Q. When is ‘Guidance’ not guidance?
A. When it’s removed from the Government website.
Early in 2015 the Government removed the link between National Planning Policy Guidance (NPPG) and Green Infrastructure (GI) guidance on the Natural England website. The shift was made as part of the push by the Coalition government to ‘simplify planning approval processes and make our policies and guidance simpler and easier to follow.’
In immediate response, the Landscape Institute, The Town and Country Planning Association, Groundwork UK and the Land Trust joined forces to write a letter to the Department for Environment, Food and Rural Affairs (DEFRA) and The Department for Communities and Local Government (DCLG) in which they expressed considerable concern. The letter made three specific points:
- Without proper, updated green infrastructure guidance within the NPPG, the GI guidance will carry little legal weight in the planning process. GI will, in effect, be ‘downgraded’ throughout the planning system. This is of particular concern at a time when the value of GI in tackling pressing issues such as climate change mitigation / adaptation and public health is well recognised.
- Archiving of GI guidance undermines the ability of all users of the NPPG to find up to date, relevant information on the underpinning concepts behind green infrastructure.
- Lack of up to date guidance will hamper efforts to deliver effective, multifunctional green infrastructure on the ground, undermining the ambitions set out in the Government’s Natural Environment White Paper (NEWP).
Last week, in the final session of the outgoing Parliament, Housing and Planning Minister Brandon Lewis responded to these points. He stated that there would be no change to planning policy or guidance on GI and that Natural England guidance is still available and accessible for users. The link to the NPPF has not been restored, but representatives of the LI, TCPA, Groundwork UK and the Land Trust will be invited to meet with Defra officials to discuss how guidance can best be provided. He pointed out that the NPPF is clear that local planning authorities should set out a strategic approach in their local plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure.
The ministerial response records that GI must be considered at a strategic level, but it offers no steer on how it will be delivered. With only three general references to GI in the NPPG, the nuts and bolts of how developers and local planning authorities should embed relevant measures to create high quality development are missing. These details, specific to how planning applications should be considered, are laid out in the now archived Natural England guidance.
Green Infrastructure – a cost or a benefit
Paradoxically given the Government perception of GI as a drag on the planning process, there is extensive evidence that it adds value to creating places where people want to live and work.
Natural England describes GI as “a strategically planned and delivered network comprising the broadest range of high quality green spaces and other environmental features. It should be designed and managed as a multifunctional resource capable of delivering those ecological services and quality of life benefits required by the communities it serves and needed to underpin sustainability. Its design and management should also respect and enhance the character and distinctiveness of an area with regard to habitats and landscape types.
Green Infrastructure includes established green spaces and new sites and should thread through and surround the built environment and connect the urban area to its wider rural hinterland. Consequently it needs to be delivered at all spatial scales from sub-regional to local neighbourhood levels, accommodating both accessible natural green spaces within local communities and often much larger sites in the urban fringe and wider countryside.” Natural England Guidance, 2009.
Whilst Landmark welcomes any measure that genuinely improves the efficiency and effectiveness of planning, we don’t agree that separation of GI policy from GI practice will achieve this objective. Detaching the guidance from the legal framework which it was framed to inform will create gaps in the decision making process, which can only hinder the function of planning to meet the needs of communities, developers and the environment. How does GI add value to meeting these needs?
Health and wellbeing
GI contributes significantly to achieving a high quality environment and sense of place, enhances biodiversity and landscape character by connecting existing and new habitats and features, and provides indirect benefits to health and quality of life. Set against a background that some 25% of men and women in the UK are now obese and over 55% are overweight, the good sense of building opportunities for recreation, exercise, and reducing stress levels into new development are obvious. So too are the community benefits of providing freely available access to, as just a few examples, natural greenspace, for play, allotments, edible forest gardens and community gardening.
Biodiversity and Climate Change
Investment in GI improves and protects habitats, and aids connectivity within natural and human ecosystems. The Natural Environment Act observes that urban green infrastructure is “one of the most effective tools available in managing environmental risks such as flooding and heatwaves”. As a practical example of this tool, quantitative assessment of the benefits of GI in urban environments by Gill found that an additional 10% of green cover in high density urban areas could moderate temperatures sufficiently to entirely counteract warming due to climate change by 2050.
Interception of water and facilitation of natural drainage GI is a key tool in aiding these processes. This may be through green roofs, sustainable urban drainage systems or SUDs (including attenuation ponds, swales, ditches and channels), reintroduction of vegetation to moderate or impede river flows through catchment management planning, as well as the creation of natural greenspaces to enable the natural infiltration of surface water. Such tools not only resolve flooding and runoff. They also add habitat diversity and provide additional green space to new development.
Turning now to the crux of the matter? Does GI add unacceptable cost to development sufficient to justify downgrading its role in planning? There is strong evidence to the contrary.
The 2014 Green Infrastructure Added Value Study of the Mersey Forest used standard financial modelling to examine different variables in costing new commercial development, such as rental levels, incentives, void periods, and the cost of green infrastructure on value. It found that the uplift in property value from improving these variables can easily outweigh the cost of providing the green infrastructure as part of new commercial development. The study showed that developers who invest in the environment, through quality of buildings and the surrounding hard and soft landscaping, can secure much higher rents (of around 20 percent) above competing schemes that have not seen the same level of investment.
Managing financial risk is a key driver for developers. The study shows that being able to attract and retain commercial tenants can reduce by 0.1-0.2 percent with green infrastructure Investment, and consequently, that will have a large impact on value. The larger the development, the greater the impact. Land and property values often increase as a result of improving the setting and consequently generate opportunities for further investment. GI cannot be considered as a single factor that will attract businesses, but it clearly adds recognisable value.
An election issue?
In view of these benefits, the Government approach is overly narrow. Uncoupling technical GI guidance from the NPPG appears to concede that Whitehall does not understand the economic, let alone the social, community and environmental benefits of GI. GI is an asset rather than a cost. The market will not, however, invest in GI in the absence of a coherent planning policy framework that recognises and protects its role in securing a healthy environment. Will this change under a new administration?
- Nature Nearby, Accessible Natural Greenspace Guidelines, March 2010, Natural England
- Green Infrastructure Guidance, 2008, Natural England
- The Natural Environment White Paper – The Natural Choice: securing the value of nature, 2011, HM Government
- Natural Environment White Paper – Implementation update report, October 2014, DEFRA
- Green Infrastructure Added Value Mersey Forest – Final Report, November 2014, BE Group