Topic 3 - Green infrastructure

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What the topic is about

As part of our aspiration to make Leeds zero carbon by 2030 we want to ensure that we are making the most of our green spaces and natural environment to help meet our climate change aspirations and improve the health and well-being of our citizens.

Our vision

Where we are now

Our current local plan has many effective policies on green infrastructure and they have seen real improvements in the way GI is delivered in Leeds. However, they don't go far enough to make us zero carbon by 2030, so we think we need to go further.

Where we want to get to

We want to:

• plant more trees and strengthen protections for existing trees, where possible
• ensure that people in Leeds have easy access to high quality, usable green space
• ensure that development maximises the delivery of biodiversity

Proposed policy areas

The areas of policy affected include:

• increased tree planting
• enhanced policy framework
• increased biodiversity and nature conservation
• enhanced greenspace

Introduction to the topic

What is green infrastructure

The purpose of the planning system is to achieve sustainable development, which is about meeting current needs without harming the ability of future generations to meet their own needs. The National Planning Policy Framework (NPPF) sets out that planning authorities should ensure that development meets economic, social and environmental objectives.

The environmental objective is defined by the NPPF as:

This paper looks at the role of the Leeds Local Plan in supporting Green Infrastructure, which forms a fundamental part of the natural environment and contributes to more sustainable development.

Green Infrastructure (GI) is defined by NPPF as:

This network includes parks, green spaces, gardens, woodlands, street trees, hedges, green walls and green roofs. Each element of GI is an important asset for local communities, providing places to play and enjoy and together they make attractive places to live and invest in.

They are also natural climate change assets, because GI:

• reduces greenhouse gas emissions, such as carbon dioxide, associated with new development e.g. by capturing carbon
• benefits public health by removing and reducing air pollution
• if well managed and protected, captures and stores carbon dioxide from the atmosphere (sequestration)
• improves the resilience of places, thereby helping communities adapt to increases in flooding and heat
• helps use scarce resources e.g. water more efficiently
• helps provide strong ecosystems and habitats for plants and animals to reduce biodiversity loss and help species adapt to changes in the climate

The NPPF recognises that GI has a value and recommends assessing the wider benefits of the natural environment / GI using two approaches:

• natural capital – a way of thinking about the natural environment as an asset
• eco-systems services - the benefits to people provided by the natural environment and ecosystems

In order to achieve net gains in sustainable development, it is therefore important to plan for Green Infrastructure in a way that:

• clearly sets out its underpinning importance to sustainable development in Leeds
• maximises its natural climate change role
• places a value on its management, creation and loss

GI often works hand in hand with “blue infrastructure” such as rivers, streams, canals, lakes and other water bodies; both blue and green infrastructure are multi-functional. For instance a well-designed pond can be a sustainable water management system for drainage of a new housing estate, a natural habitat for species, a means of soaking up carbon (as well as water), a leisure destination and improve people’s well-being.

On a wider scale, a well-designed, integrated environment can connect individual green areas and assets to create green routes and corridors, creating pleasant environments to encourage cycling and walking over large distances. It is possible to walk from Leeds City Centre to Windermere via the Dales Way Link to Ilkley and then the Dales Way to the Lake District. 

Greening especially the urban environment can also be a catalyst for investment and economic growth and GI is also usually cheaper than traditional “grey” infrastructure and creates sustainable jobs. This is often known as using nature-based solutions instead of man-made constructed solutions.

GI serves many purposes. For instance a small group of trees (copse) has various Natural Capital functions:

• biodiversity through both the species of trees, the habitat provided and the soils
• carbon capture (also known as sequestration)
• water storage

If a forest path is then developed through the copse it potentially adds the functions/services of health, leisure and education. These are the ‘ecosystem services’ the ‘natural capital’ provides. In essence GI is multi-functional and should never be seen in isolation.

Our relationship with GI has to be understood in this context; that one asset or ‘capital’ serves different purposes. From a planning point of view it is important that we understand this. For instance recent research by Professor Miles Richardson supports the mental health benefits of green space but predicates this on our ability to ‘connect’ with it. This means that green space design as well as quantity is important, as is its accessibility to a range of users.

The pandemic, climate change and the desire to see a healthier society are all key drivers that reinforce the importance of the natural environment to be available to everybody at a neighbourhood level and for those with limited mobility at the street and individual home level.

Elsewhere in the Local Plan update there are topic papers which also consider interlinked issues around better place-making and 20-minute neighbourhoods. GI plays a key role in these planning areas.

Park Square skyline

Current policy position

Protecting, enhancing and extending the network of green infrastructure has been a fundamental element of the Leeds Local Plan for many years. Indeed green infrastructure forms part of the overall Core Strategy Spatial Vision (bullet 9) and managing environmental resources makes up 5 of the 24 Core Strategy objectives. Furthermore, there are many existing policies that fulfil this function which provide an invaluable and much needed statutory basis to require protection, enhancement and extension of the natural environment.

The Local Plan currently contains policies which establish key strategic GI and ambitions to improve the gaps between key corridors.

Core Strategy, map 16: strategic green infrastructure (click to enlarge image)

This sets the framework for GI management and also more detailed plans such as the Aire Valley Leeds Area Action Plan (2017) which sets a GI network for a discreet area of the City experiencing transformational growth.

Aire Valley Leeds Area Action Plan map 5: Aire Valley Leeds green infrastructure network (click to enlarge image)

However, we are not seeing a consistently high standard of GI considerations across all developments. This is partly because national planning policy has been heavily focussed on boosting the supply of housing for the past 10 years with penalties on local authorities that do not have an adequate supply of housing. Thanks to the adoption of the Site Allocations Plan in 2019 Leeds now has a five year land supply and can strengthen its focus on housing quality.

We want to avoid green spaces that are sterile and mono-functional. Instead we want GI to be at the heart of new development as a key underpinning asset.

This helps recognise the multiple benefits and roles green infrastructure can provide, such as at Killingback Meadows where the planting of 8,000 trees and the delivery of new ponds and seasonal wetlands will help reduce flooding and provide natural habitats, as part of the Killingbeck Meadows Flood Alleviation Scheme.

National changes

Whilst detailed Government planning guidance on GI is limited, it is clear that at a legislative and departmental level the direction of Government policy has shifted recently and creates a more positive context for improved GI policies.

A Natural Capital Committee (NCC) was an independent committee which advised the government on natural capital, including ecosystems, species, freshwaters, soils, minerals, the air and oceans, as well as natural processes and functions. It led to a number of changes which support a strong direction of travel on embedding GI into planning policy at the local level as follows:

• a 25 year Environment Plan (2018) which sets the Government’s goals for improving the environment, within a generation, and leaving it in a better state than we found it
• an Environment Bill (initially laid before parliament in 2019) setting out how the Government plans to deliver its commitment to protect and improve the natural environment in the UK in light of evidence and public concern around biodiversity and habitat loss, climate change and environmental risks to public health
• guidance (2020) for policy and decision makers to help them to include contemporary approaches to Green Infrastructure and the value of these into policy (including changes to HM Government Green Book guidance on how appraisals are done)

The main issues pertinent to the Local Plan update are:

• setting targets for improving the natural environment and people’s enjoyment of it and a duty to meet and report on the targets set
• a new system for biodiversity and nature protection including a register of biodiversity gain sites(land which is subject to a conservation covenant or planning obligation and which is to be managed for the purpose of habitat enhancement)and establishing a system of biodiversity credits-enabling developers to 'purchase' credits in biodiversity gain sites
• measuring net gain and eco-systems services at the development level

Vision

Through this Local Plan update we are aiming to adopt and improve policies that will help development adapt and mitigate against the impacts of climate change by creating a better more sustainable environment. With regard to green infrastructure our vision is as follows:

This topic paper sets out the sorts of areas to be considered in taking this proposed vision forward and asks a number of questions to find out what you think.

Identification, protection, enhancement and extension of green infrastructure

Background

The value and importance of open land is widely recognised for a number of reasons such as giving us opportunities to visit and enjoy nature, providing homes to wildlife and being the landscape context for where we live. The restrictions due to COVID-19 have brought into focus the importance of accessible land and nature close to our doorsteps and this, along with the important role open land and the natural environment has in addressing the climate emergency, only increases the need to continue to protect, enhance and extend the existing network of green infrastructure within Leeds.

Policy aims

• to clearly identify existing land which merits protection and state robust reasons why protection is necessary
• to provide statutory protection for all identified green infrastructure through formal designation and a policy presumption against the loss of GI
• to seek improvements and high quality enhancements
• to seek the extension of the green infrastructure network through the identification and protection of additional open land

Existing policies and rationale for potential change

Whilst the Local Plan contains an effective suite of policies relating to GI, these policies are spread across a variety of Local Plan documents. This can be confusing and they could benefit from being strengthened and consolidated. The Local Plan update can set a clear, strong, high level framework and contain more detailed polices with robust and justified requirements, directions and targets which will ensure protection and facilitate improvements and extensions. Any policies should recognise the different values of land, whether it be for agriculture, recreation, wildlife habitats or the visual beauty of the landscape.

Within this broader framework sit other more specific issues which are considered later in this document, such as trees, areas protected for nature conservation and biodiversity.

Identification and designation

Currently the designation of land as green space is dealt with through Policy GS1 in the Site Allocations Plan which identifies areas that function as green space; whilst Core Strategy Policy G6 gives them protection from development. Whilst green space is an element of wider green infrastructure, it is proposed that there is a need to widen out policy protection for a greater range of GI categories.

Protection

Green infrastructure is currently identified in the Core Strategy but there is no presumption against development. The climate emergency and pandemic have raised awareness of its importance. A “presumption in favour of retaining green infrastructure” could offer increased protection for GI. Nevertheless, there needs to be ways in which development can be accepted. It is especially important to extend the recognition and protection into more highly built up areas where open space is at a premium.

Extension of network

Maximising the amount of GI to make the most of its benefits to the climate emergency and our wellbeing and promoting and seeking additional GI where possible can be achieved through planning policy. Some areas may be specifically identified and earmarked for future strategic GI. We can also maximise opportunities as and when they arise through; development, infrastructure projects, landscaping schemes, biodiversity improvements, greening features on buildings, land management and projects to improve the provision of open spaces such as the White Rose Forest and the council’s Woodland Creation Scheme. There would also be benefits to new policy measures to protect any new areas created so that they were not vulnerable to future development.

Quality and enhancement

It is important that areas of GI are of good quality to provide beneficial habitats for nature, opportunities for carbon sequestration and attractive, accessible locations for outdoor activities. Not all GI provided through development is of a high quality and there is a continued need for policy and practice to seek quality spaces.

Proposed policy options

Currently the key policies are Core Strategy Policies SP13 and G1 which identify land which is considered Strategic Green Infrastructure. Policy G1 then takes the defined areas and applies ‘controls’ to development within them. It is felt that the Policy SP13 in conjunction with Policy G1 would benefit from enhancement, especially in the context of the Climate Emergency and COVID-19.

One option would be to have an over-arching strategic policy (an updated Policy SP13) and then have a number of more detailed policies sitting underneath which give more information, requirements and guidance relating to specific matters. A further supplementary planning document would provide more guidance and useful information as well as examples of good practice.

Key elements could be:

• set a more holistic, strategic direction and provide consideration of all green infrastructure
• set a clear definition of “Green Infrastructure”
• provide a framework for the delivery of new green infrastructure as well as the enhancement and protection of existing GI
• set a presumption against the loss of any GI
• revise Policy G1 to set out how the green infrastructure network could be protected, enhanced and expanded and what priorities may emerge more locally
• prioritise connecting strategic GI assets within the City and with neighbouring authorities
• create new green infrastructure
• designate wild belts, on land that has little development value but does not currently benefit from green infrastructure designation or protection
• set a framework for the delivery of localised pockets of GI through green roofs, green walls, roof gardens and hedges that would help mitigate the urban heat island effect in built up urban areas and provide additional greenspace in high density areas
• provide a supplementary guidance document containing additional details, advice, support, examples of good practice etc. so as to assist developers and land managers on specific issues such as species, habitat creation, balance between nature and human activities on GI assets

Trees

Background

At around 13% forest cover in 2015, the UK is one of the least densely forested countries in Europe. This compares with 38% for the EU as a whole and 31% worldwide .

Trees provide many benefits to our environment. They store carbon emissions and take pollutants out of the air, provide shelter and shade and valuable habitats, soften the built environment and bring colour and texture , provide opportunities for us to reconnect with nature and help to support our physical and mental wellbeing which has been brought into particular focus by the restrictions due to COVID-19.

Trees extract and store damaging carbon from the air by what is called carbon sequestration. As trees photosynthesise and grow they absorb carbon dioxide that would otherwise rise up and trap heat in the atmosphere and contribute to global warming. In turn they release large quantities of oxygen. 

It is therefore vitally important that we protect existing trees and plants as they are an extremely valuable natural way of reducing carbon dioxide in the atmosphere. Indeed a large, mature tree could store in the region of 3.5 tons of carbon. Areas of woodland provide the highest concentrations of trees and carbon storage however a study undertaken by the University of Leeds concludes that 1% of regions CO2 emissions is taken up by trees outside woodlands, such as those in urban areas.

The council is a key partner in the White Rose Forest Project to develop a community forest for North and West Yorkshire (part of the wider Northern Forest). This is a partnership between local authorities, landowners, businesses and communities to increase tree cover across the region and improve the natural environment. 

The project will plant millions of trees in urban centres and countryside that will help manage flood risk, combat climate change, create jobs and provide happier and healthier places. The overall White Rose Forest Plan is expected to be launched in August 2021 whilst Leeds City Council’s White Rose Forest Strategy has been endorsed by Executive Board and is nearing completion. 

This Strategy aims to significantly increase the existing 17% tree canopy cover across the District to 33% by 2050 in partnership with business, residents, institutions, communities, landowners and farmers, building on the substantial work that the council already carries out around the planting and management of trees as well as encouraging planting and protection of trees though the planning process. 

Leeds City Council has committed to planting 5.8 million trees over the next 25 years as part of the city’s contribution to the UK net-zero targets.

Policy aims

• to establish a “presumption in favour of retaining existing trees” within the existing legal framework
• to establish a comprehensive, detailed replacement planting regime which takes into account age, size, species, carbon storage capacity etc of trees to be lost and planted to ensure no loss of sequestration levels
• to encourage additional planting and give a strong local statutory foundation for current and future tree planting projects and programmes

Existing policies and rationale for potential change

There are currently two key policies in the Local Plan that deal with trees:

• Core Strategy Policy G2
• Natural Resources and Waste Local Plan Policy LAND2

These are considered to be effective policies, however they were written before the declaration of the climate emergency and therefore they may need to be adapted and strengthened to respond to the current environmental crisis. Recent research from the University of Leeds suggests the 3 to 1 ratio of tree replacement in LAND 2 is inadequate in terms of replacing the carbon sequestration value of mature trees lost and other factors such as tree type, girth, age etc. need to be factored in. This is coupled with new pressures and a strengthening of national agendas with regard to trees that suggest Policy G2 could be made more robust. There are fundamentally two aspects which need to be addressed.

Protection

Firstly, we need to consider how best to protect the trees we already have, from large areas of woodland to individual trees. The council can serve a Tree Preservation Order on particularly visually important trees but these are only appropriate in certain circumstances and they have limited scope to protect in recognition of trees’ biodiversity or carbon sequestration importance. Under separate legislation, trees in conservation areas are protected as are those which are within a statutory designated site or are used by a protected species such as bats. This means most trees are not legally protected and other methods of protection such as the planning system must therefore be fully utilised. The control of development through the application of planning policies and the use of conditions and legal agreements attached to planning permissions provide tangible and robust methods to protect trees through, for example, ensuring buildings are far enough away to protect roots and canopy.

It must be remembered that in some cases the removal of existing trees may be acceptable, when balanced against other wider benefits, particularly wider improvements to Green Infrastructure.

Planting more

Secondly, we should consider how the planning system can facilitate the planting of more trees, over and above requiring landscaping schemes. The Local Plan could provide a strong framework for planting programmes to work within and potentially designate specific sites for future planting. We must be mindful that there are other demands on land and in more rural areas, where there is the scope for larger scale planting, the desire to plant trees must be balanced with the requirements of agriculture and food production.

Trees can also be planted as part of a development scheme. They should be an integral part of open space and, indeed, the layout and design of any housing development. They can be planted on land that has other functions, such as sustainable draining facilities, play spaces, verges, gardens etc. and therefore ensure these spaces are multi-functional and multi-beneficial. We need to be creative and push the boundaries in how this can be achieved. Tree policies are part of this but we also need imaginative design and solutions to practical issues e.g. drainage, transport infrastructure etc. Careful planting and comprehensive, ongoing maintenance and management is key to trees growing, flourishing and reaching their full potential in terms of visual quality, carbon sequestration and biodiversity gain.

Wet woodland, Whinmoor

Proposed policy options

Options for future policies could include:

• Strengthening policy to establish a presumption in favour of tree retention, whilst recognising where exceptions may be necessary, such as the delivery of outstanding improvements to wider Green Infrastructure and biodiversity
• Strengthening tree replacement requirements to fully recognise the role of trees in carbon storage and the need to compensate for any loss of carbon storage through tree removal. This could require applicants to audit the current carbon sequestration contribution made by trees on site, with a requirement to improve that sequestration level through increased and appropriate tree planting
• Allowing developments to make off-site contributions to identified tree planting areas where it is not possible to plant trees on sites
• Identifying new land for tree planting and protect it from alternative uses, where possible

Alternatively, options may include:

• Continuing to pursue non-planning solutions to the delivery of increased tree planting across the District, working with major landowners and other partners
• Retaining the existing policy approach of replacing lost trees on a for 3:1 ratio basis

Green space

Background

One of the key elements of Green Infrastructure within Leeds is “green space”. This is open space which primarily has a recreational function, whether that be, for example, outdoor sport, allotments or for more informal recreation. The importance and value of these sites more broadly has been discussed earlier in this document in relation to access to green space, opportunities for recreation and the enjoyment of the natural environment and the positive effects these have on physical and mental health. The current green space sites are formally designated through Policy GS1 in the Site Allocations Plan (2019) and are shown on the Policies Map and in the Site Allocations Plan documentation.

Green space is considered as a distinct element of green infrastructure in the Leeds Local Plan and therefore has its own suite of policies. These polices give clear requirements for new provision, including amounts per dwelling (Policies G4 and G5) and protection of existing (Policy G6).

Policy aims

We aim to:

• ensure new green space is delivered to meet current and future need
• give existing green space strong protection against loss due to development
• improve existing green space

Existing policies and rationale for potential change

Green space provision

Green space provision outside the City Centre (Policy G4) was recently revised through the Core Strategy Selective Review (2019). 

It is considered that although the Policy is working well, further changes may be appropriate to strengthen it further to deliver better, high quality Green Space. However, we would like to consider our approach to the delivery of green space within the City Centre in Policy G5 to ensure that we’re getting the balance right between high density developments in sustainable city centre locations and making sure that those residents have good access to usable greenspace.

The council is committed to supporting the delivery of improved green space in the City Centre, as evidenced through the Our Spaces Strategy which was launched in March 2020. Within the Strategy it was acknowledged that Leeds City Centre includes a relatively low quantity and quality of green spaces in relation to its size. There is also a lack of nature and limited biodiversity corridors in and between the city centre and the surrounding communities and little provision for children’s play, physical activity, relaxation and habitat diversity. In response to this, the Strategy sets key principles designed to ensure that Leeds will be a substantially greener and better connected city that is more accessible to more people, creates an environment to thrive and is recognisable as a unique place to be.

Recently approved proposals at Aire Park on the Leeds South Bank and at the Corn Exchange and the completion of new green space at Sovereign Square help us deliver on that vision. Moving forward, we’re keen to explore what role planning policy could play in supporting the aspirations to increase the quantity and quality of green space in the City Centre.

New green space at Sovereign Square

At present, City Centre developments on land less than 0.5 hectares are not required to provide green space on site and given the high densities of development, this can result in large developments not delivering green space. However, this must be balanced against requirements to utilise land efficiently, and high density residential development reflects the need to maximise good use of land. Nevertheless, given the Climate emergency and the local needs exacerbated by Covid-19, it is now seen as timely to revisit this approach to see if it needs changing to reflect different circumstances.

Where appropriate, developments can make payments to the council instead of providing new Green Space which are used to provide green space elsewhere. However, the mechanism for calculating this payment means that developments inside the City Centre contribute less than outside the City Centre. It is proposed to revisit this and assess whether the calculation should be adjusted.

Commercial developments in the City Centre above 0.5 Ha are expected to provide Green/Open Space whilst such development outside the City Centre are not. It is therefore proposed to reassess this aspect of the Policy.

Green space protection

As with the broader Green Infrastructure, one of the principle concerns is with the protection of Green Space, which is currently expressed through policy G6 of the Core Strategy.

When green space is not maintained it can fall into poor condition which can affect its usability and make it vulnerable to loss, particularly through development. In some cases it may be appropriate to redevelop sites but in most cases improving existing green space should be the preferred approach. The need for the Green Space is not reduced because of its current condition. Through the Plan we are considering whether to revise our approach to the protection of Green Space to see if this can be improved.

Proposed policy options

For city centre green space, future policy options could include:

• reviewing the site size threshold for the provision of green space
• reviewing the methodology for the calculation of sums in lieu of new green space on site
• considering the principle of commercial sites providing green space in the city centre

For wider green space protection and improvement consideration could be given to whether protection could be enhanced and whether it could be extended to include all green and blue infrastructure, such as trees, natural green space specific to biodiversity aims, new green space etc.

Nature conservation

Background

There is widespread recognition of the importance to protect and enhance the natural environment and ensure habitats and biodiversity are fully considered in planning decisions and opportunities to improve the network of habitats and green infrastructure are utilised.

Indeed the Lawton Report “Making Space for Nature” (Sept 2010) reviewed England’s wildlife sites and the connections between them and concluded that wildlife sites are generally too small and too isolated, leading to declines in species and a loss of natural services we depend on. 

The report recommends that designated wildlife sites are better protected and managed, non-designated wildlife sites are better protected, ecological restoration zones are established and we need a creative approach to water-quality, inland flooding, coastal erosion and carbon storage that will help deliver a more effective ecological network. Sites are identified and formally designated to give protection to habitats, flora and fauna which are important locally, regionally, nationally and internationally. Many organisations and agencies are involved in the recognition, protection and enhancement of wildlife habitats and geologically important sites.

In Leeds there are a number of such sites which are protected against development and activities that would harm the sites under national and international legislation and Policy G8 in the Core Strategy. In recognition of the importance of land that does not meet the criteria for formal designation, the council has identified a broader network of habitats (statutorily and non-statutorily designated) through the Leeds Habitat Network which is shown on Map 18 and referred to in Policy G9 in the Core Strategy. It is important that the Leeds Habitat Network is publicly available, however maps within Local Plans remain static, representing a snapshot in time, and become out of date as the network changes over time.

Policy aims

• provide robust and comprehensive protection of sites and species recognised for their wildlife and geological significance
• clarify existing policies and provide rationale for potential change

It is considered that existing Core Strategy Policy G8 on nature conservation designations and species is effective at protecting habitats and species and if revised, would only require minor changes.

Proposed policy options

Future policy options could include:

• updating outdated terms (including the categories of protected sites), references and documents so the policy is more relevant and applicable
• adding more explicit provision for monitoring, review and updating in the policy
• reviewing Map 18 and considering how updated versions can be made more easily available

Biodiversity

Background

Biodiversity is the term used to describe the amazing variety of life on Earth. The National Trust described biodiversity as ‘Big Nature!’. Biodiversity has a huge role in helping us live healthy and happy lives; it provides us with food, raw materials, medical discoveries and what are called ecosystem services. There are also many and varied benefits provided by the natural environment and from healthy ecosystems such as natural pollination of crops, clean air, a supply of oxygen, clean water, extreme weather mitigation and human mental and physical well-being, recreation and even tourism.

The Earth’s biodiversity is in decline due to human activities such as deforestation, land-use change, agricultural intensification, over-consumption of natural resources, pollution and climate change. A report from the Intergovernmental Science Policy Platform on Biodiversity and Ecosystem Services (IPBES) in 2019 stated that nature is declining globally at rates unprecedented in human history and the rate of species extinctions is accelerating. The report contains some hard-hitting statistics including:

• 75% of global environments (excluding marine) have been “severely altered” to date by human actions
• there has been a 47%: reduction in global indicators of the range, scope and condition of ecosystems against their estimated natural baselines, with many continuing to decline by at least 4% per decade
• more than 85% of wetlands present in 1700 had been lost by 2000. Wetland loss is currently happening three times faster, in percentage terms, than forest loss
• up to 1 million species are threatened with extinction, many within decades
• more than 500,000 (+/-9%) of the world’s estimated 5.9 million terrestrial species have insufficient habitat for long term survival without habitat restoration

The IPBES report brings sharply into focus the global scale of the destruction of the natural environment and the catastrophic effects this is and will increasingly continue to have on our lives. Biodiversity and climate change are inextricably linked through the intrinsic balance of nature and ecosystems therefore a significant change in biodiversity will inevitably have an effect on climate.

Whilst we haven’t seen large scale destruction of rainforests in Leeds, we are seeing incremental loss of our indigenous natural environment through habitat destruction and a resulting loss in biodiversity. It is therefore important that we protect the variety of life locally but also reverse the trend of losing biodiversity and achieve improvements through “biodiversity net gain”.

The Environment Bill contains a target of a minimum 10% net gain which, subject to any revisions as the Bill progresses through parliament, is expected to become law in 2021. Developments will then be legally required to deliver a 10% gain for biodiversity. 

Defra’s Biodiversity Metric is the nationally recognised tool to measure and quantify biodiversity on sites and will be used to assess initial biodiversity, guide measure to deliver an improvement and assess the resulting biodiversity to ensure adequate gain is achieved.

There is scope for biodiversity improvements to be delivered on different sites to where development is located and details of these will be embedded in Conservation Covenants (agreements with landowners to deliver the enhancement and management for a minimum of 30 years).

The council will have a duty to show where on-site and off-site Net Gain is being delivered and ensure this is achieving the required biodiversity gains and contributing to the Government’s Nature Recovery Network. Furthermore, it will need to produce a Local Nature Recovery Strategy (LNRS) which will consist of a “Habitat Map” (Leeds Habitat Network Map) and “Statement of Biodiversity Priorities”.

Policy aims

• to strengthen the requirement for improvements in biodiversity and set a required percentage level of gain
• to clarify the use of recognised methods to assess and determine levels of biodiversity
• to provide a robust policy basis for the delivery of schemes, projects and programmes that will improve biodiversity

Existing policies and rationale for potential change

The council has required developments to deliver a gain for biodiversity since 2014 through Core Strategy Policy G9 and first identified the Leeds Habitat Network on Map 18 – see nature conservation section. Policy G9 is a valuable policy and establishes the need for development to deliver a net gain in biodiversity. However, the declaration of the climate emergency, the contents of the Environment Bill, the Government’s 25 Year Environment Plan and the greater focus on nature close to where we live due to COVID-19 has emphasised its importance and required us to consider whether we need to be more ambitious and explicit in the levels of biodiversity gain required through development.

Possible approach

Whilst the elements of the Environment Bill are not legally binding yet, the council welcomes the introduction of a clear mandatory requirement of at least 10% biodiversity gain on development sites and is looking to introduce specific quantifiable requirements in policy. We must be mindful that any figure will have to be fully justified by robust data and evidence to show it is appropriate, proportionate and deliverable.

There also needs to be a system in place to ensure improvements to biodiversity are actually delivered on the ground in the right place, whether that is on development sites or elsewhere where ecological opportunities and benefits can be maximised. 

Planning policies need to provide a “hook” of key requirements and criteria and set out clearly how biodiversity issues should be considered during the determination of a planning application, supplemented by guidance. 

A Strategic Local Nature Recovery Strategy for West Yorkshire could be a key mechanism for effective and successful improvements if there was a link between the planning process and delivering biodiversity off development sites. We will continue to think how best we can do this though your ideas and suggestions would be most welcome.

Whilst biodiversity net gain is an extremely valuable mechanism to improve biodiversity, planning policy and guidance can use many other ways to reverse the loss of natural habitats and biodiversity such as protecting regionally, nationally and internationally important habitats is covered previously. But we’d like to consider revised policy for those important areas which don’t meet the criteria for special protection.

Using a % net gain on sites which already have a low level of biodiversity will not result in noticeable improvements therefore we’d like your views on how the protection and improvement of the range of habitats, flora and fauna can be at the heart of development proposals through a focus on nature and ecological considerations in scheme layout, design and details, including infrastructure and the use of “green” products and technology.

Further consideration should also be given to our approach to biodiversity off-setting. Biodiversity off-setting is a system whereby if one area of natural space is lost to development, another area is created or restored for wildlife with the aim for an overall biodiversity gain. This means economic activity can occur and the environment can continue to flourish.

Proposed policy options

Policy options for biodiversity could include going beyond the provisions for biodiversity net gain within the Environment Bill and setting more ambitious targets for net gain.

Alternatively the authority could choose to retain its existing approach, either based on the benefits of the existing policy approach or the expected provisions of the new Environment Bill.

Local food production

Background

Local food production is an important part of Green Infrastructure because it helps deliver many of the benefits of GI (e.g. for biodiversity and well-being). It is also an important part of cutting carbon in its own right because the travel and processing associated with food generates lots of carbon emissions. Indeed food is one of the biggest contributors to our individual carbon footprint. It is for this reason that the Leeds Climate Commission have concluded that growing food locally and reducing food waste are important steps in becoming a zero carbon city. Food growing can be on a commercial scale i.e. through farming, and on a local community scale, such as allotments.

From a commercial perspective the Government’s 25 Year Environment Plan notes that the UK needs to optimise sustainable national food production for both the climate agenda and also to respond to Brexit and make the UK more self-sufficient.

They note that this can be done through improved land management and that “Agritech developments can significantly improve farm performance, in terms of both profits and the environment.” They note that this can be achieved through more intensive horticulture, such as polytunnels in the countryside.

Researchers from the University of Leeds recommend that Leeds can also make better use of brownfield sites for vertical farms (agritech farms which use modern techniques to grow food indoors).

From a community perspective throughout the Big Leeds Climate Conversation local food production was a prime consideration. Growing food was the 5th most popular pro-environmental behaviour change that respondents would make, but say that barriers prevent them.

Researchers from the University of Leeds recommend identifying and making better use of urban green space including parks, housing, ex-allotment sites and allowing meanwhile uses (which means temporarily using proposed development sites to grow food; possibly in containers).

The Town and Country Planning Association specifically advocates more community food growing. They define community food growing as “the cultivation of land by groups based on residential estates, faith premises, places of employment, schools or within neighbourhoods.” There is a history of this within Leeds with places like Meanwood Valley Urban Farm – a larger community farm which also employs paid workers and organisations such as Feed Leeds, (a local version of the national Incredible Edible project) involved with sustainable local food.

Policy aims

Whilst there is already considerable enthusiasm and commitment to grow food locally the planning system can help remove barriers, such has lack of access to suitable land and through its wider Green Infrastructure policies. The proposed policy aim for local food growing are as follows:

From a commercial perspective it is important to be positive about commercial food growing so that investors know that Leeds will welcome innovation and development of the food growing sector.

Existing policies and rationale for potential change

The current Local Plan policies set the framework for Green Infrastructure and notes in paragraph 2.38 of the Core Strategy that:

However, a focus purely on allotments for growing food is considered to be too narrow, given the wider opportunities that are available and in line with a more detailed approach on Green Infrastructure policies need to be more explicit and recognise that food growing can occur on land other than allotments.

In terms of commercial agritech food growing opportunities the current Local Plan identifies over 400 ha of land for general employment, which would allow for vertical farming on allocated employment land and on other brownfield urban land which was not allocated for other purposes. But it is important to note that commercial agritech food growing may also be acceptable in the countryside too. 

The NPPF requires that “Planning policies and decisions should enable… the development and diversification of agricultural and other land-based rural businesses” and it also allows buildings for agriculture in the Green Belt.

Catch (Ark), Hovingham Avenue, Harehills – Community project with community garden

Possible approach

It is proposed that at this initial stage the plan needs to set a positive framework for local food growing and provide more detail on how this can be achieved within a revised approach to protecting, managing and providing new Green Infrastructure and local place-making policy approaches being advocated elsewhere in this Local Plan update. The Local Plan update could therefore provide policies that:

• protect existing community food growing spaces
• support the provision of new community food growing spaces in or near existing housing estates
• encourage the temporary use of vacant sites and land awaiting development
• require the incorporation of community food growing space in new residential developments as part of Green Infrastructure delivery
• require all development to incorporate measures that will contribute to on-site sustainable food production as part of Green Infrastructure delivery
• include community food growing in open space assessments and strategies in their own right, distinct from consideration of allotments

Aside from strategic support for local food growing it is considered that there are fewer opportunities to amend or set detailed policies for commercial food growing at this stage of the Local Plan update and that the current policies are not restrictive.

However, it is considered that when employment land policies and employment allocations are updated in the future, the agri-tech food sector should be specifically considered, potentially through the allocation of specific sites for this purpose. To do this now, would also necessitate a wider look at all employment sectors as to ensure that all sectors were considered in the round. This would not align with a focussed scope of the Local Plan update for the climate emergency.