Supplementary memorandum submitted by
Campaign to Protect Rural England (CPRE)
1. On 18 January 2006 CPRE provided oral
evidence to the Environment Agency inquiry. We promised to reflect
on a particular question posed during the session and hope that
this supplementary memorandum will assist the Committee in its
deliberations. In light of other evidence received by the Committee,
and further developments, we also have taken this opportunity
to comment on how forthcoming planning policy could strengthen
the consideration given to the water environment.
POWERS OF
THE ENVIRONMENT
AGENCY WHEN
PLANNING APPLICATIONS
ARE SUBJECT
TO APPEAL
2. We were asked whether CPRE believes that
the powers of the Environment Agency are adequate for individual
planning applications, when these are subject to an appeal and
being heard before the Planning Inspectorate (Question 223). We
believe it is very important that the advice of the Environment
Agency regarding flooding and water abstraction is given sufficient
weight in the planning system. This can be most effectively done
as part of the forward planning process, through the EA's advice
influencing the content of spatial plans like Regional Spatial
Strategies and Local Development Frameworks. We believe that regional
planning bodies, local planning authorities and planning Inspectors
should all attach much greater weight to the advice provided by
the EA as part of the process of plan preparation. Regarding individual
planning applications we believe the strengthening of national
guidance, as set out in draft Planning Policy Statement 25 (PPS25)
will assist considerably.
3. If an application goes to appeal, the
Planning Inspectorate also needs to have due regard to established
national and local planning policies. Providing the proposals
currently contained in draft PPS25 remain in the final document
we do not see the need for greater powers in terms of the EA's
advice. But it will be important for the Inspectorate to have
a clear understanding of the changes that will be introduced as
a result of PPS25. We would recommend the EA and Planning
Inspectorate work together to ensure all Inspectors are made sufficiently
aware of these changes in policy. This should be through formal
training, and could include providing a lead Inspector within
the Inspectorate who is able to advise on particularly complex
cases involving potential development on flood plains.
OTHER SUPPORT
FOR THE
ENVIRONMENT AGENCY
4. We believe the Government can support
the work of the EA in three principle ways. These are:
— adequate financial resourcing;
— strong environmental policies to
reduce stress on the natural environment; and
— seeking and responding positively
to the EA's advice on policy development.
5. With regard to the second of these, we
believe the publication of PPS25 provides an important opportunity
to address stresses on the water environment brought about by
the amount, location and design of new development. We recommend
that the remit of PPS25 as currently drafted be widened to encompass
other issues over the management of water as a natural resource.
It should thus become a PPS on water, rather than on the management
of floodplains. This should embrace, for example, how the planning
system should consider water abstraction from new development;
how changes brought about by climate change could affect the aquatic
environment and in turn influence patterns of development; and
clarify what "living within environmental limits", as
set out in the Government's Sustainable Development Strategy,
means in practice in relation to the water environment. Such a
change would be in keeping with the transformation of land use
planning into a broader spatial planning agenda with its increased
emphasis on the management of land. Failing this, we recommend
that these wider issues concerning water conservation are addressed
in any forthcoming PPS on climate change.
6. We hope this supplementary evidence assists
the Committee in its deliberations. Please do not hesitate to
contact us should you wish to discuss any of the issues raised
here.
CPRE
February 2006
| 
