivise investment.  

4.2         Green Infrastructure, (specifically Green Roofs and Facades) and areas of more diverse planting are, all too often Value Engineered out of projects post planning when a main contractor is procured. Research undertaken by Sheffield University , from information gathered via the planning portal, found that just under a quarter of landscape projects are built to the approved plans and just over fifty percent of the proposed planting in these schemes was correctly installed. (Abel, Halloran and Watkins, 2019)

4.3         This indicates that whilst the intention is there to enable a more biodiverse and therefore robust landscape, what is finally planted is unlikely to support an increased ecological diversity. This leads to sterile landscapes where economic cost has ultimately sacrificed ecological value.  We need methods of robust enforcement to ensure that approved schemes are realised and account for growth in natural capital within our costs.


5                How should we take into account the use of materials to minimise carbon footprint, such as use of water harvesting from the roof, grey water circulation, porous surfaces for hardstanding, energy generation systems such as solar panels?

5.1         The continued celebration and promotion of nature-based solutions such as those listed are important within our continued discourse on ‘what is a sustainable built environment’.  We must consider localised energy generation, water retention and reuse, and carbon sequestration in terms of potential ecological benefits as well as atmospheric carbon reductions.  These solutions highlight progression towards a systems based approach and we must continue to learn from and adopt nature’s circular systems of no waste, and material/resource cycles.

5.2         It is important to highlight in the discussion of materials that minimise carbon footprint, that healthy soil is potentially our greatest ally for the sequestration of carbon and the fight to increase biodiversity.   We must remember the importance of soil when assessing and delivering development - to preserve and increase its abundance and health wherever possible, with porous hardstanding minimised and non-porous hard standing eliminated completely. The filtration effect of soil cannot be replicated by SUDS, which simply retards flash flood but has no actual benefit to the environment while soil captures micro particulates (which moisture of raindrop and clouds are formed around) as nutrients.

5.3         Biodiversity is the baseline for resilience, health and wellbeing. We as humans are made up of countless microorganisms and it is similarly the diversity of them that keeps us healthy.  We believe that like WTWTA, this enquiry must advocate for the immediate adoption of regenerative and ecological principles.  The construction industry must champion biodiversity as well as ‘low carbon building materials’ in order to create a symbiotic, mutually beneficial, and fundamentally connected relationship between the built environment and the natural world for both our health and survival.


6               Finally, to assist the Environmental Audit Committee in the development of this enquiry, we would like to highlight key publications (some of which have already been referenced) that we believe are extremely important in the development of innovative and necessary approaches to ‘sustainability’ and in the primary importance in nurturing the natural world through increasing biodiversity as a fundamental priority for the success of all future development:

May 2021


Abel, Halloran and Watkins, (2019) The best laid plans: exploring shortcomings in the planning system as a cause of urban ecosystem decline, UK. Available at (Accessed 10th May 2021)

Austin, W., Cohen, F., Coomes, D., Hanley, N., Lewis, S., Luque-Lora, R., Marchant, R., Naylor, L., Queirós, A. M., Savaresi, A., Seddon, N., Smith, A., Smith, P. and Wheeler, C. (2021) Nature-based solutions for climate change, people and biodiversity. COP26 Universities Network Briefing.  Available at:

Dasgupta, P. (2021) The Economics of Biodiversity: The Dasgupta Review, London. Available at: (Accessed: 15th February 2021).

Green Alliance (2021) Jobs for a green recovery Levelling up through nature, London. Available at: (Accessed 6th May 2021)

RSPB (2021) Transitioning to a nature positive economy by 2030, UK. Available at: (Accessed 7th May 2021)