Select Committee on Environmental Audit Third Report


Supplementary Memorandum from Council for the Protection of Rural England



  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."


  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.


  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.


  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.


  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.


  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




  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.


  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.


  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 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.


  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".




  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.


  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.


  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.


  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.




  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.


  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 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.


  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".




  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.


  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.


(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.


  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.


  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.

3  p. 48. Back
4  p. 48. Back
5  p. 51. Back

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