Examination of Witnesses (Questions 660-679)
SIR MARTIN DOUGHTY, SUE COLLINS AND JONATHAN PRICE
WEDNESDAY 1 MAY 2002
660. Are you saying that it will damage the environmental sites in its present form?
(Sue Collins) I think our concern is that the combination of planning decisions taken over the next decade or two should be appropriate for the environmental capacity. There are real questions as to whether the UK, which is a very crowded island with very fragmented environmental resources, can stand the total load of development. That is why we have asked for a national look at spatial strategy as well as regional spatial strategies. Because if you just consider everything case by case then the result could be that we have greater fragmentation of the countryside, we have too great a load on the ground water system, we have insufficient attention to biodiversity and insufficient attention to sustainable water, energy and land use. There is a real question about the total load of development.
661. The Minister Lord Falconer has given an agreement that there should be a statutory objective in the planning system which will cover sustainable development. Does that not satisfy you?
(Sue Collins) It depends whether it sufficiently respects environmental capacity. The devil is in the detail, is it not? There are many interpretations to sustainable development and there is a tendency to choose the sustainable growth
662. What do you think the Minster should do to give you satisfaction?
(Sue Collins) He should have a statutory purpose for planning which has a very strong reference to sustaining environmental quality and recovering it as a key element of sustainable development.
663. There is statutory agreement or the proposal that there will be a cover for sustainable development. Is that not what you are looking for?
(Sue Collins) We have no problem with that, provided the interpretation is sufficiently strong.
664. Can the shorter focused plans referred to in planning procedure at local level effectively protect the natural environment?
(Mr Price) I think they can provided the criteria are strong enough. It appears that the objectives are for local development frameworks which are quicker to adopt and implement. I think we have no quarrel with that. I think our concern is that if those policies could be changed too rapidly to entertain shorter term political objectives we would then be concerned that the environment might be at risk. Provided that the criteria are firmly stated, then I think our concerns are less.
665. In your evidence you do say that the map-based allocations should apply to all protected wildlife and landscape designations. Is that not cherry picking?
(Mr Price) Not really, no.
666. Is that not asking for preference?
(Mr Price) I think we are asking for that because these areas are geographically defined and so we think they need protection of map-based allocation.
667. Also English Nature having the right to make specific requests does not have to apply to any other organisation?
(Mr Price) Where there is an area of land which needs protection and it relates to a geographical designation, it is fair that that should be included in a development plan and be map based. I think that helps the public and politicians understand what the plan is seeking to achieve.
668. If we get a number of organisations, including English Nature, asking for some preference in the outline, does that not scrap the whole process of new planning procedures?
(Mr Price) I think not. There is room to cover major environmental concerns relating to a geographical area without making a plan over-complex and overlaid.
(Ms Collins) There is a national policy that Sites of Special Scientific Interest should be protected and all we are saying is that in the local plan people should be aware of where these sites are.
669. Are you just saying sites of special scientific interest should be protected or are you wanting to have protection for things below that level?
(Mr Price) We would prefer county wildlife sites and non-statutory sites to be map based so that developers can see the sort of environmental considerations that might pertain to the area they are considering developing.
670. Would that not delay the procedures?
(Mr Price) I think not. If there were a capacity within local authorities to deliver all this detail, I do not think that is a delaying element in the local plan process. The delay comes with the politics and the arguments and the legal battles over housing allocation and those sorts of things.
671. What you are saying is that people should have a right to look at the development framework and make their views known on protecting special sites of interest. If that is right, are you prepared to live with the slow process of planning procedures?
(Sir Martin Doughty) We are not necessarily saying that that slows the process down. We accept that there are delays in the process. They vary between authorities and between consultees and that is an issue that needs to be addressed. I do not think that should necessarily reduce the quality of decision-making. We say the quality of decision-making needs to have consideration of these environmental factors.
(Ms Collins) The point is if you have an agreed map which shows you where the environmental assets are, then there is clarity for developers and others. The decisions about whether the development can go ahead are then made in accordance with the policy framework laid down by the national policy statements and the regional strategies. It could speed up the planning system if we get this basic information in there eg. what is a flood plain, et cetera.
Mr O'Brien: The operative word in your comment is an "agreed" map and getting to that stage can be a very difficult process.
672. The basic information does not come to light until somebody does an environmental impact assessment of an area and suddenly discovers that a particular type of newt is on the land.
(Ms Collins) Information is coming forward, yes.
673. The Welsh Assembly is preparing a national statement strategy which is looking at environmental, economic and social factors as well as land use. Is that the answer?
(Sir Martin Doughty) It sounds like the appropriate way forward. Sue may want to add to that.
674. Have you been involved in that?
(Ms Collins) Not specifically but our sister agency for Wales will have been involved in that.
(Sir Martin Doughty) We will certainly have a look at it now!
(Ms Collins) We need to look not just at individual sectors like ports and roads and coastal flood defences. In fact, the Government needs to look cross-sectorally at all these uses of land and decide on how much you can have multi-functional land use and how much you need to reserve certain types of land for certain types of development. If you build houses and put concrete down that is an irreversible loss of environmental capacity. In other cases you can have multi-purpose land use where you can integrate environmental assets and those kinds of considerations within the development. The other thing about a national strategy is to see how you can translate sustainability principles into practice. Taking a long-term view is an important sustainability principle; so is precaution and prevention of damage and also considering the effects on air, water and soil environments. All those considerations ought to inform the national policy statements for major infrastructure and for national planning guidelines. We think a debate about that would be very valuable.
675. You referred earlier to the forthcoming White Paper on regional assemblies in England. Do you think that directly elected regional assemblies would ensure that environmental issues as well as economic issues were covered on regional strategies?
(Sir Martin Doughty) I do not think we are qualified to answer that question. I was putting our comments on the regions into context because clearly there is an issue of democracy. In the planning system we have at the moment the statutory parts of it are done by democratic local authorities. If you had statutory regional planning guidance then I think most people would say that should preferably be produced by something that had the maximum of democratic involvement, and if there is to be a tier of regional government that would be an appropriate move forward with that. Whether that would then lead to a greater consideration of environmental factors, I do not think we are qualified to say.
676. Are you concerned that regional strategy statements produced in the current system would give undue emphasis to economic factors at the expense of environmental ones?
(Sir Martin Doughty) I think we are. In a sense the regional development agencies are the furthest advanced in terms of moving things to regional decision-making and so it is very important that the regional economic strategy which the RDA has responsibility for is set within an overall sustainable development framework at regional level. The East Midlands model is quite a good one where the regional economic strategy alongside regional environmental and social-type strategies are set within an overall integrated framework. At the side of that is the spatial strategy and it implements on behalf of all the elements of sustainable development and does not cherry pick economic factors.
677. Do you think the regional strategy statements proposed in the Green Paper will be effective or will they undermine the current practices such as the one you describe?
(Ms Collins) One of the issues is how much ecological and environmental expertise is available at the regional level. In the current RDAs it needs to be strengthened. It is all to play for. It could be very good. We need strategic thinking and we need environmental knowledge to be applied to the process. I would like to see strengthened arrangements for that. The system is under-resourced as it recognises in the Green Paper. It is under-resourced in its access to environmental expertise.
(Sir Martin Doughty) It would be fair to say that environmental expertise in the regions is there because the organisations who have provided it have wished to be involved. So it is often the county councils and agencies like ourselves, the Environment Agency, who have contributed to that. It needs to be a much stronger relationship if we are to have strategy guidance in the way that the Green Paper is proposing.
678. What about action plans? In your written evidence you seem a bit ambivalent. You express certain concerns and then you say that topic-based action plans are a potentially effective way of promoting local biodiversity action plans. Could you tell us how you see action plans?
(Mr Price) Our basic concern is the local development frameworks will involve a smaller tier below, and there are possibilities that this will complicate the system. We are also slightly concerned that action plans might be chopped and changed very rapidly without proper consideration of environmental factors. But provided action areas relate to areas of economic regeneration, I do not see that as one of our main, principal concerns. We are worried that action plans should not be bussed in overnight without any environmental considerations fully addressed.
679. Have you got any specific proposals on how you would like the recommendations on the action plans to be changed?
(Mr Price) I think the action plans clearly have to link in with the criteria of the overlaying developmental framework, so they must respect the environmental policies cemented within the criteria. Provided that is the case then we would be less concerned.