Memorandum by the Woodland Trust (PGP
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 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."
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.
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
operatethe 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 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.
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.
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.
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."
28 Welsh Government (2001) Planning: Delivering for
Wales, para 24. Back
Urban Task Force (1999) Towards an Urban Renaissance, p.43. Back