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Last edited 16 Jan 2026

Environmental Audit Committee. Environmental sustainability and housing growth: Sixth Report of Session 2024-26

[edit] Summary in brief

On 16 November, 2025 the Environmental Audit Committee published its Sixth Report of Session 2024-26 "Environmental sustainability and housing growth", key elements of the report are outlined below and the full report can be accesses via the hyperlinked image. The report is a House of Commons committee report, which contains recommendations to the government, the Government is given two months to respond to its contents..

The report argues that England can meet its target of building 1.5 million homes while still honouring its legally binding commitments to restore nature and cut carbon, but only if major systemic problems are fixed. It warns that current planning and environmental policies are not strong or coherent enough to halt nature’s decline by 2042, and that large-scale housebuilding carries significant carbon impacts unless embodied carbon, retrofit, and material choices are properly addressed. Across legislation, planning policy, cross-departmental coordination and data-sharing, the report finds misalignment, weak implementation, and risks of diluted environmental safeguards, especially through Environmental Delivery Plans, the Nature Restoration Fund, and changes to the mitigation hierarchy.

It highlights early problems with Biodiversity Net Gain, insufficient protection for green/blue infrastructure, and the absence of enforceable standards for whole-life carbon in the revised NPPF. The report emphasises that retrofitting and repurposing existing buildings could make a major contribution to housing supply with far lower carbon costs. It notes that there is a balance between empty houses and the housing targets but tax incentive push towards new build rather than reuse and refurbishment.

Finally, it identifies critical skills shortages in ecology, planning, construction and at Natural England, arguing that without investment in expertise and capacity, even well-designed policies will fail. Overall, the report concludes that meeting both housing and environmental goals is achievable but urgently requires stronger governance, better data, and serious commitment to the recommended reforms.

[edit] Introduction

England faces a substantial housing challenge while simultaneously being legally committed to reversing nature loss and cutting carbon emissions. The Government’s ambition to build 1.5 million homes this Parliament is presented alongside its environmental duties under the Environment Act 2021 and the Climate Change Act 2008. It is emphasised that housing and environmental goals do not have to conflict, but achieving both requires coherent policy, good data, and capacity across government.

[edit] Policy and governance

This chapter explores how well the planning and environmental governance frameworks align to deliver both housing growth and nature/climate objectives. It examines the legislative backdrop (including the Environment Act), how different departments work together, how data is shared, and how the revised National Planning Policy Framework (NPPF) fits. The chapter finds significant gaps in coordination, data fragmentation and policy misalignment that risk undermining the twin aims of nature recovery and housing delivery.

[edit] Legislation

Outlining the legislative foundation for environmental obligations in England, notably the Environment Act 2021 it reiterates the legally binding targets for biodiversity and the mandated Ministerial duty to apply environmental principles. It finds that although the legal framework is strong, transparency and full implementation remain weak.

[edit] Cross departmental working

The intersecting responsibilities between housing, planning and environment departments (e.g., MHCLG, DEFRA) require strong coordination. Evidence shows that while such structures exist, decision making remains fragmented, undermining joined up delivery of housing and nature objectives. The lack of unified, up‑to‑date geospatial and ecological data hampers strategic decision making. Witnesses stressed that siloed systems mean local authorities and regulators cannot access shared datasets, limiting efficiency and undermining nature recovery and housing alignment.

[edit] NPPF Presumption in favour of sustainable development

The December 2024 revision of the NPPF, which included changes to the ‘presumption in favour of sustainable development’ is of some concern. The revised wording lowers the bar for refusing developments and may tilt the planning system too far towards housing market delivery at the expense of nature protection.

[edit] Spatial planning

The interlinks between land use strategy, regional planning, spatial development policy and environmental and housing goals. The report suggests that current spatial planning lacks coherence and integration with nature recovery frameworks, risking less successful outcomes potentially missing targets.

[edit] Environmental Protection

Key policies such as proposed Environmental Delivery Plans (EDPs), the Nature Restoration Fund (NRF), the Mitigation Hierarchy, and the mandatory Biodiversity Net Gain (BNG) are reviewed. and ensuring robust protections for habitats and species. It warns that there is a tension between speeding up housebuilding and policy that creates environmental safeguards in housing delivery, and that some policy changes may reduce environmental safeguards unless they are carefully managed.

[edit] Environmental Delivery Plans (EDPs)

The proposed EDPs under the Planning and Infrastructure Bill would allow strategic area based conservation measures paid for through developer contributions via the Nature Restoration Fund (NRF), which aims to replace site‑by‑site mitigation. While this is praised for its potential efficiency gains, stakeholders fear they dilute local ecological requirements and allow developers to buy out on nature obligations.

[edit] The overall improvement test

The overall improvement test, is where a delivery body must show an improvement before an EDP is approved. The government has said that "the government has always been clear that it is one of the key environmental safeguards in the new system and, as such, it is vital that there is confidence in its operation." The report finds that the test’s wording is weaker than existing habitat regulations, potentially allowing greater subjectivity and diminishing protections for nature.

[edit] The Nature Restoration Fund (NRF), and Natural England

Nature Restoration Fund (NRF) is described as a central fund into which developers can pay rather than mitigate on‑site, and Natural England will be responsible for delivery. The report raises concerns about conflict of interest, oversight, and incomplete impact assessment, especially since the NRF currently focusses primarily on nutrient neutrality and lacks detailed metrics for other habitats.

[edit] The Mitigation Hierarchy (MH)

A recap of the traditional mitigation hierarchy is given (avoid → minimise → restore → compensate), then it is explained how the Bill proposes a more flexible application, removing the mandatory site‑specific assessments. Stakeholders worry this change weakens the principle and increases risk to protected habitats.

[edit] Biodiversity Net Gain (BNG)

The policy requiring a 10% net gain in biodiversity value for developments is discussed and early‑stage problems are identified. Such as inconsistent monitoring and enforcement, risk of simpler habitats being used to meet targets, and uncertainty over the long‑term management of gains.

[edit] Green and blue infrastructure

The importance of multifunctional green and blue spaces in housing schemes is emphasised; parks, ponds, tree cover etc for biodiversity, flood resilience, health and wellbeing. While the NPPF encourages them, it is argued that stronger, mandatory standards are needed.

[edit] Sustainable construction

The climate impacts, embodied and operational carbon from housing construction and use are examined and how whole‑life carbon assessments, material choice, retrofit of existing buildings, and new brownfield versus greenfield decisions impact emissions. It argues that unless embodied carbon is better addressed, the new homes programme may conflict with the UK’s legally binding carbon reduction targets.

[edit] Embodied and operational carbon

This section defines embodied and operational carbon emissions from housing: embodied from materials and construction, operational from building use. The scale of the issue is highlighted highlighting that building 1.5 million homes could release over 80 MtCO₂e, making this a key barrier to meeting carbon budgets.

[edit] Embodied carbon and the NPPF

This part shows that although the revised NPPF says planning should support net‑zero, it fails to reference embodied carbon explicitly. Stakeholders view this omission as a missed opportunity to strengthen carbon regulation and drive retrofitting and low‑carbon materials.

[edit] Alternative building materials

This subsection explores some other less common building materials (timber, hemp, clay) as being ways to reduce embodied carbon. It points to examples of modern methods of construction and government roadmaps (e.g. Timber in Construction) but notes that incentives and regulatory drivers remain weak.

[edit] Demolition and retrofit

Here the case is made for prioritising retrofit and reuse of existing buildings rather than demolition/new build. The report shows that retrofit typically emits only one‑third of the embodied carbon of new builds, it highlights various studies that indicate that between 1.5 and 1.6 million homes in England are unoccupied, which is higher than the MHCLG estimates of around 720,000. This potentially balances with the government's own target of 1.5 million homes, with Historic England estimating that repurposing existing buildings, such as commercial properties and historic buildings, could create 670,000 homes.

Together, these figures highlight the potential role that retrofitting and adapting existing buildings could play in meeting targets. It goes on to say that is is contrary to the Government’s environmental objectives to incentivise carbon-intensive new building over the re-use of existing sites and that VAT on retrofit projects should be reduced from 20% to reflect environmental benefits, supporting uptake and that properties brought back into use could count towards a local authority’s housing target.

[edit] Skills and Resourcing

The final chapter examines whether the planning, ecology, and construction workforces have the capacity, expertise and resourcing to deliver the reform agenda. It identifies shortages of ecological expertise, skills gaps in planning and construction professions, and the risk that even well-designed policy fails without the right people and infrastructure.

[edit] Ecology (Skills and Resourcing)

In terms of the availability of ecological expertise to deliver nature recovery policies, the report finds shortages of trained ecologists, uneven availability across regions, and insufficient capacity in local recording centres, all of which undermine nature protection in housing development.

[edit] Planning (Skills and Resourcing)

Planning professionals currently, often inadequately integrate ecology and nature into housing decisions, the report highlights under resourced planning, limited training in ecology for planners, and risks to nature aswell as housing targets.

[edit] Construction Skills

In terms of the workforce needed for sustainable housing delivery, such as low‑carbon building techniques, retrofit skills, MMC and so on, unless the skills base is strengthened, policy ambitions will falter despite good intention with regulation.

[edit] Natural England

The report raises concerns about the resourcing of Natural England in the regulatory and delivery ecosystem, indicative dual roles under new policy (regulator and implementer), and whether it has the capacity and independence to support the twin goals of growth and nature protection.

This article is a precis of the House of Commons publication "Environmental Audit Committee. Environmental sustainability and housing growth: Sixth Report of Session 2024-26" for full details follow the link.