Annex A
CONSULTATION ON DRAFT PLANNING POLICY STATEMENT
ONE: CREATING SUSTAINABLE COMMUNITIES RESPONSE BY FRIENDS OF THE
EARTH
INTRODUCTION
Friends of the Earth believes the planning system
should have a visionary purpose to deliver sustainable development
through processes which are both transparent and democratic. The
purpose of Planning Policy Statement 1 must be to recommit the
practice of planning to the achievement of these principles. The
tone of PPS 1 is equally important and should stress in clear
language the achievements of planning regulation and celebrate
its local democratic basis as unique in environmental regulation
in the UK.
SUMMARY
1.1 Friends of the Earth made a significant
contribution to the pre consultation drafts of PPS 1. As a result
this response focuses on a number of broad policy issues which
we believe still require significant modification. Overall we
continue to be concerned that the document unfairly prejudices
economic growth over the other important pillars of sustainable
development. In particular the tone is focused very much on the
needs of economic competitiveness while much less attention is
paid to key environmental challenges which confront the planning
system, particularly in relation to climate change. The draft
also sends equivocal messages as to whether the pillars of sustainable
development should be "integrated" or "traded off"
in planning decision-making.
POSITIVES
1.2 Friends of the Earth strongly welcomes
the inclusion of a commitment to public participation and involvement
in PPS 1. Overall Friends of the Earth remains very concerned
as to how these principles are translated into precise standards
of participation, particularly at the regional tier of planning.
However, we believe the statements of principle and particularly
the acknowledgement of the importance of the Aarhus Convention
are a very positive step forward in creating a comprehensive and
coherent framework of public participation in planning. Such commitments
can only assist in communicating the purpose of planning to the
wider public and in securing public legitimacy. We also strongly
support the new material in the draft PPS on social inclusion
and spatial planning.
NEGATIVES
The purpose of planning!
1.3 While Friends of the Earth welcomes
the statement in paragraph 1.1 that sustainable development is
the core principle of planning we remain concerned that paragraph
1.2 and 1.3 detract from this message by providing detailed discussion
of the objectives of the Sustainable Communities Plan, 2003, without
making clear what the relationship is between these goals and
the overarching achievement of sustainable development. It is
absolutely clear that these two ideas cannot be conflated nor
do they share a set of common values. The definition of a "sustainable
community" listed in annex A is quite distinct from accepted
definitions of sustainable development and even the UK Sustainable
Development Strategy. For one thing it includes nothing about
the natural environment at all. The potential for confusion between
these two ideas is compounded by the title of this PPS which makes
no mention of sustainable development.
1.4 The title and substantive purpose of
this PPS must be the achievement of sustainable development of
which sustainable communities is a distinct sub set of policy
initiatives. This hierarchy of objectives should be made clear
inside paragraph 1.1. In addition and for or the sake of clarity
PPS 1 should be titled as "Delivering Sustainable Development".
1.5 The definition of sustainable development
Friends of the Earth believes that the planning
system is one of the principal delivery mechanisms for achieving
sustainable development. PPS 1 has a particular responsibility
to ensure that sustainable development is robustly defined in
a way which allows meaningful changes to the methodology and outcomes
of planning. We believe the current definition is deficient in
4 principal ways.
A. The disproportionate weight given to economic
growth
1.6 We continue to believe that taken together
the draft is unbalanced, focusing disproportionately on economic
growth over social or environmental objectives. This imbalance
is reflected in the contrast between the amount and character
of the exposition of in paragraphs 1.15 to 1.17 on the economy
and paragraph 1.20 on the environment. In addition the reordering
of the pillars of sustainable development from the UK strategy
in paragraph 1.13 might be read as an unintentionally crude attempt
to draw more attention to economic growth as a core objective
in the planning system.
B. The way growth is defined
1.7 Friends the Earth recognises that PPS
1 broadly attempts to transpose the principles contained within
the UK Sustainable Development Strategy. However, we do not believe
that the crude definition of economic growth provides a sensitive
nor detailed enough definition to genuinely shift the culture
and practice of planning to help secure a more sustainable society.
1.8 While Friends of the Earth support the
objective of high and stable levels of employment, we believe
that economic growth as currently defined and measured should
not be regarded as an end in itself. It may often assist in the
achievement of the other three goals, but often it may not. We
need to be far more rigorous in distinguishing between the kind
of economic growth that is compatible with the transition to a
genuinely sustainable society, and that which is not. In the past
the planning system has given overwhelmingly greater importance
to a crude GDP based model of economic growth and has effectively
subordinated protection of the environment and prudent use of
resources to these other objectives. This approach has been a
barrier to the achievement of sustainable development because
of the resulting damage to the environment and loss of natural
resources which is already imposing significant economic costs
on society.
1.9 Friends of the Earth supports the Sustainable
Development Commission suggested amendment of the 4th pillar of
sustainable development.
The Government's fourth objective about the
economy should be re-formulated in such a way:
— as to promote the kind of economic
growth that supports social progress, high employment levels,
protection of the environment and prudent use of natural resources,
and to discourage the kind of economic growth that does not; and
— that links high employment with the
goal of social progress and wellbeing, rather than with economic
growth, since having satisfactory work is such a fundamental part
of social and personal security and identity. (Sustainable Development
Commission 2004)
C. Failure to include vital components of sustainable
development
1.10 PPS 1 fails to recognise important
aspects of the sustainable development ideal which are represented
both in the UK Sustainable Development Strategy (1999), other
important planning strategies such as the Wales Spatial Plan (2003)
and the findings of the Royal Commission on Environmental Pollution's
23rd report "Environmental Planning". These missing
principles include:
— environmental limits: ensuring
that resources are not irrevocably exhausted or the environment
irreversibly damaged. This means, for example, supporting climate
protection, protecting and enhancing biodiversity, reducing harmful
emissions, and promoting the sustainable use of natural resources;
— the precautionary approach: the
precautionary principle holds that where the environmental impacts
of certain activities or developments are not known, the proposed
development should not be carried out, or extreme caution should
be exercised in its undertaking; and
— the polluter pays: ensuring
that that those who produce damaging pollution meet the full environmental,
social and economic costs.
1.11 In addition to the accurate transposition
of the UK Sustainable Development Strategy, PPS 1 should identify
the need to achieve:
— environmental justice: putting
people at the heart of decision making, reducing social inequality
by upholding environmental justice in the outcomes of decisions;
and
— inter-generational equity: ensuring
current development does not prevent future generations from meeting
their own needs.
1.12 Both these principles were identified
by the Royal Commission on Environmental Pollution as vital components
of sustainable development. (RCEP 23rd report 2002) It is important
that all these principles are properly identified in describing
sustainable development and we strongly suggests that there are
incorporated into paragraph 1.12. We note that the Wales Spatial
Plan contains a clear, full and operationally useful definition
of sustainable development and we strongly urge that PPS 1 contains
an equally coherent statement.
D. The principles of sustainable development:
trade off or integration?
1.13 Paragraph 1.23 and 1.24 appears to
provide contradictory advice in considering the weight to be given
to the four pillars of sustainable development. On the one hand
this paragraph appears to indicate the desirability of integration
but at the same time it makes clear that local authorities can
give more weight to particular pillars when they see fit. While
integration is extremely challenging to traditional planning methodologies
it should be strongly encouraged by providing more guidance, here
and in best-practice, on how the process should take place.
1.14 In addition it is vital to make a distinction
between how sustainable development is incorporated into policy
and how it is applied to individual decisions. Paragraph 1.24
states that local authorities might seek to give "extra weight"
to one of the pillars in planning policy. This suggestion is very
different to giving extra weight to the impact of a particular
pillar in actual land-use decisions. The point is that policy
must always seek the highest standards of integration providing
a framework for sustainable development. In a specific application
we acknowledge that, rightly or wrongly, other material considerations
may be influential. This paragraph needs to be redrafted to ensure
such integration is the first and most important priority, that
policy should support this view and the development control decisions
should carefully seek to uphold this integrative approach wherever
possible.
Failure to adequately highlight key environmental
challenges such as climate change and biodiversity
1.15 One of the consequences of the over
emphasis on economic growth is that while the need for increased
competitiveness receives a good deal of policy discussion, the
treatment of climate change and biodiversity is brief and inadequate.
As a result, the current draft provides no real indication as
to the imperative in dealing with the real environmental challenges
which confront the nation.
1.16 Climate change urgently needs to be
incorporated as a key operational principle of the planning system
by making clear in paragraph 1.22 that anything relevant to how
far development either reduces or adapts to climate change is
a "material consideration". This broadening would be
consistent with the new power conferred on local authorities to
promote the environmental, economic and social wellbeing of their
areas, and would help the planning system play a full role in
applying this new power. Again we would favour the approach taken
in the Wales Spatial Plan which communicates both the extent of
the threat of climate change and makes clear how planning can
respond.
1.17 Nowhere in the discussion on the environment
is there the briefest mention of the principles in the UK Biodiversity
Action Plan. These principles should be incorporated into a separate
objective inside paragraph 1.22.
Prudent use of resources
1.18 We would welcome greater emphasis on
the importance of resource conservation by changing the tone of
paragraph 1.21 from the weak "encouraging energy efficiency.
. ." to the more positive "promoting energy efficiency
. . ." We doubt that in its current form this policy will
bring about any meaningful change to the practice of planning
decision making.
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