Written evidence submitted by the Wildlife Trusts [NPP 30]
1.0 Introduction
1.1 This submission has been developed by The Wildlife Trusts in response to the Committee’s inquiry into National Planning Policy.
1.2 Wherever you are, there is a Wildlife Trust caring for wildlife and wild places near you. We have a shared mission to create an environment rich in wildlife for everyone and to inspire people to value and take action for nature. We are actively engaged in the planning system, promoting opportunities to improve the natural environment and reviewing more than 60,000 planning applications a year. We have more than 800,000 members including 150,000 members of our junior branch Wildlife Watch. Every year we work with thousands of schools and our nature reserves and visitor centres receive millions of visitors. Each Wildlife Trust is working within its local communities to inspire people about the future of their area: their own Living Landscapes and Living Seas.
1.3 A Living Landscape is a recovery plan for nature championed by The Wildlife Trusts since 2006 to help create a resilient and healthy environment rich in wildlife and to provide ecological security for people. In A Living Landscape habitats are restored and reconnected on a large scale with the local community closely engaged. The vision is a primary objective of The Wildlife Trusts and builds on a groundswell of landscape-scale activity at a county level. The Wildlife Trusts have a long track record of delivering landscape-scale conservation. Across the UK there are now more than 150 Living Landscape schemes covering an area of more than four million hectares. These are being delivered in partnership with many different individuals and organisations, including farmers and landowners, water companies, land-based industries, local authorities, other NGOs, statutory agencies, local communities and volunteers.
1.4 We have an interest in this inquiry because any review of national planning policy must address nature and biodiversity considerations, if planning is to fulfil its objective of helping achieve sustainable development.
1.5 We would like to submit views on the following elements of the consultation:
1.6 We hope that this response is helpful. We will forward you our full response to the CLG consultation in due course.
2.0 Supporting new settlements and development around commuter hubs
2.1 In our experience there is often little evidence of environmental sustainability being a significant factor in the development of new settlements or urban extensions.
2.2 We support the proposal in question 6 for national planning policy to provide greater policy support for new settlements in meeting development needs providing that this is done alongside and not at the expense of meeting environmental objectives.
2.3 In order to deliver sustainable development objectives, ecological constraints and opportunities should be fully considered when developing new settlements. For example, higher density development could be supported by the provision of high quality semi-natural green spaces that incorporate walking and cycling routes as well as biodiversity enhancements.
2.4 Whilst we do not object to the proposal to increase development density around commuter hubs where appropriate, there are some potential issues with this approach which should be considered at the outset including a clearer definition of commuter hub, wider sustainability/infrastructure issues and the environmental limits of the area and the potential impact on sites of high environmental value. Clear guidelines will be needed.
2.5 Paragraph 14 of the consultation document uses the example of non-operational railway land near existing stations as an opportunity to help deliver more housing. Micheldever rail sidings in Hampshire is an example of a brownfield site that has already been subject to one planning application, although not for housing. It is adjacent to a railway station and is of high ecological value and could become more vulnerable if rigorous criteria for protecting important ecological sites are not in place. We consider sites should be considered on a case by case basis as we suggest below in paragraph 3.6.
2.6 The definition of commuter hub in Paragraph 15 needs further clarity. There are many public transport interchanges, for example train, tram and tube stops where travellers can alight to continue their journey by other public transport or active travel means, which are already in high density housing areas and would not be suitable for additional high density housing.
3.0 Supporting housing development on brownfield land
3.1 The consultation proposes making it clearer in national policy that substantial weight should be given to the benefits of using brownfield land for housing, which would, in effect, amount to a form of ‘presumption’ in favour of brownfield land.
3.2 Whilst we do not object in principle to this change of emphasis we strongly believe that the preparation of a register of brownfield sites suitable for housing must pay due regard to environmental factors, as this would result in housing being directed to the most sustainable sites and the protection of important wildlife species and habitats.
3.3 Some brownfield sites will be of high environmental value and represent important components of a resilient ecological network and are important to both people and wildlife. Building on all brownfield sites risks sites of high environmental value being isolated and eventually lost. Ultimately this will result in a degradation of local environmental quality and have implications for the Government’s efforts to halt the decline in biodiversity.
3.4 The National Planning Policy Framework (NPPF) recognises that some brownfield sites can be of high environmental value, which is welcome. However, given the proposed new emphasis on developing brownfield sites, we propose that guidance should be provided to local authorities to assist with their preparation and maintenance of brownfield registers.
3.5 This should include advice on how to manage environmental issues and constraints, both to ensure a consistent approach is taken to these issues, and to give maximum clarity to developers and the public. The guidance should be issued before local authorities commence the process of preparing registers.
3.6 We suggest that the guidance should recommend local authorities:
3.7 Greater clarity is needed on what is meant by ‘brownfield land’ and the coverage of the new presumption. For example, will the presumption only apply to the development of some sites in the register, all sites on the register or to any sites that an applicant might seek to define as brownfield? In our view the presumption in favour should be restricted to sites on the register, provided these have been assessed for suitability by the local authority as per paragraph 3.6.
3.8 Local experience shows that some developers endeavour to argue that many sites are ‘brownfield’ including those in rural areas that have had development on them (for example, solar farms, transmission masts, quarries that have re-vegetated, ex-MOD and nuclear research sites, grassed areas within airport boundaries and allotments). There needs to be recognition that in some areas, sites that might be classed as ‘brownfield’ sites are often now nature rich or can have a very small development footprint on a largely otherwise undeveloped site.
3.9 Unless there is greater clarity on what is understood by the term ‘brownfield’ there is a risk that a range of sites could be subject to a ‘presumption in favour’ of development, despite the reality that many of these are of high environmental value or in extremely unsustainable locations.
4.0 Supporting the delivery of starter homes
4.1 Whilst we have no objection in principle to the strengthening of the starter homes exception site policy, we are concerned that this could have unintended consequences for nature conservation if the clarifications we propose below are not provided.
4.2 We strongly believe revised National Planning Policy should clarify the circumstances in which it may be appropriate not to apply the exception site policy, for example in instances where there would be harmful impacts on nature conservation sites such as Local Wildlife Sites.
4.3 There are risks in assuming that sites which are unviable or under-used for retail, leisure, institutional or indeed commercial/employment uses are suitable for Starter Homes. For example, they may be in locations where non-residential development would not be environmentally harmful, but residential use would (for example, close to heathland sites of national/international importance, placing additional recreational pressure on these important areas, particularly if Suitable Alternative Green Space is not provided).
4.4 Paragraph 22 of the NPPF states that applications for alternative uses should be treated on their merits and those merits should include environmental considerations. These requirements need to be clearly stated, as otherwise it seems that locally any ‘presumption in favour’ may be taken as overriding other concerns. This could undermine the delivery of other requirements of the NPPF, such as paragraph 118.
4.5 For these reasons we consider that great care is needed on definitions. The proposed wording states “overriding … local environmental (such as flood risk) considerations that cannot be mitigated”. This is acceptable provided that “overriding local environmental considerations” include those set out in paragraph 117 of the NPPF.
5.0 Ecological Networks
5.1 The creation of ecological networks is acknowledged in current environmental policy as a key mechanism through which the biodiversity of this country can be both protected and enhanced (NEWP 2011). The NPPF already contains some positive policies on ecological networks and encourages local authorities to promote their preservation, restoration and recreation, and to identify and map components of local ecological networks as a way of minimising the impacts of planning policies on biodiversity (NPPF, paragraph 117).
5.2 Ecological network mapping is about taking a spatial strategic approach to the natural environment, identifying areas of existing value such as Local Wildlife Sites and high value brownfield land, and looking for opportunities to create connections with new habitats that will benefit people and wildlife. Without such spatial mapping, it will not be possible to identify where interventions are required in order to create ecological networks and thus deliver the environmental policy ambition. But this mapping is also a vital tool for planners and developers to ensure that the natural environment sits at the heart of local planning and ‘place making’ decisions and to help ensure that development happens in places that will benefit both nature and people.
5.3 Despite the clear policy driver within the NPPF, there is little evidence of ecological network mapping making its way into local planning processes currently[1] and, as such, potentially valuable local plan policies on ecological networks are not being supported with the spatial information needed to make them meaningful and deliverable. There is likely to be a range of reasons for this but it is our strong recommendation that much more should be done by government to support the implementation of this key policy through the provision of detailed guidance for local authorities on how to prepare and use ecological network maps.
5.4 We also recommend that government monitors the implementation of this policy and takes opportunities to share best practice across the country and to build expertise in this area of planning.
5.5 Through our own work on ecological network mapping, we are discovering the potential power of this spatial tool, not only to guide investment in nature, but also to help to resolve potential land-use conflicts and identify opportunities to deliver benefits for nature and for people. It is equally applicable in rural and urban areas (where it can inform Green Infrastructure planning) and it is also a very useful way in which to engage people with their local environment, how it works and what it needs for the future. As such it is a potentially very valuable mechanism through which to embed nature at the heart of neighbourhood planning.
5.6 We are therefore encouraging Defra to look carefully at the role of ecological network mapping during the development of its 25 year plan for the recovery of the natural environment. We also believe that Defra should seek engagement with CLG on how to best support its implementation as a key function of local planning across the country, whether this is via the recommendations outlined above (e.g. support, monitoring and developing expertise) or through other means. We would urge the CLG Committee to do the same, given the many benefits that it can help to unlock and the significant differences it would make to the delivery of positive planning for nature and people.
[1] RSPB and TWT 2015, Nature Positive Plans Local Plans Research Report, May 2015