Memorandum submitted by Natural England
EXECUTIVE SUMMARY
Natural England has considered the Government's
proposed changes to regional organisations and processes set out
in the "Sub National Review" and we find the Select
Committee's Inquiry into the role of the RDA's both timely and
welcome.
We believe this is an opportunity to redefine
the strategic objectives of RDAs so that they focus on delivering
sustainable development, pursuing the goal of economic growth
whilst taking the natural environment seriously and emphasising
the social and environmental justice benefits of a healthy natural
environment. In particular Natural England proposes that;
— There should be a strong link between
central and local government on policy delivery to ensure that
national priorities for the environment are clearly seen as a
commitment for delivery by the RDAs;
— RDAs are given a clear steer that
their role in adding value includes ensuring sustainable development
outcomes and that RDAs should set out clear indicators for how
they expect the quality of development and the regional environment
to improve;
— RDAs should form strong partnerships
with Natural England and the Environment Agency (the government's
statutory environmental advisors), to deliver the proposed national
core sustainability framework in their region and use their strategic
environmental advice to raise the quality of the natural environment;
— RDAs should take the opportunity
to improve environmental outcomes by enhancing the coherence and
co-ordination in each region between different EU funding instruments
through bringing together these funding streams under a single
regional framework;
— The performance measurement of RDAs
should closely reflect the distinctive new circumstances under
which they will operate and adopt assessment techniques which
use the concept of economic, social and environmental well-being
rather than a narrow measure of GVA to monitor performance and
inform policy.
1.0 INTRODUCTION
1.1 Natural England is a statutory body
created in 2006 under the Natural Environment and Rural Communities
Act and charged with the responsibility to ensure that England's
unique natural environment, including its flora, fauna, land and
seascapes, geology and soils are protected and improved.
1.2 Natural England's purpose is to ensure
that the natural environment is conserved, enhanced and managed
for the benefit of present and future generations, thereby contributing
to sustainable development.
1.3 Natural England is a national body with
strong regional presence, delivering positive outcomes for the
natural environment through a range of programmes and delivery
mechanisms, not least of which is the dispersement of some £2.9bn
over 2007-2013 of European funded agri-environment schemes directly
to land managers. Natural England works with a wide range of local
and regional partners—including the Regional Development
Agencies—and has a duty to co-operate and engage with local
authorities in their place making role. The recent SNR proposals
further emphasise this duty of co-operation at local and regional
level.
2.0 MAIN COMMENTS—ARRANGED
IN ORDER
OF THE
BRIEF FOR
THE INQUIRY
2.1 The need for a level of economic development/
business/ regeneration policy delivery between central and local
government
2.1.1 Natural England agrees that central
and local government need to have a strong and active relationship
over policy delivery. It should not be so tightly defined that
it constrains meeting the distinctive needs of regions, but is
sufficient to ensure that Government policy for the natural environment
is being delivered effectively as an integral part of a regional
economic and regeneration agenda.
2.1.2 We believe there is a key risk that
individual RDAs, through their new roles under the SNR proposals,
might emphasise economic performance over sustainable development
and the quality of the natural environment. In turn there is the
possibility that the spending programmes of RDAs and local authorities
(and other regional stakeholders) will be framed within the context
of an integrated regional strategy that may not address significant
natural environmental issues. This would fail to deliver Government
policy for sustainable development.
2.1.3 The economic development/business/regeneration
policy delivery relationship between central and local government
should seek to ensure that the natural environment, including
the delivery of PSA targets, is considered as an integral part
of delivery and that separate regional initiatives in these areas
contribute to and do not undermine the coherence of Government
policy.
2.1.4 This relationship should also define
the policy linkages and ensure a balanced agenda which delivers
equitably across the whole sustainable development agenda. This
should look more roundly at the value of the environment to economic
development and, in particular, the role of ecosystem services
in supporting the regional economy and community well-being.
2.1.5 This principle applies also to the
delivery of EU Structural Funds programmes, which is highly decentralised
to the regions and local partners, and the Rural Development Programme
which is a shared responsibility between Natural England and the
RDAs. Through these programmes the RDAs are required to deliver
sustainable development and should include a focus on a range
of environmental outcomes. It is important that opportunities
for consistently delivering environmental outcomes are realised
by RDAs with the partners.
2.1.6 Environmental policy operates to a
clear set of national and internationally agreed standards and
targets and the national delivery of most aspects of EU environment
policy is led by DEFRA, Natural England and the Environment Agency.
In order to ensure that this policy is delivered properly at the
regional and local level, Natural England would urge that the
RDAs should agree a common understanding of the environmental
priorities and targets with Government and its agencies, so that
they can be actively coordinated and promoted through the delivery
of all regional priorities, plans and programmes.
2.1.7 Natural England is a national body
with a strong regional structure and so we are well placed to
advise the RDAs on the delivery of national targets for the natural
environment and their integration with regional development and
social priorities.
2.2 The effectiveness of RDAs and their role
in adding value
2.2.1 The SNR proposals will challenge whether
RDAs are operating effectively and adding significant value to
deliver sustainable development in their region. It radically
changes the responsibilities of RDAs and should require that RDAs
establish new expectations of the quality of development and outcomes
from regional investment.
2.2.2 As a result of their not being given
clear direction on the delivery of sustainable development and
high quality environmental outcomes, RDAs have, to a certain extent,
been "piggy in the middle". For example, in 2006, Natural
England gave evidence to a National Audit Office review of RDAs,
expressing concern that Advantage West Midlands (AWM) was not
being effective in ensuring sustainable development outcomes.
NAO stated that this view contradicted business interviewees,
who reported that they were being pushed to consider the sustainable
development agenda, which raised issues of whether businesses
were moving as fast as they were able.
2.2.3 Unfortunately, there is some evidence
which suggests that even the RDAs are not clear on what value
they were adding, as a result of inadequate monitoring of strategic
added value (SAV). GHK consultancy, assessing the SAV of AWM for
the review of the Regional Economic Strategy in 2006, concluded
that it was extremely difficult to demonstrate some aspects of
SAV, particularly in relation to outcomes from spend as their
monitoring and tracking systems were inadequate.[162]
A key issue in future, therefore, will be how sustainable environment
and development ambitions are set out and monitored through any
new Tasking Output Framework.
2.2.4 RDAs should, therefore, through regional
strategies and refreshed investment programmes, set out clear
indicators for how they expect the quality of development and
the regional environment to improve. This will allow government
and regional stakeholders to judge the value being added by RDAs
over current practice and for future delivery; future scrutiny
should consequently be examining RDA's record in adding value
to the delivery of social integration and well-being, and environmental
benefits through regional investment.
2.2.5 As RDAs devolve activity and funds
to local authorities, their other critical role in adding value
will be to provide the strategic regional and sub-regional steer
and guidance for local delivery. Additionally, the terms and conditions
under which funds and responsibility are delegated will need to
ensure that natural environment and social outcomes are a requirement
of delivery, as part of the achievement of sustainable development.
2.3 RDA expertise
Technical Skill Sets
2.3.1 Natural England believes the RDAs,
understandably, have limited skills sets to address the spectrum
of work required for preparing Integrated Regional Strategies
(IRS), particularly to address Spatial Strategy, as well as the
wider challenge of delivering integrated economic, social and
environmental well-being. Under the SNR proposals, this lack of
expertise may be further exposed as IRS are expected to at least
consider all the other "regionally adopted second tier"
strategies.
2.3.2 In particular, RDAs lack "in-house"
forward planning and spatial planning expertise and, again understandably,
have an even more limited appreciation of delivery of policy through
effective development control. The RDAs will have to build capacity
and capability to understand these aspects of planning. At the
moment Natural England invests considerable resources in reviewing
planning applications for development proposals and assuring environmental
quality. In the light of this experience, Natural England would
expect the RDAs to use the new regional strategies as an opportunity
for improving the standard of development.
2.3.3 The ability of RDAs to access external
expertise and bring that into their decision-making processes
in a joined-up way is particularly important in reference to environmental
challenges within regional development. For example, catchment
flood management, landscape-scale improvements to biodiversity
and climate change adaptation will demand sub-regional or regional
level expertise which the RDAs will not generally possess. These
challenges are also an opportunity to deliver significant environmental
solutions to national and regional priorities, as they are often
linked to economic development and regeneration challenges such
as improving the quality of place to attract investment.
2.3.4 Natural England has observed good
practice, for example, in Yorkshire Forward's investment in external
capacity such as the Regional Environment Forum and, as a principle,
RDAs should be asked to actively seek the expertise from its regional
and local stakeholders.
2.3.5 In particular, RDAs should invite
Natural England, the Environment Agency (the Government's statutory
environmental advisors), Local Authorities and other stakeholders
(such as the Sustainable Development Commission) to help interpret
and deliver the proposed national core sustainability framework
in their region. In turn, the strategic environmental advice should
inform RDA and local authority practice to ensure projects deliver
exemplary standards of carbon management, resource protection
and a high quality natural environment.
2.3.6 Natural England will wish to work
with RDAs in developing their capacity and the capacity of local
authorities to address natural environment issues as part of their
roles in delivering outcomes.
RDA BOARDS
2.3.7 We suggest that the composition of
RDA Boards needs to demonstrate the inclusion of a wider agenda.
The appointment of RDA Board members has generally been of those
with skills and experience in business rather than with a wider
skill set that reflects the potential new roles of RDAs for housing,
planning, sustainable development and wider regeneration. Government
should ensure the RDA Boards consist of members with extensive
experience in sustainable development and the natural environment
to complement business and economic development skills.
EVIDENCE AND
REGIONAL OBSERVATORIES
2.3.8 We welcome the importance attached
to developing evidence-led integrated strategies under SNR. In
the absence of Regional Assemblies, the RDAs role in assuring
the quality of the evidence base will be crucial for sound decision
making. RDAs should be asked to fully support the development
of current and future knowledge capacity at local and regional
levels, particularly through the Regional Observatories (RO's)
or equivalents. Not all regions have RO's and where they do exist
there are significant variations in the level of support they
receive, which leads to variations in the quality of the evidence
base.
2.4 The extent of, and need for, their overseas
activities
No comments.
2.5 The consequences of expanding the RDA
remit to include new functions, as proposed by the Sub National
Review, including the delivery of EU funding
2.5.1 Challenge of integrating spatial, environmental
and economic strategies
We believe the importance of ensuring a healthy
natural environment must not be squeezed by the emphasis given
to economic development and economic growth in SNR and nor should
it be restricted by the current capability of the RDAs. RDAs need
to see their new role and especially the new single integrated
strategies, as facilitating delivery across the whole of the sustainable
development agenda.
2.5.2 There is the consequent risk that
the spending programmes of RDAs, local authorities and other regional
stakeholders may fail to deliver sustainable development and address
significant environmental issues unless they are framed within
the context of properly integrated regional strategies.
2.5.3 RDAs should be given clear direction
to produce the new strategies in line with the guidance in PPS1
(Delivering Sustainable Development, 2005) which promotes
integration. Para 1.3 of PPS1 states "Development plans
should ensure that sustainable development is pursued in an integrated
manner, in line with the principles for sustainable development
set out in the UK strategy".
2.5.4 To give confidence that development
outcomes will be environmentally sustainable, RDAs will need to
be very open and inclusive in preparation of the strategies and
in their decision making processes. RDAs should exploit the opportunity
to work with Natural England and the Environment Agency as statutory
environmental advisors in preparing regional strategies, programme
design and with scrutiny processes. This will support Government's
efforts to align the efforts of national and regional agencies
and deliver its PSA 7, 20, 27 and 28 targets on regional economic
performance, housing, the natural environment and climate change.
EUROPEAN FUNDING
2.5.5 The RDAs already deliver, or significantly
influence, through Regional Economic Strategies, the spend of
a substantial proportion of EU funding.[163]
Sustainable Development and integrated approaches are a requirement
for the delivery of these European Funds and have needed the engagement
of the environmental agencies. For example, the Rural Development
Plan for England, co-financed by EAFRD has required the RDAs,
Natural England and Forestry Commission to work together to develop
"Regional Implementation Plans". These plans, intended
to ensure integration across the four "Axes" (objectives),
were guided in part by the Regional Economic Strategies. For the
Structural fund Programmes, Natural England or other environmental
agencies and stakeholders are sometimes represented on the Programme
Monitoring Committee.
2.5.6 The use of the Regional Economic Strategies
to guide RDPE, ERDF and ESF spend and the importance of the EAFRD
for incentivising land managers to deliver environmental priorities
(which is approx 80% of RDPE fund) will in future sit alongside
the importance of environmental considerations to Regional Spatial
Strategies. This strongly suggests that the new integrated regional
strategies will need to fully embrace the environmental dimension
and that these new strategies will be important in determining
European funding priorities.
2.5.7 In principle, Natural England believes
that bringing together these funding streams under a single regional
framework offers the opportunity to enhance coherence and co-ordination
in each region between different EU funding instruments. This
will require the RDAs to work even more closely with Natural England
given that agri-environment schemes form the largest single component
of Axis 2 of the England Rural Development Programme and are currently
delivered by Natural England through its regional structure.
2.5.8 Axis 2 has a clear set of national
objectives, driven in part by national and international environmental
targets and obligations. Natural England believes that this delivery
arrangement strikes the correct balance between local and national
delivery. There is potential for further integration of the delivery
of agri-environment schemes with regional priorities and so securing
more public benefits from these funds. The regional framework
set by RDAs needs to respect and make appropriate contributions
to key national and international environmental targets.
2.5.9 It is unclear how or whether the SNR
will impact on other EU funding. There are EU centrally managed
funds for which a case could be made for greater regional control.
For example, the Competitiveness and Innovation Programme[164]
which provides funding inter alia for eco-innovation, and support
for SME's in the forestry and agro-food sectors. The current tender
system makes integration with other EU funding streams difficult.
LINKING INTEGRATED
STRATEGIES AND
REGIONAL INVESTMENT
2.5.10 Under the SNR proposals, RDAs will
have a significantly different role, well beyond their current
business-led economic development role. RDAs will have the opportunity
to bring forward regional strategies setting out a 15-20 year
vision for a region. Natural England suggests that RDAs must include
a vision for the protection and enhancement of the natural environment
as part of an integrated strategic approach to economic development
and the natural environment. The single or integrated regional
strategies (IRS) should set out the major environmental challenges
that regions need to address—we set out the scope and nature
of these challenges in our response to the SNR consultation which
ended in June 2008. RDAs should, as a consequence, then set out
a framework for investment programmes to enhance the region's
environmental assets, especially those which will allow the region
to help deliver economic growth and to adapt to major environmental
challenges such as climate change.
2.5.11 Natural England strongly supports
the proposal for improving the local evidence base through the
new duty on local authorities to undertake economic assessments.
RDAs should have an obligation to ensure that the improved evidence
base for an area includes reviewing the contribution that the
environment makes to well-being and could make to economic prosperity
at the local level.
INTEGRATION OF
REGIONAL DELIVERY
THROUGH THE
SPATIAL LEVELS
2.5.12 The SNR makes reference to the local
authority performance management framework and a new role for
local authorities in undertaking local economic assessments. This
reinforces the challenge for RDAs to ensure the alignment of priorities
and delivery at all spatial levels from national to regional and
local.
2.5.13 RDAs, working with local authorities
and other stakeholders, can explicitly link the different spatial
levels around the Place Making agenda (set out in Government's
"Creating Strong, Safe and Prosperous Communities").
In the Place Making agenda, there is an ambition of aligning all
investment resources from regional agencies and local authorities
to meet community needs. The single regional strategies will also
become the focus for concentrating the efforts of many, not just
RDA programmes, on regional priorities. This would align national
and regional priorities with regional and sub-regional investment
programmes and performance management of the delivery by local
authorities and other bodies.
2.5.14 RDAs will, therefore, need to create
confidence amongst all stakeholders that stakeholders' own delivery
objectives will also be met through closer collaboration and alignment.
From Natural England's perspective, this should be achieved through
RDAs actively seeking agreement on local, regional and national
environmental priorities.
SUB REGIONAL
AND PROGRAMME-BASED
DELIVERY
2.5.15 We welcome the new emphasis on the
role of RDAs becoming programme based, in the expectation that
a more strategic role will allow them to embrace the critical
environmental challenges faced by regions. The design of regional
funding programmes and delivery plans should explicitly embed
the enhancement of the natural environment as a required outcome.
RDAs should have the confidence of setting out environmental quality
ambitions alongside economic targets and to avoid previous weaknesses
of treating environmental sustainability as a separate theme.
2.5.16 The RDAs should use the lessons of
the EU infrastructural programmes (such as described in "The
Effectiveness Of EU Structural Funds In Delivering The Government's
Environmental Objectives, Defra 2005—The Fraser Report)
to inform the design of regional funding programmes on how best
to integrate environmental considerations into mainstream funding
programmes; as one the Competent Environmental Authorities for
EU funding programmes, Natural England would be pleased to work
with RDAs to develop best practice.
2.5.17 Natural England supports the proposal
in SNR for a statutory status of collaborative arrangements across
sub-regions, which can be for purposes wider than purely economic
development. RDAs have a significant role in facilitating the
use of this tool by local authorities and others and Natural England
would urge that RDAs should support them as a means of tackling
environmental issues that also cross administrative boundaries.
In doing so, RDAs will need a greater understanding of the role
and value of ecosystems in providing services which support economic
activity and which contribute to social well-being. The joint
work that the North West Regional Development Agency is doing
with Natural England in the Natural Economy Northwest Project
is a demonstration of how the environmental assets of the region
complement economic objectives through investment, for example,
in green infrastructure, landscape scale environmental enhancement
and habitat creation.
2.6 The accountability of RDAs
2.6.1 Regional Assemblies were able to consider
regional social and environmental issues through their development
of the RSS and scrutiny of RDAs. Whilst Natural England welcomes
the proposal for independent examination of IRS along the lines
of the current model used for RSS, this kind of scrutiny is toward
the end of the process and is, therefore, less powerful than embedding
sustainable development at the fore of future strategies. To be
properly accountable, RDAs should establish clear and transparent
fora and processes in their region to ensure that social and environmental
stakeholder expertise fully informs and shapes the design. RDAs
might consider new arrangements, such as using the Regional Sustainable
Development Roundtables or establishing in each region an external
advisory Sustainable Development Panel.
2.6.2 We suggest that RDAs should work closely
with the Audit Commission in their role as auditor for the place
making agenda and so link the different spatial levels of delivery.
RDA driven strategies need to reflect the strategic environmental
priorities of the region and a clear alignment of delivery programmes
with environmental objectives, drilling these down to Local Area
Agreements (LAA) and to the discharge of Comprehensive Area Assessment
(CAA) by the Audit Commission.
2.6.3 We recommend as good practice the
Yorkshire and Humberside Scrutiny Process alongside "Progress
in the Region", an annual report in the region that in some
detail looks at all aspects of quality of life.
2.7 How RDA performance has been measured
in the past and will be measured in future
2.7.1 We suggest the performance measurement
of RDAs should closely reflect the distinctive new circumstances
under which RDAs will operate. Not to do so would result in highly
unbalanced working. RDAs should set out a wider measure of success
which includes not only economic but also other factors which
contribute to regional and community wellbeing, including those
things for which currently it is difficult to get a monetary value,
such as the role of ecosystem services in underpinning economic
development.
2.7.2 Natural England would therefore ask
RDAs (and local authorities) to adopt assessment techniques which
use the concept of economic, social and environmental well-being
rather than a narrow measure of GVA to monitor performance and
inform policy. A potentially good model is emerging from the East
Midlands Development Agency, which is leading in developing the
Index of Sustainable Economic Wellbeing and which has already
been picked up by seven of the nine RDAs. This model uses robust
data sets to measure well-being, though EMDA recognise that more
could be done, and Natural England is working with EMDA to further
explore the potential of this model and develop the social and
environmental indicators.
2.7.3 Regional strategies will need to set
out environmental standards which will be expected to be achieved
by the end of the 20 year period, as well as the environmental
limits which will determine the acceptability of growth. The strategies
should set out clear baselines and challenging targets for the
quality of the natural environment, carbon management and climate
change adaptation etc for programmes and for delivery projects
that flow from the new strategies. It is on these that the RDA
and the region should be measured.
2.7.4 We support the extension of the EIP
model into the new arrangements and that SEA will be used, subject
to adequately integrating other assessments such as the Habitat
Regulations.
2.7.5 We suggest that RDAs, in their new
role, should be required to be exemplars of sustainable development
policy and practice.
3.0 CONCLUSION
3.1 The Government should, therefore, take
this opportunity to redefine the strategic objectives of RDAs
so that they focus on delivering sustainable development. RDAs
should be charged with pursuing the goal of economic growth whilst
taking the natural environment seriously and emphasising the social
and environmental justice benefits of a healthy natural environment.
In particular Natural England believes RDAs should set out a clear
direction for how they expect the quality of development and the
regional environment to improve and that they adopt approaches
and assessment techniques which use the concept of economic, social
and environmental well-being rather than a narrow measure of GVA
to monitor performance and inform policy.
19 September 2008
162 Evaluation of the West Midlands Economic Strategy
(GHK Consulting with input on housing from Centre for Urban &
Regional Studies, University of Birmingham). Set out the development
of the WMES and key issues and priorities. Examines the Strategic
Added Value (that is leadership, influence and coordination) provided
by elements of the WMES. Reflects on key issues and considerations
for future WMES development, including a summary of key emerging
policy challenges. Back
163
For the period 2007-2013 RDAs will be delivering £2500m European
Regional Development Fund (ERDF) and; £620 m European Agricultural
Fund for Rural Development (EAFRD) monies (based on Axis 1 and
3 budget) ( Total English EAFRD Budget-£3890m). The English
ESF Programme, influenced by the Regional Economic Strategy, is
£4000m (£2000m ESF, £2000m national funds), distributed
regionally through the Learning and Skills Council. The CAP Pillar
1 budget is £20950m distributed through the RPA. All figures
approx and exchange rate dependent. Back
164
Managed centrally by DG Enterprise on the basis of annual EU wide
calls. Back
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