1.  INTRODUCTION

  The RSPB is pleased that the ODPM Select Committee has chosen to investigate Planning for sustainable housing and communities. The positive role that planning can and should play in delivering more sustainable communities and housebuilding merits investigation. Whilst the Committee is looking at a wide range of issues in respect of this inquiry, the RSPB is particularly concerned about the potential environmental impact and consequences of housing and community building, including potential enhancement. Our submission concentrates primarily on the environmental issues identified by the Committee:

—  Whether the proposals will promote high quality sustainable communities whilst avoiding poorly designed urban sprawl.

—  The overall scale of housebuilding required.

—  The geographical distribution of new housing, including plans to concentrate development in the South East in four growth areas, Milton Keynes, the Cambridge/Stansted (M11) corridor, Ashford and the Thames Gateway.

2.  A SUSTAINABILITY PURPOSE FOR PLANNING

  2.1  The RSPB welcomes much of the statement by the Deputy Prime Minister on Sustainable Communities: Delivering through planning on 18 July[37]. In particular, we support the essential role identified for the planning system in delivering a better quality of life, truly sustainable development, living communities and urban and rural regeneration. We endorse the recognition that planning reforms should build on the fundamentals of the planning system, especially the "plan-led" system, and the recognition that culture change and more resources are urgently needing in planning.

  2.2  The RSPB strongly believe that the achievement of sustainable development should be the principal objective for the whole planning system and for all development proposals. Therefore, any new communities or housing schemes, whether small or large, should maximise their contribution towards achieving sustainable development.

  2.3  To achieve this we believe that furthering sustainable development must be a principal objective (through a new duty of purpose) in a new Town and Country Planning Act. We were, consequently, pleased that the (then) Planning Minister, Lord Falconer of Thoroton announced his intention to "put sustainability at the heart of the planning system"[38] in March 2002.

  2.4  Lord Falconer indicated that legislation should set out a statutory planning purpose that would clearly reflect the objective of planning to promote development. We are pleased that the Deputy Prime Minister reiterated this commitment: "we propose to include a statutory purpose for planning in any new proposals for legislation that are brought forward, subject to ensuring that this is done in a way that does not create additional complications for the way that the system operates"[39]. Planning for communities and housing must, in future, further this purpose.

3.  THE ENVIRONMENTAL IMPACT OF HOUSING AND COMMUNITIES

  3.1  Housing is a major economic, social and environmental issue, and the Government is faced with the difficult task of integrating the need for homes with the need to conserve our urban and rural environments and scare natural resources. Housebuilding can have damaging environmental impacts but where it is demonstrably needed, it also has the potential to produce positive planning and some environmental enhancement.

  3.2  The planning system, central and local government and developers have a crucial role to play in delivering necessary housing, of the right tenure, in the right place, at the right time and to the highest environmental standards. The RSPB believe that, as a first principle, all housing developments should address their potential environmental impacts by:

—  Avoiding adverse environmental impacts wherever and whenever possible—through careful location, design and resource use;

—  Mitigating adverse impacts where avoidance of all adverse impacts is not possible, and the development is demonstrably needed and there are no suitable alternatives; or

—  Compensating for any residual damage that cannot be mitigated where environmental damage is unavoidable. Compensation must not be used to justify environmentally damaging development and it should always be a last resort.

  3.3  The RSPB also believe that there are opportunities for enhancing the environmental quality of housing development and sites through positive planning, where housing need is proven (see 7.1 below). Enhancement should not be confused with mitigation; enhancement is about providing additional benefits, and it should not be used to make unacceptable developments acceptable.

4.  PPG3 AND SUSTAINABLE COMMUNITIES

  4.1  Choosing where to build is the most environmentally significant decision that planners, developers and landowners take. It dictates the range of environmental, social and economic impacts, both positive and negative, that a development will have. Therefore, we welcome the Government's commitment to create "sustainable residential environments" as outlined in PPG3 Housing.[40]

  4.2  We support the sequential approach to housing allocation established in PPG3. This emphasises the need to re-use previously developed land first (with availability to be determined through urban housing capacity studies—although many authorities have yet to complete theirs); to explore the scope for urban extensions second; and lastly to seek new development nodes around good public transport corridors. In addition, we believe there is some scope to intensify existing suburban areas, through strategically planned increases in housing density. This should only occur where suburbs are well served by public transport and intensification would not adversely affect their quality, (for example, in some cases the biodiversity of back gardens can be greater than that of agricultural land and, therefore, their loss could be locally significant).

  4.3  Maximum effort should be focused on, and priority given to, the development of land that has been previously developed, before attention is switched to Greenfield sites. Consequently, we believe that previously developed land options should be fully explored and realised through the four grown area studies identified—Ashford, Milton Keynes and South Midlands, London-Stansted-Cambridge (M11) corridor, and the Thames Gateway—before Greenfield options are pursued. The committee should consider whether the existing government target of providing 60% of housing on "Brownfield" land is sufficient[41].

  4.4  It should be noted that the Thames Gateway, in particular, includes habitats of significant nature conservation importance, such as inter-tidal mudflats, coastal grazing marsh and ancient woodland. It encompasses sites designated for their outstanding nature conservation importance, such as the Thames Estuary and North Kent Marshes, which are internationally important for birds and designated as Sites of Special Scientific Interest (SSSIs), Special Protection Areas (SPAs, under the EU Birds Directive) and Ramsar sites (under the Convention on Wetlands of International Importance).

  4.5  It is imperative that any community and housing development in the Thames Gateway does not damage these outstanding nature conservation assets, either directly or indirectly. Community development brings with it, and indeed may require as a pre-requisite, development of significant infrastructure, which has the potential to damage these assets. The potential new international airport at Cliffe Marshes on the Hoo peninsular in north Kent is just such a highly damaging infrastructure proposal. It would result in the loss of 275 hectares of SPA, 479 hectares of SSI and Ramsar site, not to mention approximately 60% of the RSPB's own Northward Hill reserve. The RSPB is opposed to this proposed airport option.

  4.6  In the context of seeking to maximise the use of previously developed land, it should be noted that "Brownfield" land is often used as "shorthand" for previously developed land. In many cases, "Brownfield" land may have been colonised by wildlife and established significant semi-natural habitat, so it is not always appropriate to develop "Brownfield" sites. We are, therefore, pleased that the Government's definition of previously developed land excludes land "where there is a clear reason that could outweigh the re-use of the site—such as its contribution to nature conservation . . ."[42]. Such sites should therefore be avoided.

5.  HOUSING DENSITY

  5.1  Maximum effort should also be made to increase the density of housebuilding, where this maintains and enhances quality of life. We support the advice in PPG3 that "local planning authorities should avoid the inefficient use of land"[43] and that they should critically examine standards they apply to new housing developments. We welcome the emphasis on encouraging housing development of between 30-50 dwellings per hectare. It is notable, however, that "A sustainability checklist for developments"[44], published by the Building Research Establishment in conjunction with the DTLR and DTI, is more challenging in its density objectives. It identifies 35-40 dwelling per hectare (dph) as "minimum practice" 41-59 dph as "good practice" and 60+ dph as "best practice". It is also surprising that, given the assertion on density in PPG3, the recently introduced residential density Direction only applies to London and the South East[45]. We are keen that higher densities are achieved wherever they are required and that "good" and "best practice" in density is the norm, not "minimum practice".

  5.2  The emphasis in PPG3 on creating well designed, quality places and developments, that are better linked to public transport, consist of a greater mix of uses, have more greenspace, and make most efficient use of land is welcome. Better quality and design is central to the task of creating sustainable communities but in some cases, design has been, and still is, of an inadequate standard. Examples of good or best practice have not been as widely adopted as they might have been and some local authorities suggest they need more guidance.

  5.3  Moreover, "quality design" must mean better resource efficiency overall, not just in terms of energy efficiency, as is implied in PPG3[46]. For instance, new development can have a dramatic impact on water resources. Water conservation measures are an importance consideration for new communities. Water conservation measures could include:

—  fitting water meters to encourage more efficient use;

—  water efficient toilets, showers and taps;

—  "grey" water recycling technology—using already used water, for example from washing clothes and dishes, bath water, etc—especially on new developments;

—  rainwater collection facilities for use in gardens.

  Developers should also consider incorporating sustainable drainage systems such as:

—  permeable paving, to reduce surface run-off and allow rainwater to filter into the water table[47];

—  reedbed creation, other other suitable on-site water retention measures, to clean run-off, allow gradual filtering back into the water table and which, at the same time, provide wildlife benefits.

  Development on floodplains and areas at risk from sea level rise may need to be avoided.

6.  SUSTAINABLE CONSTRUCTION AND SUSTAINABLE HOUSING

  6.1  Once a sustainable location has been identified, the next challenge is to build communities and housing that contribute towards sustainable development. Planning should help to deliver distinctive development that people want, placing a premium on locally distinctive, environmentally beneficial design—development that is "fit for place" and "fit for purpose". It should promote resource efficient development wherever and whenever appropriate.

  6.2  The Government has itself identified that "the economic, social and environmental benefits which can flow from a more efficient and sustainable construction industry are potentially immense"[48] and that the planning system "has a key role in underpinning more sustainable construction"[49]. Careful planning of the nature, design, layout and the materials used in settlements and housing, as well as other forms of development, can greatly improve their sustainability. The Government concludes that "greater resource efficiency lies at the heart of the sustainable development challenge for construction"[50].

  6.3  Over 90% of non-energy minerals extracted in Great Britain are destined for construction. Nearly 50% of non-renewable energy in the UK is used by building services. Construction produces 70 million tonnes of soil, building and demolition waste per annum of which, astoundingly, 13 million tonnes is made up of materials that are never used. This is clearly an unsustainable practice which manifestly fails to follow the Government's own waste hierarchy of reduce-re-use-recycle[51].

  6.4  Building a better quality of life, the Government's sustainable construction strategy, provides 10 themes/practical actions for developers to follow to create more sustainable building[52].

—  Re-use existing built assets—eg Re-use, refurbishment or renovation.

—  Design for minimum waste—design out waste in the use of land (by building at higher densities), in construction and throughout the use of the building.

—  Aim for lean construction—eg a quality management process and waste elimination.

—  Minimise energy use in construction—and the transport of materials and waste.

—  Minimise energy in building use—eg through use of natural light and heat/cooling, and Combined Heat and Power and renewable energy sources.

—  Avoid pollution.

—  Preserve and enhance biodiversity—"look for opportunities throughout the construction process—from the extraction of raw materials, through the construction phase, to the landscaping of buildings and estates—to provide and protect habitats"[53].

—  Conserve water resources—through water efficient design.

—  Respect people and their local environment.

—  Set targets—measure and compare performance with others.

  6.5  In most cases, these use tried and trusted technologies or approaches whose wider application could have s significant beneficial impact on resource efficiency and environmental impact. In addition, as the report points out, reducing consumption of materials and land, reducing waste, increasing energy efficiency, and managing construction and buildings better are good for business as well as the environment.

  6.6  The committee should investigate why, despite significant Government encouragement and available technology, residential developments and buildings frequently fail to meet the best resource and environmental design standards. The need for a stronger role for planning, stricter standards, better or more co-ordinated resources and/or more comprehensive guidance should be considered.

  6.7  Every opportunity should be made to minimise waste, by avoiding over-specification and over-delivery, and to lead from the front through Government and the public sector—as the public sector purchases about 40% of the construction industry's output by value (£24 billion per annum). In particular, our approach to costing buildings needs to adopt a more whole life costing approach, rather than focusing on the initial cost of building and assuming that cheapest is best.

  6.8  As the Government points out, "public concern for the protection of the environment means that, if construction projects are the win widespread public acceptance, the way in which they are carried out will come under close scrutiny. (Construction) organisations will need to be able to demonstrate a concern of sustainability at the heart of their businesses"[54]. Clearly, a "step change" is required in the future construction of communities and housing.

7.  ENVIRONMENTAL ENHANCEMENT

  7.1  If both location and construction are sustainable, then opportunities for environmental enhancement may be appropriate. Development should, wherever and whenever possible, seek to put something back—it should enhance places, rather than just protect them. Developers can take positive steps to benefit wildlife, and provide varied, distinctive and attractive housing in the process. This will be achieved by:

—  developing sites with little of no wildlife of environmental value, and where other constraints are absent;

—  minimising the development's environmental impacts;

—  enhancing a site's wildlife value through retention, creation and appropriate management of wildlife features and habitats.

  7.2  Wildlife is not confined to designated areas, and the variety of habitats in all our countryside is important for wildlife conservation. Non-designated countryside provides wildlife corridors and stepping-stones that help to maintain the current range of diversity of habitats, and help important species to prosper. Legislation and planning policy guidance encourage the management of landscape features that are important for wildlife.

  7.3  Housing which incorporates countryside features, and retains a greater degree of the site's character, is likely to be more attractive to potential purchasers. Countryside features that are important for wildlife, landscape and amenity include hedgerows (especially ancient), trees, copses, watercourses, ponds and marshy ground/wetland.

  7.4  Development can also provide opportunities to re-instate some of the countryside features that we have lost in the past through wildlife enhancement. This should be borne in mind when considering landscaping. Strategic consideration of landscaping at an early stage in project and site design should recognise that one large (habitat) area will normally be more valuable for wildlife than a number of smaller areas. A full ecological survey of a site at an early stage can help to identify areas and features to be retained of planted, as well as areas appropriate for development. Key principles that can, therefore, be adopted in all developments are:

—  forward planning, involving early co-operation and dialogue between key partners;

—  ecological survey, prior to detailed site design, to collect information on the site's natural environment and allow early identification of constraints and opportunities;

—  retention and management of countryside features including ponds, hedges and trees, which must be effectively protected during construction works;

—  ecological enhancement through, for example, hedge and woodland planting and management;

—  creation of strategically identified and broad "green" corridors within the development, to aid the passage of wildlife through the site.

  7.5  Even very small-scale measures to encourage wildlife can be easily incorporated in new housing developments. For instance, swifts and house martins have traditionally found ideal nesting sites under the eaves, ventilators and other available cavities of buildings. Modern houses rarely offer these opportunities[55]46. Simple adjustments can be made to cater for birds, including leaving small spaces in the ventilation mesh to allow swifts and house martins to nest, of incorporating specifically designed nestboxes under eaves or on a gable ends. However, to maximise the chance of these being used, developments need to cater for other key needs of such birds, including food, water, shelter and shade.

38   Lord Falconer of Thoroton at the launch of Living Spaces, 18 March 2002. Back

39   Sustainable Communities, paragraph 15. Back

40   DETR (2000) PPG3 Housing, The Stationery Office. Back

41   The Council for the Protection of Rural England suggests an increased target of 75%, for instance. Back

42   PPG3, Housing, Annex C. Back

43   PPG3, para. 57. Back

44   Brownhill, D and Rao, S (2002) A sustainability checklist for developments: a common framework for developers and local authorities, BRE, Watford. Back

45   ODPM (2002) The Town and Country Planning (Residential Density) (London and South East) Direction 2002. Back

46   PPG3, para. 56. Back

47   Further information on water conservation and sustainable water management can be obtained from the Building Services Research and Information Association (BSRIA), and the Environment Agency National Water Demand Management Centre. Back

48   DETR (2000) Building a better quality of life-a strategy for more sustainable construction, (para 1.3) DETR. Back

49   Building a better quality of life, (para 4.3). Back

50   Building a better quality of life, (para 2.1). Back

51   HM Government and National Assembly for Wales (2000) Waste Strategy, Stationery Office. Back

52   Building a better quality of life, (para 5.2). Back

53   Building a better quality of life, (para 5.2). Back

54   Building a better quality of life, (para 3.3). Back

55   Wotton, SR, et al (2002) Homes for Birds: the use of houses for nesting by birds in the UK, in British Birds 95, November 2002. Back