APPENDIX 5
Supplementary Memorandum from Council
for the Protection of Rural England
A RESPONSE BY CPRE TO THE OVERARCHING TERMS
OF REFERENCE OF THE COMPREHENSIVE SPENDING REVIEW
INTRODUCTION
1. CPRE welcomes the opportunity to contribute
to the Government's Comprehensive Spending Review (CSR) and to
examine afresh the role and purpose of Government Departments'
policy and expenditure. We have a longstanding interest in the
machinery of Government and its effectiveness in delivering environmental
objectives.
2. The Review is especially important for the
newly integrated DETR in a new Government which has clear manifesto
commitments for integrating the environment in all aspects of
its policy: "The foundation of Labour's environmental
approach is that protection of the environment cannot be the sole
responsibility of any one department of state" . . . "We
will put concern for the environment at the heart of policymaking,
so that it is not an add-on extra but informs the whole of government,
from housing and energy policy through to global warming and international
agreements . . . All departments must promote policies to sustain
the environment."
SUMMARY
3. Our submission on this aspect of the Review
focuses on the structure and operation of the DETR itself. We
are making other submissions on particular elements of the review
within the DETR which are summarised in Annex II. Although we
believe new environmental policy instruments in the form of additional
regulation, new laws, changes in policy direction, more widespread
use of economic instruments and a redisposition of public expenditure
are required, and we summarise these below, we believe the Department
could also do much more within its own resources to advance the
cause of environmental integration.
4. The CSR provides an opportunity for a fundamental
review of the effectiveness of the Department's own structure
and organisation to the delivery of environmental objectives both
internally and externally and for moving towards new models of
development. This might take the Secretary of State's five key
priorities—integration, decentralisation, regeneration,
partnership and sustainability—as a guide. We believe this
review will reveal the benefits to be gained from a new Departmental
mission among the different Directorates, close integration of
their work and the need to address afresh important cross-cutting
issues such as rural policy or key processes such as land use
planning. Failures in each of these areas currently combine to
obstruct effective process towards regeneration and more sustainable
development. Strong political leadership on the environment will
also be important as a way of carrying forward cross-cutting issues
both within DETR and between different departments. The new Government
provides an opportunity to achieve these improvements.
5. In this context we welcome:
— the integration of the Departments
of the Environment and Transport and regional policy issues and
the additional leadership which is provided by having the Deputy
Prime Minister as Secretary of State. These are important moves
towards a more effective and influential Department; and
— the establishment of the Sustainable
Development Unit within the Department as an important signal
of the DETR's commitment to "greening" itself and the
Government as a whole.
6. Notwithstanding these important advances
the Department inherits a strongly vertically differentiated structure
and historic difficulties in working across functional boundaries.
While it is still early days, we have not yet detected sufficient
determination to tackle these internal obstacles to integration
so that conflicts of view and approach internally are removed
and the Department can focus on strategic, cross-Governmental
objectives.
OVERALL CHARACTERISTICS
OF AN
EFFECTIVE DETR
7. We identify three complementary characteristics
of an effective DETR:
— to be an examplar and model of integration
and working practices in all its internal operations, to effectively
address environmental considerations and move towards sustainable
development;
— to be a successful champion of the
environment within and across Government;
— to wield sufficient "clout"
and influence with other Government Departments and in Cabinet.
8. The central organisational aim of the CSR
for DETR should be to move towards a structure and organisation
which displays these characteristics and uses them to influence
Government as a whole and other key audiences. The case for this
can be made not only in terms of the threat to the environment
but also the wider advantages of moving towards different models
of development which meet economic and social need at a lower
environmental cost.
9. Our overwhelming impression, however, is
of a Department which is still failing to display these characteristics
and where conflicts of view and approach within the Department
and the lack of a shared vision or objectives are as serious an
obstacle as the more familiar problems of interdepartmental wrangling
with MAFF, the DTI or Treasury. Notwithstanding goodwill and strong
intent towards tackling some of these issues they are not yet
being consistently delivered in the Department's actions and outputs.
Some of the problems created by the current structure and organisation
are summarised in Annex I.
THE CASE
FOR PUBLIC
EXPENDITURE AND
INTERVENTION
10. We recognise that the CSR is to be based
on a zero-based review of expenditure and the need for public
policy intervention. We hope that we do not need to stress too
much the need for public intervention when it comes to environmental
and countryside policy. It is an absolute necessity. The environment
in general and the countryside in particular are "public
goods" par excellence where the market cannot be expected
to provide what society needs and where the externalities of market
decision need to be addressed.
11. That the environment and the countryside
is something that people care about and demand action is well
recorded. In a 1996 Gallup opinion poll the countryside was second
only to freedom in the list of concerns among the English people
and in a RSGB survey for CPRE in 1997 80 per cent. of those questioned
were worried about what sort of countryside the next generation
would inherit. Moreover it is important to recognise that public
concern about the environment can manifest itself in different
ways. Work undertaken by Opinion Leader Research for a group of
major environmental NGOS in February 1997 confirmed that "some
of the most motivating aspects of mainstream issues of voter concern
have a strong environmental sub text". It showed that
while many people do not spontaneously associate the environment
with electoral decision making it has a powerful appeal, "clearly
coming out of the shadows when people are asked to look to the
future" or when addressing issues which are not overtly
environmental, such as the quality of urban living. The environment
is also identified as "a very real problem" where
the Government has a vital role but also where greater public
involvement in decision is needed.
12. The way in which public intervention is
exercised can differ greatly. Much can be achieved through the
support of voluntary action and the provision of information and
advice but this is not enough. Legislation, regulation and public
policy and expenditure are all necessary to the effective delivery
of environmental objectives. And they cannot all be guided by
quantifiable measures or economic assessments. Some of the most
important attributes of the countryside—tranquillity, beauty,
local character—are essentially qualitative and cannot be
"valued" in a conventional sense. This does not mean
that they are not important and it is vital that public policy
recognises and responds to this in a way which means they are
not overlooked when decisions are made.
FUTURE DETR AIMS
AND OBJECTIVES
13. A starting point for our consideration of
the CSR was to look at the Department's current aims and objectives.
The first stated objective of the CSR is to "review the
Department's aims and objectives, the contributions they make
to the Government's objectives, and how the Department plans to
assess whether it is achieving its objectives". The preparation
of aims and objectives for the newly integrated Department will
be a vitally important process since they need to provide the
strong lead which will draw the Department's activities together.
We strongly urge that the new aims and objectives be prepared
in an open and consultative process, including inviting public
comment on drafts as occurred when the Department of Employment
and Education merged, and offer below some suggestions for issues
which might be addressed. One function of the new aims and objectives
should be to encourage more horizontal integration where individuals
in different sections of the Department identify with a large
number of them rather than focusing narrowly on a single aim which
relates to their work priorities. The process would also benefit
from a compelling and uniting overarching Departmental mission
for the whole DETR so that desk officers in all areas of work
felt united around a single objective relating to sustainable
development.
14. The new aims and objectives of the DETR
which might help guide future public intervention could include:
— support and recognition of the benefits
of urban renewal and liveable cities and the physical separation
of town from country;
— use of the planning system to promote
sustainable development and the management of natural resources;
— the safeguarding of rural land against
unnecessary development, making other uses such as agricultural
and forestry as environmentally responsible as possible, and recognising
the multiple benefits of farmland and woodland in addition to
their productive capacity;
— reducing demands for goods and services
(such as land, minerals, water, energy and soil) so they fit environmentally
sustainable levels of supply rather than expanding supply to meet
ever-increasing demands;
— supporting an efficient and effective
transport system which meets needs for accessibility rather than
mobility, encourages shifts towards less environmentally damaging
modes of transport and progressively reduces the need to travel;
— attaching value both to places of
national environmental importance and to the local environment
in which the common but environmentally and culturally vital elements
of life flourish and which contribute to the character and distinctiveness
of our environmental resources and the economic value of the countryside.
15. The separate CPRE submissions on detailed
aspects of the spending review within the DETR and other Departments
further explore these issues and we place particular emphasis
on the failures in relation to planning and rural policy. These
submissions, summarised in Annex II,[3]
also identify in more detail our priorities for introducing new
policy instruments as a complement to organisational reform of
the Department.
OUTCOMES OF
THE DETR CSR
16. In summary we believe that in responding
to these principles the CSR of the DETR should result in, inter
alia:
— new and compelling aims and objectives
for the DETR, including an overarching departmental mission focused
on sustainable development, which provide a clear sense of direction
and inspire commitment across all areas of its responsibility;
— organisational changes within DETR
which unite staff around this goal, albeit within vertically separated
directorates, and improved mechanisms for dealing with cross-cutting
issues, e.g., by early involvement of the Sustainable Development
Unit and a strengthening of its "policing" role and
the introduction of administrative procedures which require environmental
issues to be addressed;
— appointment of an Environment Minister
to the Cabinet;
— a set of environmental policy objectives
and targets in a new Sustainable Development Strategy to guide
decisions across different policy areas towards a common goal;
— regular external and expert assessment
of DETR and Government performance against the aims and objectives
of the DETR and the Sustainable Development Strategy, e.g., by
statutory Agencies and the parliamentary Environmental Audit Committee;
— a set of publicly resonant environmental
indicators to encourage and monitor change and move beyond conventional
measures of economic progress;
— recognition of the countryside as
an important cross-cutting issue and a clear and swift statement
of the Government's approach to rural issues, such as through
a new Countryside White Paper, which establishes objectives and
targets for rural policy and provides a focus for identifying
the rural implications of other policy decisions. A key priority
for the White Paper should be to maximise the benefits of current
EU agricultural and rural development policy reforms within England
and to explore the potential of a new, more integrated approach
to the countryside Agencies (focused on the Countryside Commission,
Rural Development Commission and the Farming and Rural Conservation
Agency) which better addresses rural issues together;
— an enhanced land use planning system
which is valued for its role in encouraging more sustainable patterns
of development, increasing the efficiency of decisions and reducing
conflict, securing wide public policy objectives (such as urban
renewal and countryside protection) from private and public investment
and integrating agricultural spending with other land use objectives.
Priorities for reform include an extension of planning policy
to embrace resource management, new forms of public involvement
and participative democracy and the selective extension of planning
controls. This can be achieved largely through PPG reviews, active
support for a new approach in the planning process and some legislative
changes;
— complementary support from a suite
of new economic instruments (such as a greenfield levy, harmonisation
of VAT on new build and conversions and charges on private non-residential
parking) which influence land use and development decisions and
new and strengthened measures to reduce the consumption of natural
resources and the generation of waste;
— a new direction for transport policy
which sets real targets for reducing traffic levels, establishes
new processes for looking at alternatives to road construction
and plans new development in ways which reduce the need to travel;
— a more integrated use of public expenditure
on housing and regeneration to aid urban renewal and land use
planning objectives as well as to increase the supply of affordable
homes;
— a strengthened, invigorated and more
integrated contribution from the countryside Agencies which combines
countryside protection, positive land management and appropriate
rural economic and social development with a more effective role
in advice and policy formulation. Consideration could be given
to the creation of an integrated agency for the countryside with
a modern and effective environmental mandate and objectives;
— a fresh commitment from the Government
as a major landowner to provide a model of and inspiration for
good practice in the sustainable use and integrated management
of land;
— a critical review of current public
expenditure programmes against environmental objectives. A number
of potentially wasteful programmes are summarised in Annex III[4];
— new environmental legislation to
strengthen countryside protection and the conservation of natural
resources, increase the effectiveness of the planning system and
strengthen environmental accountability and duties—a summary
of some of the most important areas for legislative reform is
attached in Annex IV[5].
October 1997
ANNEX I
EXAMPLES OF A LACK OF POLICY INTEGRATION
WITHIN DETR
THE LACK
OF INTEGRATION
OF HOUSING
POLICY WITH
ENVIRONMENTAL OR
LAND USE
POLICY
This is illustrated by the recent consultation
paper over the use of capital receipts which received only limited
circulation which did not include environmental or land use planning
groups despite the direct impact of the proposals on their interests.
The lack of integration with the Department's planning and regeneration
policies was also evident. The same criticism in reverse can be
levelled at the previous Government's Green Paper on household
growth which barely addressed the central question of affordable
housing and its environmental and social implications. Moreover,
the current CSR for housing policy almost entirely omits reference
to environmental or land use issues.
THE SEPARATION
OF WASTE
MANAGEMENT AND
WASTE PLANNING
Despite clear overlaps these two areas of work
are poorly integrated with the result that the contribution of
land use planning to resource management is frequently underestimated
and sometimes totally overlooked. There are similar problems in
relation to the management of water resources where land use and
development implications are still poorly addressed.
THE SPONSORSHIP
AND SUPPORT
OF THE
UK CONSTRUCTION INDUSTRY
This operates without making vital policy connections
with the Department's responsibilities for reducing the environmental
impact of construction and encouraging more sustainable patterns
of development and living. This can result in different arms of
the Department working in opposition to one another and inefficiencies
in the deployment of staff resources. Notwithstanding the question
of the appropriateness of the Department's sponsorship role for
construction, the mismatch between the £26.2 million Construction
Research Programme and the £2.7 million Planning and Minerals
Research Programme (1994-95) is stark and inappropriate.
THE HANDLING
OF CROSS
CUTTING ISSUES
SUCH AS
RURAL POLICY
AND LAND
USE PLANNING
The lack of purchase of rural policy questions
on some of the key challenges faced elsewhere in the Department
was brought to the fore by the previous Government's Rural White
Paper and is evident in the terms of the current CSR of rural
policy. It is unfortunately the case that the links between the
DETR's rural policy division and agricultural policy are in many
ways superior to the influence of rural policy objectives on issues
such as housing development, development plans or minerals extraction.
Equally disappointing is the lack of attention to land use planning
mechanisms for the delivery of policy objectives in other sections
of the Department. The scope for using development plans to reduce
demands for water and construction aggregates is just one example
of a lost opportunity in this area.
SUSTAINABLE DEVELOPMENT
UNIT
If the Sustainable Development Unit is to fulfil
its role in building environmental considerations more effectively
into departmental activity significant further changes will need
to be made. The Unit has made only a limited contribution to the
current review of transport policy and has not demonstrated any
purchase on the internal debate on the household projections or
planning decisions over development plans and individual planning
applications despite their huge environmental significance. We
are also disappointed that responsibility for the SEA Directive—which
provides one of the key instruments for delivering more sustainable
development—is not held by this Unit. The challenge outside
the Department is clear with only the DETR's CSR terms of reference
referring to sustainable development as one of the Government's
overarching objectives and repeated references to the aim of "sustained
economic growth".
ANNEX II
SUMMARY OF CPRE RESPONSES TO DETR SPENDING
REVIEWS
RURAL POLICY
(JOINT WITH
MAFF)
The countryside needs to be recognised as an
important cross-cutting issue and as a priority concern of the
Government where intervention is a necessity if the strong public
interest in the countryside is to be recognised. A clear and swift
statement of the Government's approach to rural issues, such as
through a new Countryside White Paper should be published, establishing
the Government's objectives and providing a context for policy
and organisational reforms. The evolving approach to rural development
in which economic, social and environmental issues are becoming
increasingly intertwined and in which some of the functions of
the Rural Development Commission may be absorbed by the new Regional
Development Agencies suggest the need to examine the potential
benefits of a new integrated countryside Agency reporting to MAFF
and DETR, bringing together the Countryside Commission, the Farming
and Rural Conservation Agency and parts of the RDC to provide
a more effective rural voice and demonstrate the Government's
rural commitment. The opportunities for making much better use
of agricultural spending for achieving environmental objectives
should be taken and all agricultural payments should be conditional
on meeting basic environmental standards.
ENVIRONMENTAL POLICY
Growing public concern about the environment
will require the introduction of stronger policy measures, including
new regulations and the greater use of economic instruments. A
new suite of economic instruments such as a greenfield levy and
charges on private non-residential parking should be introduced
which influence land use and development decisions and new and
strengthened measures are required to reduce the consumption of
natural resources and the generation of waste. The Government
should publish a set of publicly resonant environmental indicators
to encourage and monitor change and introduce new measures of
progress which address quality of life and environmental concerns,
moving beyond conventional measures of economic progress. Improved
Greening Government mechanisms and resource accounting which deals
with pan Government objectives are needed for dealing with cross-cutting
issues and Strategic Environmental Assessment should be introduced
into the policy making process.
PLANNING
The land use planning system provides an extremely
cost effective and efficient way of achieving public policy goals,
many of which could not be achieved in any other way. It is an
important cross-cutting mechanism for the delivery of environmental
objectives across the Government as a whole and the connections
between land use planning and other public policy instruments
and policy objectives need to be substantially improved, especially
in relation to housing, regeneration and economic investment.
The planning policy objective of sustainable development needs
to be made more meaningful by providing more detailed objectives
in PPGs and development plans and expanding the environmental
role of the planning system and planning should be in the vanguard
of the Government's commitments to "democratic modernisation"
in local government and the delivery of "best value".
Efforts to speed decisions over major infrastructure projects
should be tempered by recognition of the need to provide an effective
public policy framework for such inquiries and to secure public
confidence in the outcome of any public inquiry.
HOUSING (JOINT
WITH DSS)
The environmental and regeneration dimensions
of housing policy should be much more widely recognised and better
integrated. The supply of affordable housing should be increased
and the role of the planning system strengthened, including by
greater controls to prevent the oversupply of market housing.
Public and private investment in new housing should be linked
more directly to the achievement of environmental objectives,
especially in terms of urban renewal.
We have also made submissions to the other CSRs
concerning the lack of reference to sustainable development as
one of the Government's overarching objectives and the need for
the environment to be an integral part of their review. We shall
be submitting separate views on transport policy as part of the
process of preparing a Transport White Paper.
ANNEX III
POTENTIALLY WASTEFUL PROGRAMMES OF GOVERNMENT
EXPENDITURE
ROAD CONSTRUCTION
This Government has inherited a £6 billion
road building programme. We welcome the review of the Programme
and encourage DETR to take a critical look at all the schemes
to see whether cheaper alternative solutions exist. For example,
the upgrading of the A30/303 will cost £70 million. Cheaper,
small scale safety improvements suggested by CPRE and the Countryside
Commission would cost less. Other "unwanted" schemes
include: the A590 High and Low Newton Bypass (£10 million
approximately); A1 Baldock to Alconbury (£128 million—DBFO
but will be paid in shadow tolls by the public purse); A49 Hereford
Bypass (£52 million) and M25 widening j12-j15 (£93 million);
M62 east-M606 link roads (£21 million) and A650 Bingley relief
road (£13 million). We are also concerned by suggestions
in the recent Review document for the Roads programme that the
costs to the public purse of DBFO schemes are "not applicable"
when costs will be borne as shadow tolls. In addition there is
the unnecessary cost and controversy of pursuing schemes through
public inquiries which give rise to strong objections and where
alternatives have not been rigorously pursued.
LOCAL TRANSPORT
BUDGET
The local transport budget has been significantly
cut over recent years (£829.6 million in 1996-97 to £746.2
million for 1997-98). At the same time there has been increasing
recognition that solutions to the problems of car and lorry dependency
will be found at the local level. The pressures placed on the
local transport budget have therefore increased and expenditure
does not relate as well as it should to policy priorities. Two
areas where particular action is needed are the continuing funding
of local authority road schemes and the allocation given to bridge
strengthening.
Last year cost over-runs for the 126 road schemes
still being supported by the local transport budget prevented
the previous Government from supporting local authority "packages"
and led to the axing of the "minor works" budget which
is used by local authorities to implement small scale improvements
such as new cycling and pedestrian facilities which often meet
policy objectives at a lower cost. In many cases CPRE believes
that many of the road schemes now being supported (where construction
has yet to take place) could be replaced by less damaging proposals.
These would seek to reduce traffic levels and make better use
of the existing network—in line with current policy for
national trunk roads. The proportion of all money going to local
authorities for road building has increased from 74 per cent.
in 1995-96 to 83 per cent. in 1997-98 (RCEP 1997). The
Government state that "the development of the package
approach is a high priority for Ministers" they concede
that "because of the shortage of resources there may well
be limited scope for accepting any new package bids."
(TPP Circular June 1997).
The bridge strengthening programme consumed
£110 million in 1997-98 (over 10 per cent. of the entire
local transport capital allocation). This funding is in order
for local authority roads to carry heavier lorries. Although the
EC Directive requires that 40 tonne lorries be permitted on Britain's
roads, it does not require universal accessibility on all roads.
CPRE believes that the development of strategic lorry route networks
and the introduction of restrictions could be considerably more
cost effective and help to reduce the environmental impact of
lorries in the countryside.
RURAL DEVELOPMENT
Rural development initiatives administered through
the Rural Development Commission and through EU funding sources
such as the Structural Funds frequently place too much emphasis
on infrastructure and the speculative development of workspaces
rather than the development of human resources. A current example
is the RDC's expenditure of over £4 million on 100 per cent.
funded workshops with a job potential of just 118 (£34,500
per job at best). Such expenditure cannot be considered cost-effective
and will barely influence market driven changes.
AGRICULTURAL SPENDING
The wastefulness of agricultural spending is
well documented and it is not confined to the CAP. Six current
examples include:
(1) Lost profits compensation
Agriculture remains in a very privileged position
by contrast with other sectors. In many areas land managers are
specifically compensated for income foregone which stands in stark
contrast to other industries in relation, for example, to planning
controls where no compensation is given when consent for development
or a change of use is refused.
Schemes which explicitly compensate for intensive
farming income foregone include the Nitrate Sensitive Area scheme,
the Arable Area Payments Scheme, Set-aside schemes and the Farm
Woodland Premium Scheme. There is now a shift towards positive
environmental management payments but lost profits from the intensive
production capacity of the land remains the basis upon which payments
are made and therefore the economic value of environmental goods
is assessed. The scale of agri-environment area payments is pitched
according to the relative productivity, or in the uplands, the
potential stocking level (and therefore potential headage payment
income) of the land.
The compensation principle also applies under
the Wildlife and Countryside Act 1981 and the associated
1983 Financial Guidelines whereby English Nature are empowered
to pay owners to prevent them from conducting potentially damaging
operations. English Nature has four months to negotiate a management
agreement for the land which compensates the owner for profits
foregone. Among the UK statutory conservation Agencies, management
agreements of this kind amounted to £7 million in 1992-93
(NAO, 1994).
In our view compensation for lost profits is
not a sustainable or acceptable framework for long term agricultural
support and environmental protection. Moreover, as a basis for
evaluating the cost of public environmental goods, it perpetuates
productive capacity and individual profit as the primary land
purpose.
(2) Voluntary principle and opt-out
Great importance is attached to the importance
of farmers' freedom to opt out of management schemes. Management
agreements range in period but the longest is just 10 years and
with ESAs there is an optional break clause after five years.
In our view it is a poor use of public money if investment in
the environmental capital of the nation can effectively be thrown
away after five years without any safeguards to protect the long
term public benefits which have been generated from public resources.
(3) Conflicting expenditure—the flax loophole
Agriculture production payments can sometimes
undo years of conservation expenditure resulting in public expenditure
giving rise to directly contradictory results. One example is
the fibre flax subsidy which offers £250 per acre without
any environmental conditions being attached to the payments. The
choice of whether to grow flax remains dependent on an individual
farmer's view of market signals and it may be grown on land not
eligible for Arable Area Payments even where public money is being
used to achieve other aims on this land—the so-called flax
"loophole". The perversity of this problem is made even
more stark by the fact that there is not even a well-established
market for flax yet and some crops end up being ploughed in.
For nationally designated sites to be diversely
affected by agricultural policy is a clear example of wasted public
money. For example around 16 ha of a 26 ha SSSI within the South
Downs ESA, was ploughed by a farmer taking advantage of the high
level of subsidy available for flax growing which was much greater
than that available through ESA payments. Only intervention through
the use of reserve powers under the 1981 Act by the Environment
Secretary helped to safeguard some of the site in chalk downland
in East Sussex and these powers are both limited in scope and
inappropriate for more general application to resolve this anomaly
in public expenditure.
(4) Conflicting expenditure—headage payments
Some agri-environment measures result in livestock
being paid for twice over. The Hill Livestock Compensatory Allowance
(HLCA)—the headage payment on breeding cows and ewes kept
in Less Favoured Areas—is designed to encourage the continuation
of farming and rural populations in upland areas. Moorland agri-environment
payments and a few National Parks grant schemes pay farmers an
additional supplement to reduce stock to a specified level on
an area basis. In many cases rather than reducing stock numbers
they are simply relocated, so in effect stock are receiving payment
twice over, once to keep them on and once to take them off.
The situation is doubly compounded on commons,
where an individual may have registered rights on more than one
common. In some cases, the same sheep are registered twice, receive
HLCA payment twice and then agri-environment compensation twice.
Rationalising the basis upon which HLCA and
moorland agri-environment schemes are administered and funded
would not only bring financial benefits but also a clear and more
positive statement of the environmental value of LFA land.
(5) Downstream costs
An estimated £800 million is being invested
to comply with EU drinking water quality standards in respect
of nitrates, a large source of which is derived from agricultural
run-off. Preventative action, either by regulation or the application
of a nitrate application environmental condition to all agricultural
payments could be much more cost effective than seeking to cure
the problem once it has arisen.
MAFF Research programme
The breakdown in funding of MAFF's 1996-97 research
programmes provides a further indication of the low priority afforded
to environmental protection and enhancement. Out of a total budget
of £125.6 million just 15 per cent. is allocated to "Protecting
and enhancing the environment" which compares to 45 per cent.
for "Improving economic performance".
ANNEX IV
PRIORITY LEGISLATION FOR THE COUNTRYSIDE
AND THE ENVIRONMENT
ENVIRONMENTAL DUTIES
Place a duty on all Government Departments and
public bodies to further the conservation and enhancement of the
environment and of natural resources by integrating environmental
considerations into the preparation of policy and the discharge
of any functions.
Require all new legislation and policy proposals
to be accompanied by an environmental compliance assessment which
addresses its impact on environmental objectives.
NATIONAL PARKS
Give the New Forest and the South Downs equivalent
protection to National Parks.
Introduce a statutory test for major development
in National Parks which requires it to demonstrate a national
need and a lack of alternatives.
Place a duty on all public bodies to further
National Park purposes.
Extend the duty for National Park Authorities
to map moorland and heath to the preparation of wider audits of
the environment resources of National Parks.
TOWN AND
COUNTRY PLANNING
(a) Environmental role
Require a strategic environmental assessment
of all development plans.
Require local authorities to include policies
in their development plans on the conservation of energy and other
natural resources and the maintenance and enhancement of biodiversity.
Strengthen the powers of minerals planning authorities
to review and revoke outdated and environmentally damaging planning
consents without compensation.
(b) Public participation
Extend the minimum period of public consultation
on planning applications from 21 to 28 days.
Require all planning obligations to be placed
on a public register.
Place Regional Planning Guidance on a statutory
footing with minimum legal requirements for public participation
and strategic environmental assessment.
(c) Improving efficiency and providing safeguards
against abuse
Place a general duty on local planning authorities
to enforce planning controls.
Make unauthorised irreversible breaches of planning
control a criminal offence.
Reduce the grounds on which an appeal against
an enforcement notice can be made.
Reduce the time period for lodging planning
appeals from six to three months.
Require local planning authorities to give reasons
for granting planning consent.
Introduce a carefully defined right of public
appeal against the grant of planning permission in contravention
of an agreed development plan or by a local authority to itself.
Reduce the scope to appeal against the refusal
of planning consent, including in cases where repeat applications
have been made.
Require planning applications where there are
unresolved objections from any of the countryside agencies or
which give rise to sustained third party objections to be called-in
by the Secretary of State.
(d) Extending planning control
Remove Crown exemption from planning controls.
Extend advertisement controls to road side tourist
signs and commercial colour schemes.
Remove the anomalous exemption of agriculture
and forestry from the planning system by including them within
the definition of development and subsequently granting permitted
development rights for much activity.
Significantly reduce the extent of permitted
development rights for the changing the use of land, temporary
uses such as noisy sports, caravans and for development for agriculture
and forestry purposes and by statutory undertakers and utilities.
LANDSCAPE AND
AGRICULTURE
Introduce legal protection for drystone walls,
ponds, copses and other features of landscape, cultural and wildlife
importance.
Strengthen the system of tree preservation orders
and extend it to orchards.
Require all agricultural payments administered
by the Government to be conditional on protection and enhancement
of the environment, including application of a mandatory code
of good agricultural practice.
Place a duty on local authorities to protect
and manage AONBs.
Introduce a single integrated mechanism for
supporting farmers and land managers to care for the countryside.
Remove the system of lost profits compensation
under the Wildlife and Countryside Act 1981.
NATURAL RESOURCES
Extend the definition of pollution to include
light pollution.
Place a duty on water companies and the Director
General of Water Services to conserve and promote the efficient
use of water resources.
Extend the powers of the Environment Agency
to review and revoke abstraction licenses, including without compensation.
Establish a national resource management strategy
with national targets for reducing road traffic levels, waste
generation and the consumption of energy, minerals and water resources.
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