Memorandum submitted by English Nature
(V14)
EXECUTIVE SUMMARY
(a) English Nature believes that the proposal
for an "Integrated Agency" provides an exciting opportunity
to deliver a better natural environment for the people of England.
(b) As an independent, properly resourced
Non-Departmental Public Body and with the right statutory remit,
the new body can put into practice many of the principles and
recommendations in the Rural Delivery Review. It can deliver existing
work, such as Public Service Agreement targets, more effectively;
join up existing work currently carried out in separate bodies;
and in doing so give a clearer and better service to the people
and partners that depend on the work it does.
(c) The reform agenda, within Defra and
across Government as a whole, that it exemplifies, provides a
clear context. It also provides challenges. The scale of change
means that it is essential that the formation and operation of
the "Integrated Agency" is carried out in a joined-up
way within an overall policy framework that provides the right
environment for the new body to succeed.
1. INTRODUCTION
1.1 English Nature is the statutory body
that champions the conservation and enhancement of the wildlife
and geological features of England. We work for wildlife, in partnership
with others, by:
— advising Government, other agencies,
local authorities, interest groups, business, communities and
individuals on nature conservation in England;
— regulating activities affecting special
nature conservation sites in England;
— enabling others to manage land for
nature conservation through grants, projects and information;
and
— enthusing and advocating nature conservation
for all and biodiversity as a key test of sustainable development.
1.2 Through the Joint Nature Conservation
Committee, English Nature works with sister organisations in Scotland,
Wales and Northern Ireland to advise Government on UK and international
nature conservation issues.
1.3 English Nature contributed to Lord Haskins'
Rural Delivery Review during 2003 and since its publication last
November has been participating in Defra's Modernising Rural Delivery
Programme. Throughout this submission the "Integrated Agency",
yet to be named, shall be taken as including:
— all the current functions of English
Nature (ie including rural, urban, coastal and marine);
— the landscape, access and recreation
functions of the Countryside Agency; and
— the agri-environment schemes (and
some other functions such as licensing) from Defra's Rural Development
Service.
2. THE PROPOSAL
TO ESTABLISH
AN "INTEGRATED
AGENCY"
2.1 English Nature believes the proposal
to establish the "Integrated Agency" provides an exciting
opportunity to:
— enhance biodiversity in England,
both by improving the condition of special wildlife sites and
through action at landscape scale across the wider countryside;
— provide real benefits and opportunities
for people from all parts of society to enjoy nature, landscape
and have better access to England's natural environment;
— provide better and more joined-up
advice to Defra and the rest of Government;
— provide more streamlined, responsive
and joined-up services to partners, key groups such as land managers,
and the public as a whole;
— achieve improved outcomes for the
whole range of work currently carried out by the separate bodies;
— collaborate more effectively with
key national partners such as the Environment Agency, the Forestry
Commission in England and English Heritage; and
— operate in a co-ordinated way with
and through others at a regional and local level.
2.2 All of these benefits will depend heavily
on the expected CAP reform to influence more environmentally sensitive
agriculture; the proposed streamlining of rural, agricultural
and environmental funding streams; and appropriate funding for
the "Integrated Agency" to deliver its mission.
3. ENHANCING
BIODIVERSITY IN
ENGLAND
3.1 We believe that the creation of the
"Integrated Agency" will provide improved opportunities
to help deliver the Public Service Agreement targets for Sites
of Special Scientific Interest and farmland birds, as well as
the UK Biodiversity Action Plan targets, through for example:
— fewer, simpler, better targeted,
more efficient and more understandable rural funding schemes,
and especially an integrated package of properly designed, resourced
and targeted agri-environment schemes as described below;
— the ability to give a better, and
more joined-up, service to SSSI owners, occupiers and other land
users in order to influence policy makers, resolve perceived conflicts
between site protection and access, and encourage better public
use and appreciation of special sites; and
— closer working at both policy and
operational level with other bodies such as the Environment Agency,
Forestry Commission and English Heritage (see below).
3.2 The broad scope of the "Integrated
Agency" will build on the successes and world class reputation
of its constituent bodies, the legislative changes of the Countryside
and Rights of Way Act 2000, and the expected benefits of CAP reform.
The establishment of the new body will provide a positive opportunity
to take further the change in focus of nature conservation, signalled
by the England Biodiversity Strategy "Working with the grain
of nature" (Defra, 2002), from defensive protection of special
sites against damage to positive management, habitat restoration
and action at a landscape scale to secure better outcomes for
the natural environment and for the people who enjoy its benefits
and depend upon it for their livelihoods and well being. The new
body will continue to rely on its constituent bodies' current
blend of advice, advocacy, incentive and regulation to achieve
these outcomes.
3.3 Natural processes must function properly
to sustain resilient ecosystems, and English Nature has international
expertise based on over 50 years of research and experience in
this area. Healthy ecosystems (including the biodiversity and
geodiversity they contain) in turn contribute to high-quality
landscapes. The work of the Countryside Agency and its predecessors,
English Nature's work with others on pilot approaches to area
based delivery, and future work with the Environment Agency to
develop River Basin Management Plans will form the basis for action
at a landscape scale to sustain and enrich nature and natural
features. Working at the landscape scale will not only ensure
that change addresses multiple public policy objectives but also
provide a link to people's sense of place and their cultural heritage.
Changes in the agri-environment schemes will play a critical part
in ensuring that landscapes, special sites and the habitats and
features that they contain are all sustained by advice and incentives
that deliver benefits for people and for the economy as well.
3.4 English Nature and its partner bodies
are already pioneering this joined-up approach. For example, rivers,
lakes and fens are suffering excessive siltation and nutrient
enrichment from diffuse agricultural pollution. We have proposed
a two-tier approach with basic measures (eg through the Entry
Level Scheme) across all catchments and targeted action where
additional SSSI protection is necessary. We have also established
a joint programme of work with the Environment Agency and the
Rural Development Service that:
— establishes early action on tackling
diffuse water pollution from agriculture in two priority catchments
where there is existing activity (control catchments: river Avon,
Hampshire and Bassenthwaite Lake, Cumbria) and in two priority
catchments where there is little/no current activity (experimental
catchments: the river Teme, Shropshire, Herefordshire and Worcestershire,
and the river Wensum, Norfolk);
— reviews lessons learnt from previous
catchment initiatives;
— provides a model for joint working
processes within a co-operative catchment initiative;
— provides an experiential basis for
establishing how national environmental priorities are translated
into local action and delivery; and
— complements "pathfinder"
activity on social and economic services that will be undertaken
by the Local Government Association, Regional Development Agencies
and Government Offices.
3.5 This joint programme will be the principal
mechanism for the respective organisations' contribution to Defra's
Stakeholder Initiative, and our advice on targeting priority catchments
for early action on diffuse water pollution will be delivered
in this way.
4. PROVIDING
BENEFITS AND
OPPORTUNITIES FOR
PEOPLE
4.1 English Nature believes that the "Integrated
Agency" should aim to ensure that:
— more people across the whole of rural
and urban England, including socially excluded groups, enjoy nature
wherever they are;
— there is greater engagement and participation
by people and communities with the natural world;
— people have easy access to green
areas in our towns and cities; and
— there is more sustainable economic
use of the natural world.
4.2 English Nature has made a great deal
of recent progress in promoting the involvement and enjoyment
of increasing numbers of people. In so doing it has demonstrated
the benefits of nature to the lives and well being of people in
England. It has dramatically expanded the network of Local Nature
Reserves, has promoted accessibility to greenspace in towns, has
provided funding for community projects, and has further promoted
access to its National Nature Reserves and through its website
to a considerable amount of data, information and other resources.
It has also promoted the sustainable economic use of natural resources.
4.3 At the same time the Countryside Agency
has also made enormous progress in encouraging access and participation
through such work as the countryside access mapping project, and
promoting sustainable tourism, the link between walking and health,
and better access to and management of greenspace in the urban
fringe. Similarly, the Rural Development Service has increased
access provision through agri-environment agreements.
4.4 Proposals for the "Integrated Agency"
provide a considerable opportunity to do more to meet the growing
public need for health, exercise, enjoyment, understanding and
participation with the natural environment. Combining the knowledge,
professionalism and scope of the constituent bodies will help
provide people in England with more opportunities to enjoy nature
and the countryside and help to deliver real benefits for society.
5. PROVIDE BETTER
AND MORE
JOINED-UP
ADVICE TO
DEFRA AND
THE REST
OF GOVERNMENT
5.1 As an independent Non-Departmental Public
Body (NDPB) the "Integrated Agency" will give advice
on policy formulation to its sponsor Department and across Government
as a whole. This advice must be based on sound science and research
and expert knowledge, informed by our experience of local delivery.
Joining up the work of its constituent bodies will bring different
specialisms together and add particular value in areas such as
agri-environment, water and land use policy (eg building on the
existing collaboration through the inter-agency Land Use Policy
Group), spatial planning and sustainable communities.
6. PROVIDE MORE
STREAMLINED, RESPONSIVE
AND JOINED-UP
SERVICES
6.1 The constituent bodies that will form
the "Integrated Agency" very often deal with, or provide
services to, the same people. For example, 55% of the area of
land affected by the open access provisions of the Countryside
and Rights of Way Act 2000—currently managed by the Countryside
Agency—is also a Site of Special Scientific Interest designated
by English Nature. The majority of the 32,000 SSSI owners and
occupiers are also eligible for payments under agri-environment
schemes. Creating the "Integrated Agency" will reduce
confusion and overlap of effort and improve the quality of the
information, contact and service provided.
7. ACHIEVING
IMPROVED OUTCOMES
MORE WIDELY
ACROSS THE
NEW BODY
7.1 The constituent bodies that will form
the "Integrated Agency" are already working more closely
on common projects, for example:
— the Rural Development Service, Countryside
Agency and English Nature regionally-based staff are working together
to produce joint regional statements that will form the blueprint
both for the new body's delivery at the regional level and its
collaboration with other Regional delivery bodies; and
— the Rural Development Service and
English Nature staff are working on integration of English Nature's
Wildlife Enhancement Scheme into the higher-level agri-environment
schemes to ensure a more efficient and unified mechanism to fund
SSSI management. This will give better environmental outcomes
and a clearer, simpler service to land owners and managers.
7.2 These are useful pointers to the future
of how the new body can achieve better outcomes as part of a larger
and more efficient and influential body.
8. COLLABORATION
WITH KEY
NATIONAL PARTNERS
8.1 English Nature looks forward to building
on its already close and productive working relationships with
the Environment Agency, English Heritage and the Forestry Commission
in England.
8.2 It is important that the differentiation
of roles between that of the Environment Agency and the new body
is kept distinct, recognising that there will often be shared
outcomes. While air, soil and water resource protection and regulation
is the Environment Agency's major role, the new body will focus
on ensuring that the health of our natural resources—biodiversity,
geology and landscapes—provides the basis for diverse and
resilient ecosystems. We already have a Joint Ventures Programme
with the Environment Agency which identifies a number of areas
where we need to work closely together, and our recent work together
on influencing the environmental quality measures included in
the water companies asset management programme for 2005-10 provides
a clear demonstration of the effectiveness of our collaboration.
We are actively exploring how to achieve closer alignment and
deliver better environmental outcomes under the new arrangements.
8.3 English Nature also looks forward to
closer collaboration with the Forestry Commission in England and
fully utilising its woodland management expertise. Whilst the
Strategy was silent about any future proposal to examine whether
the Forestry Commission's work in England should be included in
the new body, we remain open-minded on this point subject to the
possible effects of further organisational change being taken
into account as legislation and the implementation plan are proposed.
8.4 At the same time the "Integrated
Agency" will have the opportunity to collaborate with a wide
range of other governmental and non-governmental partners. English
Nature already has a Memorandum of Understanding with English
Heritage and a joint programme of work which has been developed
because of the high level of coincidence between natural, archaeological
and historic heritage and the synergy between these interests.
In future we expect there will be more opportunities to work closely
with English Heritage over the targeting of agri-environment schemes
and other measures that help to conserve historic landscapes and
other features of cultural importance. Like its forerunners the
new body will also depend closely on forging strong national partnerships
with strong and diverse voluntary sector.
9. REGIONAL AND
LOCAL RESPONSIVENESS
9.1 English Nature welcomes the move to
more devolution of decision-making to regional and sub-regional
level and development of rural delivery frameworks. It believes
the "Integrated Agency" will play a key role in helping
to express national policy objectives through regionally and locally
identified priorities, and better joining-up with other regional
and local approaches. To help ensure that the new body will be
effective at the regional level whilst responsive to regional
and local needs, English Nature intends to:
— develop and agree service standards
between English Nature and local authorities, in particular with
regard to statutory advice provided as part of the land use planning
system;
— work with Government Offices, and
other stakeholders, to ensure that the Rural Strategy pathfinder
projects help develop improved ways of delivering rural services;
— involve the Local Government Association
as a key stakeholder in shaping the change process and developing
the vision and objectives for the Integrated Agency;
— work with Local Authorities to ensure
that Community Strategies, and Local Strategic Partnerships, adequately
reflect the value of environmental quality and accessibility to
local communities; and
— explore new ways for English Nature
to deliver, with the Countryside Agency, RDS and local authorities,
integrated packages that achieve environmental improvement, community
ownership and increased opportunities for recreation and access.
9.2 While it will be for the "Integrated
Agency" to determine the detail of the way it is structured
and organised, English Nature believes that the new body should
build upon the existing strengths of its constituent bodies which
already have a strong and effective presence at regional and local
level. This should be designed to aid responsiveness and flexibility
at regional level, both in the delivery of policy and in its response
to differing needs across England.
10. REFORM OF
THE COMMON
AGRICULTURE POLICY
10.1 The creation of the "Integrated
Agency" will provide an opportunity to respond positively
to the reform of the Common Agricultural Policy. CAP reform is
perhaps the single most significant external factor affecting
the successful operation of the new body. It is central to the
rural agenda and critical to delivering more environmentally-sensitive
agriculture.
10.2 Recent Ministerial decisions on CAP
reform confirm the Government's commitment to transfer resources
from farm subsidies into EU-funded rural development and agri-environment
programmes. This source of funding will be an important way for
the new body to deliver a number of the Government's environmental
targets and objectives.
10.3 Future delivery of EU-funded rural
development and agri-environment schemes in England will be through
a twin-track approach: Regional Development Agencies (RDAs) will
be responsible for agriculture and food industry regeneration,
and the "Integrated Agency" will help to deliver funding
that contributes to environmental management and natural resource
protection. Whilst this approach allows specialist expertise to
be fully utilised and the resources from different funding streams
to be combined, particular attention will have to be given to
the integration of socio-economic and environmental agendas in
policy development, planning and at the point of delivery.
10.4 The European Commission has also recently
published its proposals for the future of EU-funded rural development
and agri-environment programmes. The prospects for a significant
increase in the UK share of the EU rural development budget are
low. In addition, the Commission's proposals for a minimum allocation
of resources to socio-economic strands in Member States' rural
development programmes means that, without a substantial increase
of the UK budget, the current resources available to agri-environment
schemes would fall significantly. However, there appear to be
opportunities for Member States to integrate environmental objectives
into both the competitiveness and wider social strands of rural
development programmes.
10.5 English Nature believes that the "Integrated
Agency" should be sufficiently resourced to continue the
progress towards meeting a number of Government's environmental
targets and objectives. To help achieve this, over the next two
years Defra and its agencies must also ensure that:
— negotiations on the structure and
scope of the proposed European Agricultural Fund for Rural Development
successfully conclude with legislation consistent with the UK's
objectives for the future of farming, food and the environment;
— the increase in the budget for EU-funded
rural development in England is sustained in the 2007-13 programming
period through an increase in the UK share of the budget and further
transfers of resources from farm subsidies into rural development
and agri-environment schemes; and
— the twin-track structure for rural
delivery in England (via RDAs and the "Integrated Agency")
is made compatible with the Commission's more integrated approach.
Appropriate priorities, targeting and accountability processes
should ensure environmentally sustainable outcomes from both economic
and agri-environmental programmes that contribute to the Government's
environmental objectives.
11. THE PROPOSED
STREAMLINING OF
RURAL, AGRICULTURAL
AND ENVIRONMENTAL
FUNDING STREAMS
11.1 English Nature welcomes the conclusions
of Defra's recent review of funding streams. The simplification
of funding schemes to achieve social, economic and environmental
outcomes, and of the advice and systems that support these outcomes,
will provide a clear basis on which the work of the new body can
be planned in order to achieve simplicity for people requiring
funding or advice, value for money and the "Integrated Agency's"
overall policy objectives.
11.2 The expected period of transition before
the formal creation of the new body provides ample time in which
to work out the detail of this approach. The "Integrated
Agency" will need to be responsive to the differing needs
of national, regional and local level customer groups and be sensitive
to how these relate to the outcomes it is seeking.
12. DELIVERY
MECHANISMS
12.1 English Nature supports the principles
behind the delivery mechanisms of the Strategy. We believe the
"Integrated Agency" will provide opportunities for more
efficient working and for better services to users, building on
the successes and experience of its constituent bodies. It is
important however that lines of accountability are clear. The
Secretary of State's decision that the "Integrated Agency"
will be an independent NDPB is thus welcome and significant. As
well as independence in advice and delivery, English Nature also
believes that the new body should be able to decide the best way
to structure itself and how its underpinning systems and services
will be provided, in order to best meet its statutory functions
and give efficient and responsive services in line with Haskins
principles.
13. RESOURCES
FOR THE
"INTEGRATED AGENCY"
13.1 As well as adequate agri-environment
scheme funding, the ability of the "Integrated Agency"
to deliver its target outcomes is dependent on adequate resourcing
both of the transition and its steady state. In order for English
Nature to continue to deliver business as usual during the interim
period, any transition costs need to be covered out with its normal
grant-in-aid.
13.2 Whilst paragraphs 73 and 75 of the
Strategy make clear that operational benefits are the key driver,
English Nature is concerned that the potential cost savings which
could be achieved as a consequence of the integration should not
come to be regarded as a principle driver of the change process.
The creation of the "Integrated Agency" aims to improve
effectiveness, and whilst efficiencies may be involved, English
Nature expects that any savings should be re-invested in front
line business delivery.
14. THE STRATEGY
AND THE
RURAL DELIVERY
REVIEW
14.1 English Nature welcomes the Strategy
as a whole and considers that to a very large degree it incorporates
the recommendations of Lord Haskins' Review. However, it is important
to realise that an "Integrated Agency", including rural,
urban, coastal and marine functions, covers issues beyond Lord
Haskins' remit.
14.2 In particular, we believe that the
response to recommendations 16 to 19, on the "Integrated
Agency" and the way it will work with others, gives a clear
signal for the bodies affected to work together ever more closely
to turn these recommendations into reality. It is important that
the timescales involved, together with the breadth of change that
the Strategy as a whole represents, do not weaken the effectiveness
of current bodies and the "Integrated Agency". English
Nature is committed to playing a full part in the change process,
alongside joined up action across the whole of Defra and its agencies,
to ensure success.
17 September 2004
| 
