6th Report - Environmental sustainability and housing growth

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 … Read more 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 and one for the PIB—in response to this report. (Recommendation, Paragraph 23) Show less

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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 … Read more 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 decision-making and collaboration. It should be maintained by a cross- 85 departmental team. We note that mechanisms to consolidate and share data–such as the National Land Data Framework and MAGIC (Multi-Agency Geographic Information for the Countryside)–are in development. We recommend accelerating this into a fully operational data sharing platform. This would facilitate cross-government working on nature, planning and housebuilding decisions. (Recommendation, Paragraph 32) Show less

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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, … Read more 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, unplanned and speculative development. These revised definitions should be provided to the Committee in the Government’s response to this report. (Recommendation, Paragraph 45) Show less

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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 … Read more 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 Act 2021 86 targets, the Environmental Improvement Plan, Biodiversity Net Gain, Nature Recovery Networks, Environmental Land Management Schemes, Local Nature Recovery Strategies (LNRS), Environmental Delivery Plans (if in existence) and Flood Plans. The relationships between LNRS and other spatial planning and nature policies, such as the ones noted above, should be made clear. In its response to this report, Government should lay out how each of the policies mentioned above align and work together. (Recommendation, Paragraph 58) Show less

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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 … Read more 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 areas, in reflection of unique and local environmental characteristics. The Ministry of Housing, Communities and Local Government, and the Department for Environment, Food and Rural Affairs, should work together to audit all local plans once produced to ensure that, collectively, they add up to meet national house building and biodiversity targets. (Recommendation, Paragraph 59) Show less

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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 … Read more 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 on biodiversity should eventually be integrated into Sustainable Development Strategies and be required to align with Local Nature Recovery Strategies. (Recommendation, Paragraph 60) Show less

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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 … Read more 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 and consider the need for property flood resilience measures in all new developments through building regulations. As stated in our recent report on flood resilience, the Government should initiate a consultation on statutory requirements for assessing the cumulative impact of development on flood risk within local and regional plans by the end of Show less

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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 … Read more 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 out mechanisms as to how decisions made by the Secretary of State could be scrutinised and held accountable. (Recommendation, Paragraph 80) Show less

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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) Read more 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) Show less

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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 … Read more 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 EDPs. (Recommendation, Paragraph 86) Show less

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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 … Read more 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 a fully comprehensive impact assessment of the environmental aspect of the NRF has been completed can informed decisions about the efficacy of the NRF be made. The Government and Natural England must be clearer as to how approaches to the NRF will differ depending upon the environmental issue at hand. If this is not possible, then the NRF should only be applied to nutrient pollution, as we cannot be sure of the impact it will have on the environment otherwise. (Recommendation, Paragraph 90) Show less

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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 … Read more 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 (PIB) is brought into force and should set out details of how it is to be implemented, such as timelines and actions to be taken by relevant stakeholders. We encourage the OEP to monitor and regularly report on the implementation of the PIB once in statute, including on 89 how successful it is at safeguarding protected habitats and species, the application of the overall improvement test, compliance with the EPPS Duty and the non-regression statement on the face of the Bill. (Recommendation, Paragraph 91) Show less

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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 … Read more 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 last resort. We believe that the strict application of the MH on housing developments should remain in place, unless it is proven, using the best available scientific evidence, that nature is better served by not adopting the hierarchy in specific and individual instances. (Conclusion, Paragraph 97) Show less

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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 … Read more 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 improvements in all occasions where the MH has not been applied. This transparency is necessary to build confidence that nature a) has not been depleted and b) that it is benefitting from this alternative approach. (Recommendation, Paragraph 98) Show less

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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 … Read more 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 been applied to developments with an EDP, alongside evaluations of the effectiveness of the decisions made to improve the environment. (Recommendation, Paragraph 99) Show less

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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 … Read more 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 oversight and enforcement of BNG throughout its lifespan, and how monitoring and enforcement is standardised across Local Planning Authorities to ensure consistent delivery. (Recommendation, Paragraph 112) 90 Show less

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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 … Read more 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 Government should consider the implications of third-party delivery models. In addition, the Government should explain to us what it is already doing to prevent residents from being overcharged for BNG services in its response. (Recommendation, Paragraph 114) Show less

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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 … Read more 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 undermine the policy. The Government should not exempt all small sites, but consider minor alterations, to ensure that the effectiveness of the policy is maintained. We reiterate our recommendation in paragraph 124 of our report on The Role of Natural Capital in the UK’s Green Economy. The Government should wait at least three years before making any substantial changes to BNG, as this could be viewed as a watering down of ambition. (Recommendation, Paragraph 116) Show less

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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 … Read more 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 concerns. (Recommendation, Paragraph 117) Show less

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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 … Read more 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 Drainage Systems mandatory in all new developments. (Recommendation, Paragraph 128) Sustainable Construction Show less

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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 … Read more 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 policy in this area. (Conclusion, Paragraph 140) Show less

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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, … Read more 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, as soon as possible [ … ], the Government should seek to establish the RICS methodology as the UK industry standard for whole-life carbon assessments”. (Recommendation, Paragraph 141) Show less

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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 …

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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 …

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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 …

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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)

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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 …

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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 …

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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 …

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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 …

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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)

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