Select Committee on Transport, Local Government and the Regions Memoranda


Memorandum by the Woodland Trust (PGP 45)

THE PLANNING GREEN PAPER

  The Woodland Trust welcomes the opportunity to contribute to this inquiry. The Trust is the UK's leading charity solely dedicated to the conservation of native woodland. We achieve our purposes through acquiring woodland and sites for planting and through advocacy of the importance of protecting ancient woodland, enhancing its biodiversity, expanding woodland cover and increasing public enjoyment of woodland. We own over 1,100 sites across the country, covering around 18,000 hectares (45,000 acres) and we have 250,000 members and supporters.

THE EFFECTIVENESS OF THE SYSTEM OF LOCAL PLANS AND THE GOVERNMENT'S PROPOSALS TO REPLACE THEM:

  The effectiveness of the local plans system at present is extremely variable. The Trust would like to see all local plans include strong policies to protect the environment, especially ancient woodland (land that has been continuously wooded since at least AD1600) and we have found in a recent survey of local authority policies that some protect this habitat absolutely from development while other authorities with significant areas of ancient woods provide little or no protection.

  We agree with the Government that the system is too slow with local plans taking years to produce, however we believe that the proposals go too far with too much emphasis on streamlining the system for the benefit of business development and with little concern for the environment. We would like to have seen the Government consider other options for reform of the local plan system, such as those proposed by the Welsh Assembly Government which involve reform of the unitary development plan system by introducing new style local development plans which would "include the benefits of a more streamlined content and process whilst minimising the disruption and uncertainty caused by introducing a completely new system of development plans."[28] These plans would be shorter and more focussed than current UDPs but would still maintain a more comprehensive approach to planning than that being proposed in England.

  The system proposed in the Green Paper would be at least as complex as the current local planning system. At present there are three levels of planning in unitary authorities: Planning Policy Guidance, Regional Planning Guidance, Unitary Development Plans, and four levels of plans in district councils' areas: Planning Policy Guidance, Regional Planning Guidance, Structure Plans, Local Plans. The proposed system could in fact lead to up to seven different levels of planning with there being four different types of action plan possible in an area covered by Local Development Frameworks. For example there could be Planning Policy Guidance, Regional Spatial Strategies, Local Development Frameworks, Area Master Plans, Neighbourhood Village Plans, Design Statements, Site Development Briefs that all apply in one area. This does not imply a streamlined system; it is at least as complex as the current system and would probably lead to far less certainty.

THE ROLE OF REGIONAL PLANNING BODIES:

  Before strategic planning is moved from county to regional level (as proposed), the resulting democratic deficit arising from regional bodies currently being indirectly elected or appointed must be addressed. We are disappointed that a Regional White Paper has not been published at the same time as these proposals as the complexion of the regional tier will be crucial in achieving legitimacy for the new planning proposals. It is also very unclear how the regional/sub-regional/local planning relationship would operate—the proposed arrangements leave a large gap between the regional strategic planning tier and the local planning tier. This will serve to reinforce the feeling that planning is remote, especially in relation to housing allocations.

  Regional planning bodies have an important role in setting the planning agenda for a whole region, especially in terms of environmental protection. Sustainability must lie at the heart of the planning system and this includes Regional Spatial Strategies. We strongly believe that any new regional structures should have a duty to promote sustainable development in a similar fashion to the Welsh Assembly's duty. The natural environment often crosses local authority boundaries and regional planning bodies should take a broader landscape scale perspective on environmental protection to ensure that key regional environmental assets are effectively safeguarded from development.

THE PROCEDURES FOR SCRUTINISING MAJOR DEVELOPMENT PROJECTS:

  The proposals for approving major infrastructure projects through Parliament will mean that complex decisions about these projects may be made against a backdrop of short term political considerations and pressures rather than via real in depth analysis of sustainability issues such as community impact, economic gain and environmental impact. This would, in effect, turn Parliament into a planning body with significant timetabling implications, and if the proposals were to go ahead we believe that there must be a clear commitment that votes on major infrastructure projects will not be whipped, applying the same rules to the national planning body as apply at a local level.

BUSINESS PLANNING ZONES:

  The Woodland Trust is opposed to the proposals for creating business development zones. Creating more zones where development is given a free reign undermines the principle of a plan led system and risks damaging valuable environmental assets since it is extremely unlikely that all business planning zones will be placed in locations where they have no environmental impact. If this approach were to be adopted, it is essential that strict environmental standards be introduced, along with a requirement for any such development to be on brownfield land. We are disappointed that the Green Paper makes no reference to this.

WHETHER THE GOVERNMENT'S PROPOSALS WILL SIMULTANEOUSLY INCREASE CERTAINTY, PUBLIC PARTICIPATION AND FASTER DECISIONS, PARTICULARLY FOR BUSINESS:

  Far from increasing certainty, we believe that the proposals for local development frameworks will in fact lead to greatly increased uncertainty. The idea that greater certainty will arise from local plans that no longer include comprehensive policies for all areas of a district is far from convincing. We are particularly concerned that important environmental assets such as ancient woodland will be subject to increased pressure from development because it will not necessarily be clear in Local Development Frameworks whether development will be permitted. This will serve to increase uncertainty and confusion not just for environmental bodies but for business too, as there will be no way of knowing what will or will not constitute appropriate development in certain locations.

PLANNING'S CONTRIBUTION TO THE URBAN RENAISSANCE:

  The planning system has a crucial role to play in delivering the "urban renaissance", and delivering sustainable development, but we feel that the Government fails in the Green Paper to address the issue of how the planning system can be used to create a better environment. Above all there must be protection in urban areas of those habitats that are irreplaceable and are of cultural and environmental importance such as ancient woods and ancient and mature trees. Central to the urban renaissance is a high quality natural environment, green areas are generally regarded as more desirable and a high quality environment helps to encourage inward investment in an area by making it attractive to business. The planning system should actively promote the value of green space in urban areas rather than including environmental protection and enhancement as an afterthought. As the Urban Task Force's final report stated the system should:

    "promote the idea of the ecologically sustainable city in which humans recognise that they cohabit with nature. Trees, woodland and other open space are all important in fostering biodiversity, in enhancing human health and well-being and in reducing noise and pollution."[29]

Ed Pomfret

James Cooper

March 2002



28   Welsh Government (2001) Planning: Delivering for Wales, para 24. Back

29   Urban Task Force (1999) Towards an Urban Renaissance, p.43. Back


 
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