Memorandum submitted by the Campaign to
Protect Rural England (V11)
INTRODUCTION
1. CPRE works for a beautiful and productive
countryside which is enjoyable for everyone, both present and
future generations. We campaign for the more sustainable use of
land and other resources. We are the pre-eminent non-governmental
organisation in the field of planning and the protection of the
countryside, and the integration of these with land management
policy. We also have considerable experience in the field of rural
service provision and the management of rural development in order
to retain a clear physical distinction between urban and rural
England and to help tackle rural poverty.
2. CPRE regards the content and purpose
of the Rural Strategy 2004 as central to our own work.
It is a crucial area of Government initiative, in terms of the
quality and extent of the countryside, its landscapes and wildlife,
how it is managed, and its resilience in the face of pressures
for development and the impacts of climate change.
3. Recently, we have been directly involved
in the development of proposals for the proposed new integrated
agency, the Government's response to Lord Haskins' Rural Delivery
Review, and the future of the funding of land management and rural
development.
OVERVIEW: THE
RURAL STRATEGY
AND GOVERNMENT
4. CPRE considers that it is of the utmost
importance that all Government departments recognise their role
in pursuing and advocating the Rural Strategy, following the lead
given by DEFRA. In particular, those departments which sanction,
direct, deliver or advise actions which have physical effects
on the countryside and our natural resources should be accountable
for their actions insofar as they help or hinder the achievement
of the Rural Strategy. The strategy has huge implications
for urban society in England and in some cases, such as the remit
of the Integrated Agency, is likely to have direct influence over
the urban as well as the rural environment. CPRE believes that
the pursuit of the long term and universal public benefit to be
derived from the strategy requires commitment across Government.
5. We would draw attention in particular,
to the crucial importance of the Office of the Deputy Prime Minister
in ensuring that the overarching sustainable development remit
described in the Rural Strategy is strongly supported through
the planning system. Sustainable outcomes from economic, social
and environmental considerations should be genuinely reconciled,
rather than traded off against one another in pursuit of economic
development. The Department for Trade and Industry (DTI), particularly
through its responsibility for renewable energy and its sponsoring
of the Regional Development Agencies (RDAs), also has a specially
important part to play in successful achievement of the objectives
of the Rural Strategy. Most of the RDAs do not yet have
sufficient understanding or commitment to sustainable development
or the particular issues encountered by some rural communities.
It is vital that the DTI provides leadership in changing this
state of affairs. CPRE considers that the relaunch of the Sustainable
Development Strategy by DEFRA scheduled for February 2005 will
play a substantial part in determining whether the Rural Strategy
can be effectively delivered or not. It will also be vital
that the Treasury continues to support the pursuit of existing
Public Service Agreement (PSA) targets for habitats and farmland
birds, as well as future compliance with the Water Framework Directive,
with substantial funds for agri-environment schemes and better
land management. The Department of Culture, Media and Sport should
ensure that the role of English Heritage in monitoring and protecting
the rural historic environment is enhanced rather than compromised
through reorganisation or reduced resources.
6. CPRE considers that the Government's
three priorities for rural policy as set out in the Rural Strategy[3]
are not comparable, in terms of their importance. The third priority,
Enhancing the Value of our Countryside—protecting the
natural environment for this and future generations, is of
axial importance to the whole population and to succeeding generations.
The sustaining of all economic and social progress, both urban
and rural, is largely dependent on the successful pursuit of this
priority. The second priority, Social Justice for all,
is strongly supported by CPRE, as is the targeting of resources
under the first priority, Economic and Social Regeneration,
to areas of greatest need. But the strategic importance to the
nation of these two priorities should be clearly recognised as
being of secondary importance to the third priority asset out
in the Rural Strategy. This would be consistent with the
Government's aim as set out in Planning Policy Statement (PPS)
7 Sustainable Development in Rural Areas[4].
We cannot see a defensible case for the special support of enterprise
across rural England in general when much of rural England is
by many measures more prosperous than urban England.[5]
CPRE's concern that the Government may be concentrating disproportionately
on supporting rural enterprise regardless of the actual need for
this support, is amplified in our analysis of PPS 7.
7. We subscribe to the observations made
in the summary of chapter 3 of the Rural Strategy. We would
suggest, however, that not enough recognition is made of the importance
of the historic environment in the review of the benefits provided
by the countryside. This analysis is substantiated by evidence
that people consider "old houses and buildings" together
with the countryside as being the strongest defining characteristics
of England's heritage and environment.[6]
CPRE would welcome the establishment of the historic environment
as a central environmental concern for DEFRA, by developing a
PSA target for the management of the rural historic environment,
a Code of Good Practice for farming, land management and rural
development, and the adequate support of delivery of advice and
exercise of statutory obligations by DEFRA, its agencies and Non-Departmental
Public Bodies.
THE PROPOSAL
TO ESTABLISH
AN INTEGRATED
AGENCY
8. CPRE warmly welcomes the twofold strategy
within the third priority, Enhancing the Value of the Countryside.
However, we consider that the first element of the strategy, the
protection and enhancement of rural and urban environments and
the integration of the management of the natural environment,
as being the essential prerequisite for the successful delivery
of the second element, the enhancing of the value and natural
beauty of the countryside.
9. We are also concerned that the emphasis
on the contribution of the countryside to the social and economic
well-being of the nation, though an accurate observation, fails
to give primary recognition and prominence to the importance of
protecting biodiversity and the beauty, diversity and tranquillity
of the landscape for its own sake and for the health of future
generations. We draw the attention of the committee to the recent
speech by the Minister for Rural Affairs to the Association of
National Park Authorities when he said of the proposed Integrated
Agency, "So we will have a strong body with the twin,
mutually reinforcing objectives of conserving and enhancing the
resource of nature, together with realising the social and economic
benefits for people of so doing." Expressed in this way,
we fear there is almost inevitably going to be conflict between
the two objectives and that they are therefore unlikely to be
mutually reinforcing much of the time. CPRE strongly believes
that the Integrated Agency should have no distinct responsibility
for realising social and economic benefits per se. Rather, we
believe its actions should deliver a countryside and an urban
environment which will give others the opportunity to realise
the wider benefits flowing from diverse wildlife and accessible
natural beauty.
10. Throughout the third chapter of the
Rural Strategy, it is evident that progress can only be
made if an adequate level of resources is devoted to achieving
action on biodiversity, water, soil, landscape and agricultural
and forestry practices. CPRE is concerned that there is little
recognition of this fact, or of the urgency of securing long term
funding, both from the Exchequer and from the reform of the Common
Agricultural Policy. In particular, many of the objectives of
the third priority depend on the negotiation of a substantial
settlement for the United Kingdom from the European Agricultural
Fund for Rural Development (EAFRD). CPRE considers that it is
essential that the Government makes an explicit commitment to
secure levels of funding from the EAFRD which can deliver success
in the priority areas for action and ensure a significant role
for agriculture and forestry in the long term. Furthermore, it
is vital that the Integrated Agency itself is adequately funded
to undertake the duties it will be given. The organisation will
only be a credible force in relation to Government decisions if
the capacity and calibre of the leadership and staff are of the
highest quality.
11. CPRE is also concerned that the measures
required under cross compliance in association with the Single
Payment Scheme should play an effective part in achieving the
objectives of the Rural Strategy. We consider that there
is a risk that if DEFRA does not ensure that cross compliance
measures are robust and effective, the Single Payment Scheme will
be discredited as a contributing element to the Rural Strategy.
Any consequent reduction or withdrawal of the Single Payment could
in turn, threaten to destabilise farming businesses, with damaging
consequences for the quality of the countryside, its biodiversity,
landscape and natural resources. This could have severe consequences
for the success of the Rural Strategy.
12. CPRE warmly welcomes the proposal to
establish an Integrated Agency consisting of English Nature, the
landscape, access and recreation elements of the Countryside Agency
and that part of the Rural Development Service responsible for
environmental land management. We also strongly support the Government's
recognition of the need for the Integrated Agency to work very
closely with the Environment Agency, English Heritage and the
Forestry Commission, as well as regional and sub-regional partners,
such as National Park Authorities and Area of Outstanding Natural
Beauty boards. We urge the Government to do everything it can
to make co-ordination between these organisations as easy and
effective as possible.
13. The Rural Strategy states that
an Integrated Agency will provide "a clearer framework
for resolving potentially conflicting objectives between conservation
and the use and enjoyment of our natural environment".
CPRE agrees that the linking of landscape, biodiversity and access
could lead to internal conflict within the Integrated Agency.
We consider that the purposes of the Integrated Agency should
be spelt out in the clearest terms and suggest that it should
have the following two objectives:
— the protection and enhancement of
all aspects of England's natural heritage; and
— the securing of access to and promotion
of public understanding of England's natural heritage.
CPRE suggests that potential conflict between
the two objectives could be removed by the adoption of a mechanism
similar to the Sandford Principle, enshrined within the Environment
Act 1995 for the pursuit of National Park purposes by National
Park Authorities.[7]
We consider that such a mechanism would be consistent with the
pre-eminent importance of protecting the natural environment (see
paragraph 8).
14. CPRE warmly welcomes confirmation of
the independent status of the Integrated Agency as a Non-Departmental
Public Body. We consider that the following elements would be
crucial in conferring the degree of independence and integrity
which would command respect for the new Agency within and outside
Government:
— a Council appointed by the Secretary
of State;
— non-executive members of the Council
who are effectively independent once appointed;
— legally enshrined duties and capacity
to act as a statutory consultee, including in the planning process;
— a scrutinising role which relies
on impartiality for its credibility;
— a corporate plan which acts as a
contract between the Government and the organisation and a management
statement setting out its long term public purposes;
— freedom to commission research which
is not subject to influence from external commercial or political
interests; and
— an "arm's length" relationship
with Government which supports striking an independent stance
in offering advice on policy and advocating views to Government
without fear of controversy.
15. The linking of landscape and biodiversity
protection recognises the vital importance of a broad scale of
operation required to secure the integrity of habitats and the
landscapes we value. The inclusion of responsibility for access
to the countryside recognises the importance of the continued
engagement of the public with the vital work to secure our natural
heritage in the long term. In the recent past, CPRE observes that
the interests of statutory landscape protection have suffered.
This is in our view, partly due to a confusion among elements
within the Countryside Agency of its statutory purpose to preserve
and enhance "natural beauty in England, both in areas
designated as National Parks or AONBs and elsewhere"[8]
with a duty to act as an arbiter in the debate over the desirability
of landscape protection. We see a significant opportunity for
the Integrated Agency to reinvigorate the zeal with which the
statutory purpose of protecting the landscape is performed, without
being muted by too great a desire for consensus.
16. CPRE sees a particularly important opportunity
for the Integrated Agency to recognise and act on the strong congruence
between the prevention of habitat fragmentation and the retention
of substantial areas of tranquil countryside. The responsibility
of the Integrated Agency for landscape protection brings the issue
of the experience of landscape by the public into prominence.
Despite the fact that the Rural White Paper of 2000 explicitly
included a commitment to measure tranquillity as part of a measure
of change in countryside quality[9],
so far, this experiential indicator has not been forthcoming.
CPRE is working with the Countryside Agency and other partners
to develop a methodology which is widely acceptable and which
can be used to measure tranquillity and changes in its extent.
We intend to publish our findings shortly[10].
We see the formation of the Integrated Agency as a valuable opportunity
for the protection of tranquillity to become central to the task
of an independent body with the ear of Government. We observe
that the threats to tranquillity, such as major road building
projects, the expansion of airport capacity or the spread of diffuse
development across the countryside are very often similarly threatening
to the integrity of habitats and their effective functioning for
the species that inhabit them. The safeguarding of tranquil areas
and habitats on a landscape scale would provide an immensely significant
linkage between the viability of ecosystems and the quality of
life.
17. The prominence given to tackling the
threat of climate change in the priority areas for action is reassuring.
However, there is little or no mention of the implications for
biodiversity and landscape in England as a result of climate change.
Considerable work has been undertaken to understand the implications
of climate change on species in the United Kingdom[11].
CPRE proposes that the Integrated Agency be given statutory responsibility
within its first objective as set out in paragraph 13, to advise
the Government on the implications for the natural heritage of
England of climate change and to deliver measures designed to
anticipate and mitigate the effects on biodiversity and landscape
quality of such change. Such a statutory obligation would have
profound implications for the management of designated sites and
land adjacent to designated sites, the promotion of particular
land management practices across the wider countryside and the
need to secure corridors for the dispersal of species for long-term
adjustment to climatic conditions. As a nation, we need to contemplate
the prospect of wholesale change to the character of our landscapes
over little more than a generation. Such a statutory obligation
on the Integrated Agency would give a focus for action and give
one organisation a clear leadership role in the management of
landscape and habitat change.
18. One of the most important functions
of the Integrated Agency as set out in the Rural Strategy will
be its provision of a "stronger, more coherent evidence
base for informing policy". CPRE strongly agrees that
securing this capacity for the Integrated Agency is vital. We
consider the following elements to be essential in this respect:
— Total independence and freedom from
interference for those gathering evidence within the Integrated
Agency or commissioning research from outside it. From the late-1950s,
the catastrophic contamination by persistent organochlorine pesticides,
from which this country is only now recovering, was detected and
then reversed largely because of the freedom of the then Nature
Conservancy to commission research with no known outcome and no
certainty of causes beforehand[12].
The ill-conceived and damaging restrictions of the Rothschild
Principle, introduced in the mid 1970s, should be removed to allow
the Integrated Agency to commission, undertake or act as a partner
in research which does not have defined outcomes.
— Unrestricted ability to deploy the
evidence base in a policy and advocacy role directly to ministers,
at the highest levels of Government and early enough on in the
process of decision making to play a full part in the establishment
of sustainable development decisions. The advent of the Strategic
Environment Assessment Directive is likely to require substantial
resources to be available to the Integrated Agency to evaluate
the effects on landscape and biodiversity of major development
proposals.
— The capacity to conduct systematic
scanning for environmental threats in the future, anticipating
them and planning for their avoidance or mitigation.
— The ability to communicate directly
with the public, and to secure and sustain their confidence in
the independence of the Integrated Agency.
THE PROPOSED
STREAMLINING OR
RURAL, AGRICULTURAL
AND ENVIRONMENTAL
FUNDING SCHEMES
19. CPRE recognises the virtues of simplifying
the funding schemes presently available. We urge caution, however,
in the creation of the three new funding streams. It is important
that valuable elements, such as the protection of landscape, cultural
heritage and the historic environment, are not lost from the remit
of the new schemes by default. The existing titles of the two
programmes Agricultural and Food Industry Regeneration and
Natural Resource Protection do not clearly indicate that these
elements of the Rural Strategy will be covered by them,
one way or another.
THE DELIVERY
MECHANISMS FOR
THE STRATEGY,
ITS ENVIRONMENTAL
IMPACT AND
ITS LINES
OF ACCOUNTABILITY
20. The contribution of the historic environment
and cultural heritage in achieving economic regeneration should
be more fully acknowledged in the Rural Strategy. We suggest that
the heritage sector should be represented on the Regional Priority
Boards. English Heritage, with their well-established regional
structure, could make a valuable contribution to the protection
and enhancement of the rural landscape, as well as to urban environmental
regeneration.
21. CPRE broadly welcomes the Government's
proposals for new delivery mechanisms. However, we see potential
difficulty in the separation of the economic and social aspects
of rural development from environmental and natural resource protection
measures. The presence of substantial regional offices of the
Integrated Agency will be vital in ensuring that the objectives
of the RDAs are fully reconciled with the Government's objective
to protect and enhance the countryside for the sake of its intrinsic
qualities. The RDAs should be robustly challenged by DEFRA and
the DTI to ensure they develop competence and interest in rural
communities, and in the effects of development on the quality
of the countryside and its biodiversity. It is crucial that the
RDAs do not undermine the planning process by offering funding
to local authorities for rural regeneration which provoke hasty
and ill-considered departures from agreed local planning policies.
22. We await further details on the operation
of the reformed Regional Rural Affairs Fora (RRAFs). The value
of the RRAFs in bringing together a wide variety of interests
has been considerable. They should be adequately resourced in
order to have the capacity to lead the debate on rural policy
in their regions. In the experience of CPRE, the case for landscape
protection and the tackling of rural social exclusion both benefit
from representation on the RRAFs.
23. The retention in a new form of the Countryside
Agency is welcomed by CPRE. We consider that the new Countryside
Agency should have statutory status in order to ensure that rural
interests cannot be sidelined without the will of Parliament.
We welcome the retention of the role of the Chairman of the Countryside
Agency as Rural Advocate but see it as essential that this post
has statutory authority. CPRE regards this as particularly important
for the effective targeting and tackling of rural poverty, where
this exists, and in the provision of genuinely needed affordable
housing in rural areas.
THE EXTENT
TO WHICH
THE STRATEGY
INCORPORATES THE
RECOMMENDATIONS OF
LORD HASKINS'
RURAL DELIVERY
REVIEW
24. CPRE pays tribute to the work of Lord
Haskins in addressing a very wide remit and in delivering a coherent
and comprehensive review of rural policy and delivery. Although
we do not share all Lord Haskins' conclusions, CPRE acknowledges
the value of his investigation and the opportunity it has provided
to take stock of how the countryside might best be served by Government
and independent agencies. We support the Government in retaining
a reformed Countryside Agency and also in linking landscape and
biodiversity purposes in the new Integrated Agency. Although we
agree with the analysis of separating policy and delivery in the
case of the Countryside Agency, we see possible disadvantages
in the case of the Forestry Commission and English Nature. Certainly,
it is vital that the Integrated Agency retains the policy advocacy
role which English Nature has developed so effectively in the
last ten years. In the case of the inclusion of the Rural Development
Service (RDS) within the Integrated Agency, we recommend that
institutional "fire walls" are set up to ensure that
the policy advice and delivery functions of the Integrated Agency
are not confused in practice. In the mean time, we suggest that
the RDS is reconstituted to reflect the shift towards Pillar 2
funding through the EAFRD and the urgency in expanding the scope
and effectiveness of modulation expenditure.
17 September 2004
3 Rural Strategy 2004: Overview, page 5. Back
4
PPS7, section 1(iv) states that the Government's overall aim is
to "protect the countryside for the sake of its intrinsic
character and beauty, the diversity of its landscapes, heritage
and wildlife, the wealth of natural resources and so it may be
enjoyed by all." Back
5
Sources: The State of the Countryside Report 2004 shows
that rural unemployment is lower than urban unemployment. The
Rural Strategy 2004 page 64, quotes Keeble, 1999, showing
that small and medium sized enterprises have grown faster in rural
areas than in urban ones using the old urban/rural definitions. Back
6
The State of the Countryside Report 2004, page 23. Back
7
The Environment Act 1995 amends the National Parks and
Access to the Countryside Act 1949 by inserting a new clause
11A: (2) "In exercising or performing any functions in relation
to, or so as to affect, land in a National Park, any relevant
authority shall have regard to the purposes specified . . . and
if it appears that there is a conflict between those purposes,
shall attach greater weight to the purpose of conserving and enhancing
the natural beauty, wildlife and cultural heritage of the area
. . ." The other purpose is "promoting opportunities
for the understanding and enjoyment of the special qualities [of
National Parks]". Back
8
The Powers and Duties of the Countryside Agency, Bircham
Dyson Bell: (1) General Functions; Part I s 1(2). Back
9
Our Countryside: the future, chapter 9, paragraph 9.5.2. Back
10
Tranquillity Mapping: Developing a Robust Methodology for Planning
Support is a project co-sponsored by CPRE's North East Regional
Group; The Countryside Agency; the North East Regional Assembly;
Northumberland Strategic Partnership; Northumberland National
Park and Durham County Council. Back
11
The MONARCH project has investigated the implications of climate
change models for selected species. This project has been undertaken
by the Environmental Change Institute, Oxford University; ADAS;
the British Trust for Ornithology and CABI Science. Back
12
See: "Toxic Chemicals and Wildlife: Raising Awareness
and Reducing Damage", NW Moore, in Nature Landscape and People
Since the Second World War, Tuckwell Press 2001 ISBN 1 86232
1477. Back
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