Source · Select Committees · Environmental Audit Committee
6th Report - Environmental sustainability and housing growth
Environmental Audit Committee
HC 439
Published 16 November 2025
Recommendations
1
Rejected
Imperative to publish considerations on planning reforms' compliance with environmental principles.
Recommendation
The Government has assured us that section 19 of the Environment Act 2021, which requires Ministers to give full consideration to the Environmental Principles Policy Statement (EPPS) when making policy, was complied with during the drafting of the latest revision …
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Government Response Summary
The government rejects the recommendation to publish their considerations on how the NPPF and PIB comply with the EPPS, stating that such considerations are not routinely published to protect the ministerial decision-making process.
2
Not Addressed
Provide separate statements to Committee demonstrating NPPF and PIB compliance with EPPS
Recommendation
The Government should set out how the NPPF and PIB comply with the EPPS, in line with sections 17 and 19 of the Environment Act 2021. Two complete and separate statements should be shared with the Committee—one for the NPPF …
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Government Response Summary
The government's response details its Planning Data Platform for land and housing data, digital planning services, and forthcoming Land Use Framework, but does not provide statements on how the NPPF and PIB comply with the Environmental Principles Policy Statement (EPPS).
4
Not Addressed
Establish a shared geospatial and environmental data platform for cross-government use
Recommendation
Within 12 months of this report, the Government should establish a shared geospatial and environmental data platform, integrated with a case working system. This should be designed for use across government departments, arms-length bodies and local planning authorities to aid …
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Government Response Summary
The government's response discusses a consultation on changes to the National Planning Policy Framework (NPPF) and environmental sustainability, which does not address the recommendation to establish a shared geospatial and environmental data platform within 12 months.
6
Accepted in Part
Ensure local planning authorities produce up-to-date local plans for appropriate development assessment
Recommendation
We recommend that the Government do more to ensure that local planning authorities are able to, and do, produce up to date local plans, to ensure that developments are being assessed by appropriate local policies, rather than being subject to …
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Government Response Summary
The government has published a consultation on a new NPPF with policies to align plans with environmental requirements and aims to digitise the planning system with new digital tools to improve plan-making and monitoring. This partially addresses enabling local planning authorities to produce updated plans.
7
Not Addressed
Amend NPPF's sustainable development definition to prioritise environmental sustainability and strengthen safeguards
Recommendation
We recommend that the Government should amend the definition of the presumption in favour of ‘sustainable development’ in the December 2024 revision of the NPPF to give greater weight to environmental sustainability. This should include strengthening safeguards against environmentally unsustainable, …
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Government Response Summary
The government's response discusses the abolition of the 'Duty to Cooperate' and general biodiversity policy in the NPPF, but does not address the recommendation to amend the definition of 'sustainable development' to give greater weight to environmental sustainability.
9
Not Addressed
Align future national land use policies with all environmental targets and frameworks explicitly
Recommendation
Any future national spatial planning or land use policies, such as a Land Use Framework or Spatial Development Strategies, must be aligned with, and complimentary to, all environmental targets, frameworks and policies. These include but are not limited to: Environment …
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Government Response Summary
The government's response focuses on the mechanics and accountability of Environmental Delivery Plans (EDPs), including the Overall Improvement Test and public consultation, but does not provide the requested overview of how EDPs align with the broader set of environmental targets and policies.
10
Not Addressed
Ensure local authorities have up-to-date plans to collectively satisfy national environmental targets
Recommendation
Local authorities must ensure they have up to date local plans and environmental and climate planning policies. When combined, all local plans and policies should satisfy national environmental targets, allowing for flexibility as to how they meet these targets between …
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Government Response Summary
The government's response addresses Natural England's role in the National Restoration Framework (NRF) and potential conflicts of interest, and does not engage with the recommendation regarding local plans, environmental policies, or a joint audit to meet national targets.
11
Not Addressed
Incorporate biodiversity into Duty to Co-operate, aligning with Local Nature Recovery Strategies
Recommendation
We recommend that the Government should explicitly incorporate matters relating to biodiversity into the Duty to Co-operate, enabling local planning authorities to work together to meet national house building and biodiversity targets at a regional level. The Duty to Co-operate …
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Government Response Summary
The government's response discusses the Nature Restoration Fund (NRF) and Environmental Delivery Plans (EDPs), focusing on monitoring and reporting environmental outcomes, but does not mention or commit to incorporating biodiversity into the Duty to Co-operate for local planning authorities at a regional level.
13
Not Addressed
Initiate consultation on statutory requirements for assessing cumulative impacts of development on flood risk.
Recommendation
We reiterate that the Government should ensure that flood and climate resilience are embedded into the core tools of planning, regulation, and investment appraisal. The NPPF should be strengthened to prioritise flooding avoidance and climate adaptation, mandating sustainable drainage systems …
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Government Response Summary
The government's response refers to monitoring and implementation of the Nature Restoration Fund (NRF), which does not address the recommendation to embed flood and climate resilience in planning tools, strengthen the NPPF, mandate sustainable drainage systems, or consult on cumulative flood risk impact.
14
Accepted in Part
Employ the full breadth of policy levers to improve the natural environment.
Recommendation
We acknowledge and welcome the Government’s amendments in June 2025 to Part 3 of the Planning and Infrastructure Bill. Akin to the OEP, we see the potential benefits of moving towards a more strategic approach to nature recovery. The amendments …
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Government Response Summary
The government explains how the mitigation hierarchy will be applied through the Nature Restoration Fund (NRF) and how the Secretary of State will regulate the prioritisation of conservation measures within Environmental Delivery Plans (EDPs), demonstrating action on some policy levers.
15
Acknowledged
Avoid viewing nature as an inconvenience or blocker to new housebuilding projects.
Recommendation
The Government must not veer down the path of viewing nature as an inconvenience or blocker to housebuilding. In most cases housing delivery is delayed or challenged due to unclear and conflicting policies, land banking and skills shortages. Using nature …
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Government Response Summary
The government responds by detailing the monitoring and reporting requirements for the Nature Restoration Fund (NRF) and Environmental Delivery Plans (EDPs), asserting that these robust safeguards will ensure positive environmental outcomes are secured alongside development, implicitly addressing the concern about nature being viewed as a blocker.
17
Not Addressed
Publish criteria and accountability mechanisms for Secretary of State's EDP improvement test decisions.
Recommendation
In the interest of transparency, in response to this report, MHCLG and DEFRA should publish the criteria the Secretary of State will use to determine whether an EDP has passed the overall improvement test or not. It should also set …
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Government Response Summary
The government's response discusses controlling costs and ensuring effective implementation of on-site Biodiversity Net Gain, including consultations on estate management companies, but does not address the recommendation to publish criteria for the Environmental Delivery Plan's overall improvement test or accountability mechanisms for the Secretary of State.
19
Not Addressed
Publish statement outlining conflict of interest protections for Natural England's EDP and Fund roles.
Recommendation
Natural England should publish a clear statement outlining how it will protect against conflicts of interest arising when developing, implementing and assessing Environmental Delivery Plans and the Nature Restoration Fund in response to this report. (Recommendation, Paragraph 85)
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Government Response Summary
The government's response discusses challenges and proposed exemptions for delivering Biodiversity Net Gain on brownfield land with Open Mosaic Habitat, but does not address the recommendation for Natural England to publish a statement on managing conflicts of interest in Environmental Delivery Plans.
20
Not Addressed
Regularly assess if EDP policy implementation reduces public confidence in Natural England.
Recommendation
The Government and NE should regularly assess whether the implementation of the EDP policy is reducing public confidence in NE and consider how they can, from the outset, build confidence in NEs ability to be both producer and arbiter of …
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Government Response Summary
The government's response details funding for local planning authorities to implement Biodiversity Net Gain and support skills development, but does not address the recommendation for assessing public confidence in Natural England's role regarding Environmental Delivery Plans.
22
Not Addressed
Revise Nature Restoration Fund impact assessment to include diverse environmental issues and local authority roles.
Recommendation
The Government should revise the impact assessment for the NRF, to take account of a variety of environmental issues, not only nutrient neutrality. It should consider the impact, role and budget of local authorities during the revision process. Only once …
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Government Response Summary
The government's response details investment in flood and coastal defence, support for nature-based solutions for flood risk, and policies for sustainable drainage systems, but does not address the recommendation to revise the impact assessment for the Nature Restoration Fund.
23
Not Addressed
Prepare comprehensive regulatory assessment for the Nature Restoration Fund before PIB Part 3 enactment.
Recommendation
Given the weak impact assessment of the NRF, we ask the Government to prepare a regulatory assessment of the NRF, if and when it is adopted. This assessment should be completed before Part 3 of the Planning and Infrastructure Bill …
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Government Response Summary
The government's response discusses updating guidance on carbon accounting and states it is not currently considering the RICS methodology for whole-life carbon assessments. It does not address the committee's specific request for a regulatory assessment of the NRF or OEP monitoring of the PIB.
24
Not Addressed
Strict application of mitigation hierarchy for housing developments remains essential without scientific justification.
Recommendation
The relaxation of the mitigation hierarchy (MH) in the Planning and Infrastructure Bill has been a significant point of contention. The MH aims to ensure that harm to nature is first avoided, with destruction and compensation used only as a …
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Government Response Summary
The government's response focuses entirely on carbon accounting and climate change targets, stating it will maintain a voluntary approach to carbon assessments and update planning practice guidance. It does not address the committee's recommendation regarding the strict application of the mitigation hierarchy in housing developments.
25
Not Addressed
Publish site-specific evidence of environmental improvements when mitigation hierarchy has not been applied.
Recommendation
Whilst accepting the Minister and NE’s assurance that the MH has remained in place, and would only be set aside where doing so would demonstrably benefit nature, we urge the Government and NE to publish site-specific evidence of the environmental …
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Government Response Summary
The government's response discusses its commitment to net zero, the challenge of embodied carbon, and the assessment of evidence for reducing emissions, but does not address the recommendation to publish site-specific evidence of environmental improvements where the Mitigation Hierarchy has not been applied.
26
Not Addressed
Publish annual reports detailing mitigation hierarchy application and environmental effectiveness on EDP sites.
Recommendation
We recommend that this evidence should include the systematic monitoring and review of the environmental outcomes on all sites where an EDP has been approved and introduced. NE should publish annual reports detailing the extent to which the MH has …
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Government Response Summary
The government's response discusses the complexities of introducing tax incentives for green energy installations and declines to review council tax based on embodied carbon. It does not address the recommendation to systematically monitor environmental outcomes on EDP sites or for NE to publish reports on mitigation hierarchy application.
28
Not Addressed
Clarify responsibilities for oversight, enforcement, and standardised monitoring of off-site Biodiversity Net Gain projects.
Recommendation
More clarity is needed on how off-site Biodiversity Net Gain (BNG) projects will be maintained, monitored, and enforced over the full 30-year period. We ask the Government, in response to this report, to lay out clearly who is responsible for …
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Government Response Summary
The government's response discusses whole-life carbon assessments and updating Planning Practice Guidance for carbon emissions, completely failing to address the recommendation for clarity on how off-site BNG projects will be maintained, monitored, and enforced.
30
Not Addressed
Set out plans to control long-term costs of on-site BNG and prevent overcharging residents.
Recommendation
The Government should set out how it plans to control the long-term costs and implementation of on-site BNG initiatives, so they are delivered to sufficient standards and ensure unreasonable costs are not passed onto households; as part of this, the …
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Government Response Summary
The government's response discusses construction product reform, green procurement, and ecolabels, but it does not address how it plans to control long-term costs or implementation of on-site BNG initiatives, or prevent households from being overcharged for BNG services.
32
Not Addressed
Prevent blanket exemptions for small sites and defer substantial BNG policy changes for three years.
Recommendation
While the Government has completed its consultation on new exemptions to BNG, additional exemptions must not undermine the effectiveness of the policy, ecosystem integrity, or the establishment of the BNG credit market. Entire exemptions from BNG for small sites would …
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Government Response Summary
The government's response focuses on the NPPF, VAT on renovations, and tackling empty homes, and does not address the recommendation regarding BNG exemptions for small sites or the timing of policy changes.
33
Not Addressed
Enhanced Regeneration Programme offers solution if BNG requirements impact brownfield site viability.
Recommendation
In the event that BNG requirements do render brownfield sites less attractive or viable then the Enhanced Regeneration Programme could be an appropriate approach, particularly in areas that require housing growth but have struggled to secure investment, related to viability …
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Government Response Summary
The government agrees ecological expertise is critical and details significant investments to boost general planning capacity and skills across the system, including for ecological advice, but does not address the specific suggestion of using an Enhanced Regeneration Programme for brownfield sites if BNG impacts viability.
34
Accepted
Assess local authority capacity for monitoring BNG commitments and ensure adequate resourcing.
Recommendation
The Government should conduct an assessment of the capacity and performance of monitoring of BNG commitments by local authorities. Local authorities must understand their responsibilities to ensure that BNG promised is delivered and buy in expertise and resource if it …
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Government Response Summary
The government states it continues to work with stakeholders to strengthen the planning workforce and already supports local planning authorities with ecology through existing recruitment, skills development, and specialist training programs, but does not commit to conducting a specific assessment of BNG monitoring capacity or new accountability measures.
36
Rejected
Mandate prescriptive standards for green and blue infrastructure in all new and refurbished developments.
Recommendation
The Government should be more prescriptive on the standards of green and blue infrastructure in new developments. The Government should mandate initiatives like Natural England’s Green Infrastructure Framework in new and refurbished developments to seek to ensure high standards of …
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Government Response Summary
The government rejects developing mandatory training or reviewing planning qualifications related to ecology and decarbonisation, stating it has no plans for such measures and that local planning authorities make their own training decisions, though it supports a wider planning capacity programme. It does not address being more prescriptive on green/blue infrastructure standards or mandating the GI Framework.
37
Not Addressed
Embed nature-based solutions into national flood resilience strategy by 2027 and mandate SuDS.
Recommendation
As recommended in our Flooding Resilience report, nature-based solutions are highly effective and underutilised in protecting England’s properties from flooding. The Government should embed nature-based solutions as a core component of national flood resilience strategy by 2027 and make Sustainable …
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Government Response Summary
The government's response details ongoing support for local planning authorities through the Planning Capacity and Capability Programme, focusing on training and skills for planners in areas like BNG and nutrient neutrality, but it does not address the recommendation to embed nature-based solutions in flood resilience strategy or mandate Sustainable Drainage Systems.
38
Not Addressed
Accelerate introduction of policy to reduce embodied carbon in the built environment.
Recommendation
Reducing embodied carbon is vital to decreasing the carbon emissions of the built environment and meeting the UK’s legally binding climate targets. Considering that key milestones for reducing carbon emissions are rapidly approaching, the Government must accelerate the introduction of …
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Government Response Summary
The government's response focuses on skills, workforce capacity, and job plans within the construction and energy sectors, rather than addressing the recommendation to accelerate policy introduction specifically aimed at reducing embodied carbon.
39
Not Addressed
Establish RICS methodology as the UK industry standard for whole-life carbon assessments.
Recommendation
We reiterate and support the recommendation given by our predecessor Committee on embodied carbon and whole-life carbon assessments: a. “The RICS Professional Statement on whole-life carbon assessments is fit for use and already familiar to UK industry. We recommend that, …
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Government Response Summary
The government's response details Natural England's role in the National Restoration Framework (NRF) and its funding, completely failing to address the recommendation to establish the RICS methodology as the UK industry standard for whole-life carbon assessments.
40
Accepted
Develop progressively ratcheted carbon targets and set timeframe for mandatory whole-life carbon assessments.
Recommendation
Additionally: a. “We recommend that following the introduction of whole life carbon assessments, the Government should develop progressively ratcheted carbon targets for the built environment, to match the pathway to net zero set out in periodic carbon budgets. These ratcheting …
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Government Response Summary
The government states that it has already set legally binding carbon reduction targets and that it must be able to meet those targets in the round.
41
Acknowledged
Review taxation policies to incentivise homeowners, housebuilders, landlords, and tenants towards low-carbon homes.
Recommendation
The Government should consider what other steps it could take to encourage low-carbon approaches to building, including reviewing taxation policies to incentivise home owners, housebuilders, landlords and tenants to favour homes with lower levels of embodied carbon. (Recommendation, Paragraph 143)
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Government Response Summary
The government acknowledges the importance of addressing embodied carbon and is assessing evidence to consider the best way forward, while also keeping all taxes under review.
42
Rejected
Commission a review into Council Tax and Stamp Duty Land Tax for lower embodied carbon homes.
Recommendation
We recommend that the Government commission a review into Council Tax, Stamp Duty Land Tax and any other tax policies to consider the merit of offering lower bands of taxation for homes with lower levels of embodied carbon. (Recommendation, Paragraph …
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Government Response Summary
The government does not plan to review council tax on the basis of embodied carbon because of potential complexity, revenue impact and the fact that council tax is paid by occupiers, not owners or developers.
43
Acknowledged
Accompany RICS whole life carbon assessment framework amendments with a formal statement.
Recommendation
We would encourage any amendments made to the RICS whole life carbon assessment framework to be accompanied with a formal statement, detailing the amendments and confirming that they have been approved to become part of the UK industry standard. This …
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Government Response Summary
The government is not currently considering adopting the RICS methodology as the UK industry standard for whole-life carbon assessments, but will keep it under review.
44
Rejected
Mandate major developers submit whole life carbon assessments for all planning applications.
Recommendation
Major developers should submit whole life carbon assessments as part of planning applications to local authorities; this should be mandatory for all major developments, as defined in the NPPF. The Government should consult on ways to financially incentivise housing development …
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Government Response Summary
The government does not agree with mandating whole life carbon assessments at this time, but commits to updating Planning Practice Guidance to assist local authorities and support developers in reducing carbon emissions.
46
Acknowledged
Update NPPF revision with clearer expectations and conduct consultation on embodied carbon reduction.
Recommendation
The December 2024 revision of the NPPF should be updated to include clearer and stronger expectations on embodied carbon for new developments. The current Government should also honour the promise made by the previous Government and conduct a consultation on …
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Government Response Summary
The government published a consultation on a new NPPF in December 2025, including proposed changes to climate change policies. They are still reviewing the evidence on measuring embodied carbon and considering policy options, citing other related initiatives already underway.
48
Acknowledged
Introduce eco-labelling for building products to popularise low-carbon materials in housebuilding.
Recommendation
Whilst the Government has taken initial steps to promote timber through the Timber Construction Roadmap, there remains a lack of clear incentives and guidance to encourage the adoption of low-carbon material in housebuilding. The Committee believes the Government should take …
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Government Response Summary
The government states that more can be done to encourage, incentivise, and implement environmental and sustainable practices across the construction products sector, and that it intends to remain aligned to the EU regime, but stops short of committing to eco-labelling for building products while it analyses consultation responses.
49
Accepted
Consult by April 2026 on financial incentives for lower embodied carbon products and manufacturing.
Recommendation
The Government could also consider other financial incentives in product areas where the cost differential makes adoption of lower embodied carbon products unattractive and support for manufacturing set up of lower embodied carbon products. We recommend that the Government consult, …
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Government Response Summary
The government states it is already exploring financial mechanisms such as the Advance Market Commitment pilot for low carbon concrete.
52
Acknowledged
Prioritise and incentivise building retrofitting over demolition by strengthening reuse requirements and reducing VAT.
Recommendation
Government should prioritise and incentivise retrofitting over demolition by strengthening requirements to reuse, repurpose and refurbish buildings before any demolition. It is contrary to the Government’s environmental objectives to incentivise carbon-intensive new building over the re-use of existing sites. To …
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Government Response Summary
The government acknowledges the importance of reusing existing buildings and states that it encourages this through the VAT system with a reduced rate of 5% for certain residential renovations, but states that any further reduction in VAT rates must represent value for money and is the responsibility of the Chancellor.
55
Accepted
Invest in ecology training and establish local ecological resource hubs by July 2026.
Recommendation
We recommend that the Government should invest in and prioritise the training and upskilling of talent in ecology as a priority. As a temporary measure, to address current staff shortages, the Government should pilot and establish local ecological resource hubs, …
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Government Response Summary
The government believes existing investments in planning capacity, including funding for skills development, recruitment of ecologists, and support for environmental arm's-length bodies, make ecological resource hubs unnecessary, though they will keep the position under review.
57
Accepted
Standardise and embed essential practical components into ecology course design by April 2026.
Recommendation
We recommend that the Government, via Skills England, begins working with ecology qualification providers to standardise and embed essential practical components into ecology course design, by April 2026. This is to ensure that courses are geared towards modern policy demands …
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Government Response Summary
The government asserts that it already supports local planning authorities with ecology through recruitment, skills development and specialist training, referencing a previous response.
58
Accepted
Establish a national pathway with professional bodies to accelerate early-career ecologist training.
Recommendation
The Government should partner with professional bodies to accelerate the training of early-career ecologists through a national level, government- supported pathway, similar to that of the Pathways to Planning programme backed by the Local Government Association and MHCLG. The first …
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Government Response Summary
The government states they are already expanding national routes into planning and related environmental roles and do not consider a separate, ecology-specific national pathway necessary at this time, but will keep this under review.
60
Accepted in Part
Planning qualifications fail to adequately equip professionals with carbon literacy and ecological knowledge
Recommendation
Planning qualifications do not adequately equip professionals with sufficient levels of carbon literacy or ecological knowledge. This undermines planning officers’ ability to fully consider environmental factors in their decision making. To ensure that climate resilience, carbon emissions and ecology are …
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Government Response Summary
The government rejected mandatory training or a review of planning qualifications, but will work with the Planning Advisory Service to develop continuous professional development modules in ecology, carbon literacy and climate change, and provide funding for training.
61
Rejected
Require mandatory training in ecology and carbon literacy within planning qualifications and accreditation
Recommendation
Planning qualifications and accreditation should include mandatory training in ecology and carbon literacy, to ensure that planning professionals have adequate knowledge of nature and climate issues to address these challenges in the built environment. We recommend that the Government, via …
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Government Response Summary
The government has no plans to develop mandatory training in ecology and the decarbonisation of buildings, or review current planning qualifications. They state local planning authorities decide on resource allocation for training.
62
Accepted in Part
Develop and support continuous professional development modules in ecology and carbon literacy for qualified planning professionals
Recommendation
In addition, we recommend that the Government works with the Planning Advisory Service to develop suitable continuous professional development modules in ecology, carbon literacy and climate change, for qualified planning professionals and support their delivery through local authorities. These should …
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Government Response Summary
The government will continue to work with PAS and explore opportunities to strengthen continuous professional development for planners, including modules related to ecology, carbon literacy and climate change, but does not fully commit to the recommendation.
65
Accepted
Provide realistic assessment of construction workforce numbers and skills needed for housing and climate targets
Recommendation
We recommend that the Government, in response to this report, should: • Provide a realistic assessment of the construction workforce and what is needed to deliver the Government’s housing targets for each remaining year of this Parliament. This should include: …
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Government Response Summary
The government states that Skills England publishes assessments of priority skills needed across the economy to 2030, including construction and housebuilding and mentions additional funding and plans addressing skills gaps.
67
Accepted
Publish paper detailing Natural England's required resourcing to deliver housing targets by March 2026
Recommendation
The Government should publish a paper, by March 2026, clearly laying out the Government’s housing targets, NE’s role as a statutory consultee and in developing and implementing the NRF, and what resourcing will be required for NE going forwards to …
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Government Response Summary
The government states that the Planning and Infrastructure Act establishes Natural England’s role in developing and implementing the NRF and mentions funding allocated to set up and support the NRF.
Conclusions (22)
3
Conclusion
Not Addressed
Improved data sharing is a fundamental enabler of efficient and effective cross-organisational work to deliver sustainable housing. While there is evidence of cross-departmental working between DEFRA and MHCLG on planning, nature and housebuilding, the evidence we have taken suggests that existing data platforms are still siloed within organisations. This inhibits …
Government Response Summary
The government's response focuses on general plan-making system reforms and the use of digital tools, but does not specifically address the committee's observation about siloed geospatial and ecological data platforms inhibiting cross-organisational data sharing.
5
Conclusion
Acknowledged
We have heard strong and repeated concerns that the environment could be sidelined in the presumption for sustainable development, and that the current revision of the National Planning Policy Framework (NPPF) could result in unsustainable and speculative development. The evidence we received suggests that the presumption in favour of sustainable …
Government Response Summary
The government acknowledges the challenge of balancing competing land needs and states that a new national infrastructure spatial tool is being developed to integrate strategies, data, and tools, including environmental considerations, for housing, growth, and land use.
8
Conclusion
Not Addressed
Stakeholders highlighted the importance of alignment between a national Land Use Framework, environmental policies and planning policies. Such alignment will help direct housing developments and nature conservation or restoration to appropriate locations. It will also help reduce confusion, avoid conflicting objectives, and support coherent decision-making and streamlined delivery. Crucially, it …
Government Response Summary
The government's response details existing and proposed policies on flood risk and sustainable drainage systems within the NPPF, but does not address the broader concern about the importance of alignment between a national Land Use Framework, environmental policies, and planning policies.
12
Conclusion
Not Addressed
As our recent report on flood resilience stated, the planning system fails to account for the cumulative and cross-boundary impacts of development on flood risk. Land use decisions are often made in isolation, without considering downstream consequences, catchment-scale dynamics, or long-term resilience. This fragmented approach undermines catchment- based and natural …
Government Response Summary
The government's response discusses the impact assessment of the Nature Restoration Fund (NRF) using nutrient neutrality as an example and the legislative safeguards for Environmental Delivery Plans, but it does not address the committee's observation regarding the planning system's failure to account for cumulative and cross-boundary impacts on flood risk.
16
Conclusion
Not Addressed
We are concerned about the levels of subjectivity that may arise if the Secretary of State for the Environment acts as the sole and final arbiter of whether an Environmental Delivery Plan satisfies the overall improvement test. (Conclusion, Paragraph 79)
Government Response Summary
The government's response details the mechanisms for off-site Biodiversity Net Gain, including legal agreements and enforcement, but does not address the committee's concern about the Secretary of State's subjectivity in assessing Environmental Delivery Plans.
18
Conclusion
Not Addressed
Considering the conflicting roles Natural England (NE) are expected to play in developing, delivering and assessing Environmental Delivery Plans (EDPs) and the Nature Restoration Fund, we are concerned about the potential for either a real, or a perception of, a conflict of interest. We do not doubt the earnestness and …
Government Response Summary
The government's response outlines measures to simplify Biodiversity Net Gain for small and brownfield developments and its application to Nationally Significant Infrastructure Projects, but does not address the committee's concern about Natural England's potential conflict of interest in Environmental Delivery Plans.
21
Conclusion
Not Addressed
We accept that the initial impact assessment of the Nature Restoration Fund (NRF) was carried out on the basis of nutrient neutrality, due to limitations with broader data availability. However, as the NRF will have considerable implications for a wide range of environmental issues aside from nutrient pollution, a unidimensional …
Government Response Summary
The government's response discusses consulting on changes to planning policy for the natural environment, including green infrastructure provision, but does not address the committee's criticism regarding the unidimensional impact assessment of the Nature Restoration Fund (NRF).
27
Conclusion
Not Addressed
It is too early to assess the overall success of Biodiversity Net Gain (BNG), as the policy is still establishing itself. Its long-term success is dependent upon the establishment of clear and effective regulation. The absence of standardised monitoring and enforcement protocols, clear lines of accountability, and insufficient resourcing, undermines …
Government Response Summary
The government's response states it is not considering adopting the RICS methodology for whole-life carbon assessments and will keep it under review, which is unrelated to the committee's concerns about the regulation, monitoring, and enforcement of Biodiversity Net Gain (BNG).
29
Conclusion
Not Addressed
We are concerned there is a risk that implementing Biodiversity Net Gain (BNG) on housing developments may inadvertently result in unreasonable fees for residents or more expensive housing, which runs counter to the Government’s aim of creating more affordable housing. Communities of all socio-economic backgrounds should be able to afford …
Government Response Summary
The government's response discusses a consultation on NPPF climate change policies and ongoing work on reducing embodied carbon, which does not address the committee's concerns about Biodiversity Net Gain leading to increased housing costs or fees.
31
Conclusion
Not Addressed
Introducing new exemptions to BNG when the policy remains in the early stages of implementation may have unintended consequences, particularly if applied too broadly. We believe more time is needed to assess the effectiveness of BNG before substantive changes are made. (Conclusion, Paragraph 115)
Government Response Summary
The government's response details its exploration of financial mechanisms for low embodied carbon products and an Advance Market Commitment pilot for low carbon concrete, which does not address the committee's concern about introducing new Biodiversity Net Gain exemptions.
35
Conclusion
Acknowledged
We recognise and welcome the recognition of the importance of green infrastructure in the latest revision of the NPPF. However, we heard that more can be done to promote it within the planning system. (Conclusion, Paragraph 126)
Government Response Summary
The government agrees on strengthening early career pathways, expanding graduate schemes, and supporting professionals in planning, including ecology-related roles, to ensure the planning system has the necessary expertise, but does not directly detail new measures to promote green infrastructure within the system.
45
Conclusion
Acknowledged
The revised NPPF does not contain explicit reference to embodied carbon, despite a widely held opinion that the NPPF must play a central role in supporting low-carbon housing. This oversight limits the NPPF’s ability to minimise carbon emissions from new buildings and undermines efforts to meet the UK’s emission reduction …
Government Response Summary
The government published a consultation on a new NPPF in December 2025, including proposed changes to climate change policies. They are still reviewing the evidence on measuring embodied carbon and considering policy options, citing other related initiatives already underway.
47
Conclusion
Acknowledged
Alternative building materials, such as timber and hemp, offer practical and effective ways to reduce the embodied carbon of buildings. Their use supports Government ambitions to reach net zero and continue to deliver on their sustainable housing target, in addition to stimulating economic growth through the development of relatively nascent …
Government Response Summary
The government believes more can be done to encourage sustainable practices across the construction products sector, while considering safety, productivity, innovation and growth. The government references the Construction Products Reform White Paper and says it intends to remain aligned with the EU regime.
50
Conclusion
Accepted
Retrofitting existing buildings is more environmentally friendly and sustainable than demolition and new construction. We accept that not all existing properties can be converted into residential buildings, and do not deny that some new homes do need to be built. However, prioritising the retrofit and regeneration of existing buildings could …
Government Response Summary
The government says that retrofitting and regeneration of buildings is already encouraged in policy through a consultation on a new NPPF and the VAT system.
51
Conclusion
Accepted
Although retrofit and regeneration of buildings is already encouraged in policy, it is often sidelined. Strengthening focus in this area should be prioritised, considering the range of benefits associated with doing so. (Conclusion, Paragraph 167)
Government Response Summary
The government says that retrofitting and regeneration of buildings is already encouraged in policy through a consultation on a new NPPF and the VAT system.
53
Conclusion
Accepted
As with the embodied and operational carbon recommendation (Para 138nb mbnj ) we believe that the Government should investigate how it can use the tax system to reduce the tax burden on properties that reduce their carbon footprint and/or increase the tax burden on environmentally regressive properties to create a …
Government Response Summary
The government recognizes the importance of reusing existing buildings and already encourages this through the VAT system on residential renovations. The government has also given local authorities powers and incentives to tackle empty homes.
54
Conclusion
Accepted
One of the strongest messages we have heard throughout this inquiry is that local planning authorities are severely under-resourced in terms of ecological expertise. Addressing this should be a priority, as without rapid and meaningful support, the Government will struggle to meet its house building targets while adhering to environmental …
Government Response Summary
The government agrees that ecological expertise is critical in the planning system and outlines the actions it is already taking through additional investment and the Planning Capacity and Capability Programme to strengthen skills across the system.
56
Conclusion
Accepted
Qualifications in ecology may not always contain sufficient practical elements in the courses that equip future ecologists with the necessary skills for professional practice. The Committee has heard that some students may require additional training to develop the necessary competencies needed for professional roles after gaining formal qualifications such as …
Government Response Summary
The government does not consider establishing separate ecological resource hubs is necessary, citing existing investments and close work with the sector to monitor capacity.
59
Conclusion
Accepted
The shortage of planning professionals in local authorities is undermining the planning system’s ability to function effectively. Planning officers are unable to thoroughly consider applications within statutory timeframes and are unable to adequately pre-consult. This capacity gap compromises the quality, transparency and timeliness of planning decisions. This is problematic, as …
Government Response Summary
The government agrees that ecological expertise is critical in the planning system and outlines the actions it is already taking through additional investment and the Planning Capacity and Capability Programme to strengthen skills across the system.
63
Conclusion
Accepted
We have heard concerns that the construction industry does not have the numbers, nor the skills, needed to deliver the volume or types of homes that will enable the Government to meet its targets for housing, the environment, nature and net zero. We welcome the Government’s acknowledgment of this, along …
Government Response Summary
The government acknowledges the concerns, and states that Skills England publishes assessments of priority skills, and a Construction Jobs Plan is being developed. The government also says it is investing £15bn in home upgrades via its Warm Homes Plan and has made several policy commitments to address skills gaps.
64
Conclusion
Accepted
However, we are yet to be convinced that this alone will be enough. As the Government itself has acknowledged, the construction sector will be instrumental in meeting wider Government commitments. Recruiting new talent is essential but training takes time and, in the interim, the existing workforce is already overstretched but …
Government Response Summary
The government describes existing actions to address skills gaps in the construction sector, including skills assessments, a Construction Jobs Plan, funding for skills, and investment in home upgrades, in response to concerns about the workforce's ability to meet housing and environmental targets.
66
Conclusion
Accepted
If the environmental objectives of the Government are to be achieved, it is vital that Natural England (NE) is adequately resourced. However, NE does not currently have the necessary resources to deliver the Government’s expectations of it. Its reliance on partners, such as local authorities, is concerning considering they are …
Government Response Summary
The government states that it has allocated funding to set up the Nature Restoration Fund and further funding to boost capacity in the planning system, and will continue to work with Natural England to ensure appropriate resources are in place.