Memorandum submitted by the Royal Society
for the Protection of Birds (RSPB)
SUMMARY
The Royal Society for the Protection of Birds
(RSPB) wants the best institutional arrangements to ensure the
protection and enhancement of biodiversity in the English regions.
We believe that there are deficiencies in most,
if not all, in most aspects of the current regional and sub-regional
arrangements to deliver "sustainable growth", which
is defined in the government's regional economic performance public
service agreement (PSA) as "economic growth that (|) is
within environmental limits, but also enhances the environment
and delivers social welfare".
As presently framed, we do not believe the Sub-National
Review reforms will lead to improved outcomes for wildlife, habitats,
landscapes and the practical delivery of sustainable development.
We therefore propose that:
— Regional Sustainable Development
Agencies are created with a new, stronger sustainable development
duty.
— Sustainable development is the explicit,
overarching goal and context for the new Single Integrated Regional
Strategies, and underpinned by a new sustainable development metric.
— Single Integrated Regional Strategies
should be robustly assessed and scrutinized by independent champions
of sustainable development.
— Formal arrangements be introduced
to enable civil society to participate in decision-making.
— The value of natural assets is recognized
in decision-making.
INTRODUCTION
1. The RSPB is the charity that takes action
for wild birds and the environment. We are the largest wildlife
conservation organisation in Europe with over one million members.
2. We have a significant experience of English
regionalism over the last decade, including: taking places on
the boards of Regional Development Agencies and their advisory
groups; as members of Regional Assemblies, their executives, and
in their scrutiny function of Regional Development Agencies (RDAs);
as members and associates of regional sustainable development
champion bodies; as members of regional groupings such as Regional
Rural Affairs Forums; as members and leading advocates of regional
environmental fora; via substantial inputs into Regional Spatial
Strategies (including Examinations in Public), and finally via
the many contacts and experiences we have at the local level including
with local government, Local Strategic Partnerships and delivery
structures of many kinds.
CREATING REGIONAL
SUSTAINABLE DEVELOPMENT
AGENCIES WITH
A NEW
STRONGER SUSTAINABLE
DEVELOPMENT DUTY
Statutory duty to deliver regional sustainable
development
3. Under existing legislation (RDA Act 1998),
Regional Development Agencies (RDAs) have a statutory purpose
"to contribute to the achievement of sustainable development
in the United Kingdom where it is relevant to its area to do so".
This purpose is too weak to ensure sustainable development is
embedded and delivered under the proposed regional arrangements.
To ensure it is not an "add on" option for Regional
Development Agencies, in our view it is imperative they are given
a statutory duty to deliver sustainable development. In practice,
this should mean that they are tied to delivering the twin goals
of sustainable development as set out in the Government's own
document "Securing the Future", namely to deliver a
strong and healthy society which lives within environmental limits.
Create Regional Sustainable Development Agencies
4. We suggest that Regional Development
Agencies (RDAs) should be organised to become Regional Sustainable
Development Agencies (RSDAs) and become accountable to CLG and
DEFRA as well as BERR, thus reflecting their new sustainable development
purpose and contribution to associated Public Service Agreements
(PSAs).
Gap in capacity and skills
5. In our experience, RDAs do not have sufficient
in-house capacity, experience or expertise to deliver economic
development within environmental limits, or develop spatial planning
within the wider context of sustainable development.
6. It will be important to ensure that there
are environmental skills to sit alongside economic and social
expertise, especially within the RDAs. RDA Boards should include
environmental expertise to ensure that the environmental considerations
are integrated into policy and delivery. To ensure the required
balance in expertise, we suggest that the Secretary of State for
Environment, Food and Rural Affairs has a role in the appointments
to RDAs' boards.
Role of environmental stakeholders in the new
governance arrangements
7. Currently RDAs, regional Government Offices
and many non-environment-centred regional institutions lack any,
enough, or the right environmental skills, specialists, or advocates
to effectively understand and then engage with environmental priorities
and delivery.
8. A number of regional sustainable development
champions (eg sustainable development roundtables) and Social,
Economic and Environmental partnerships (SEEPs), many of which
are run under the auspices of Regional Assemblies, provide valuable
advice and influence to regional policies. Their role has been
widely recognised as helping the region develop in an inclusive
and dynamic manner. However, this valuable regional expertise
risks being weakened and lost with the new governance arrangements.
9. It is essential that environmental, social
and economic representatives continue to have an effective voice
in decision-making and help ensure genuine improvements in environmental
and social wellbeing.
10. As part of ensuring "fit for purpose"
engagement in the proposed regional arrangements the Government
should develop a set of minimum standards. These would ensure
the intent set out in Prosperous Places (page 6) that ..."
the new arrangements will place a premium on effective stakeholder
engagement and management".
11. We recommend that each region should
have at a minimum a strong and identifiable network of environmental
interests, with the right capacities to be effective. The regional
network needs to work effectively both at an internal environmental
sector level, and provide a one-stop shop for external regional
actors. The network should include the statutory environmental
sector, but it must be able to be independent and have sufficient
funding to perform its role effectively.
12. The network should be the source of
environmental representatives in any regional stakeholder groupings
that may replace the Regional Assemblies' current SEEP (social,
economic and environmental) representative arrangements.
REGIONAL ACCOUNTABILITY
AND SCRUTINY
ARRANGEMENTS TO
SUPPORT THE
DELIVERY OF
SUSTAINABLE DEVELOPMENT
13. The new accountability and scrutiny
arrangements should focus on ensuring that sustainable development
is delivered at the regional and sub-regional levels.
14. The RSPB proposes that existing regional
sustainable development champion bodies (round-tables etc), threatened
as they are with the regional arrangements in transition, must
be reconfirmed with a formal place in the new post-SNR arrangements.
They should be provided with sufficient resources to play their
"challenge" role and ensure that policies and plans
are developed and implemented respecting environmental limits.
Regional ministers should have an explicit role to ensure sustainable
development happens in practice in their regions.
15. The Government must take care to ensure
that scrutiny arrangements for sustainable development have sufficient
sanctions (eg via regional scrutiny arrangements, including the
regional ministers) to have effect.
SUSTAINABLE DEVELOPMENT
AS THE
EXPLICIT, OVERARCHING
GOAL AND
CONTEXT FOR
THE SINGLE
INTEGRATED REGIONAL
STRATEGIES (SIRS)
16. We remain concerned that there is too
great a focus on promoting economic growth. In Prosperous Places,
it is suggested that the Government will only expect Single Integrated
Regional Strategies to contribute to Public Service Agreements
(PSAs) on economic growth and housing. This is too narrow, particularly
if the SIRS are to incorporate the existing Regional Spatial Strategies,
which require an integrated approach to achieving economic, social
and environmental objectives.
17. In its Sustainable Development Strategy,
Securing the Future (2005), the Government's twin objectives
for sustainable development are stated as achieving "a strong,
healthy and just society and living within environmental limits
by means of sound science, good governance and a sustainable economy".
This helps to position sustainable economies as means rather than
ends objectives; quality of growth matters not just quantity.
18. The overarching context and framework
for the Single Integrated Regional Strategies must be the Government's
own approach to sustainable development, as set out in the Sustainable
Development Strategy. Furthermore, SIRS should reflect government's
wider commitments to sustainable development, climate change and
the natural environment and therefore be aligned to the relevant
Public Service Agreements 27 and 28.
Retaining and further developing nature conservation
policy in SIRS
19. The Government proposes to bring together
spatial and economic planning into one Single Integrated Regional
Strategy (SIRS). These strategies would set-out high-level strategic
priorities for housing and transport and be developed on the basis
of the economic evidence gathered at sub-regional level. We are
concerned that we would be losing the details of biodiversity
policies in the current regional spatial strategies. In the South
West of England, for example, the partnership "Biodiversity
South West" produced the South West Nature Map, which identified
the best areas in the region to conserve, create and connect wildlife
habitats at a landscape scale. Policy in the South West Regional
Spatial Strategy requires the local planning authorities to use
the Nature Map to identify local opportunities for biodiversity
enhancement, and specifically refers to the need to link habitats
"to create more functional units which are more resilient
to climate change". It is not clear where such policies,
which require a strategic approach, will fit in the proposed arrangements.
Include sustainable development metrics in the
implementation and monitoring arrangements of SIRS
20. The arrangements for monitoring Single
Integrated Regional Strategies should include the need to report
on sustainable development outcomes.
21. Gross Value Added (GVA) alone fails
as a metric of sustainable growth since it does not integrate
the environmental costs of economic growth. It does not track
real improvements in quality of life or environmental decline
caused by unsustainable economic activity.
22. We are concerned that RDAs will have
little incentive to promote sustainable development when their
performance is judged on meeting a new single growth target, measured
by GVA. The new RDAs (with a strengthened sustainable development
duty) are required to report on how they are implementing "sustainable
growth". To give sustainable development delivery traction
and ensure that the environmental impacts of the economic growth
are monitored, we suggest that sustainable development metrics
are used alongside GVA. This would allow biodiversity to be recognised
as a key indicator of sustainable development and a sustainable
economy. We suggest the Sustainable Development Commission is
given the urgent task to appraise and propose such a metric.
DEVELOP AND
USE ROBUST
EVIDENCE BASE
TO INFORM
SIRSS AND
FUTURE POLICY
Developing the environmental evidence base
23. We welcome the principle of basing the
SIRS on a robust evidence base. This must be far more than an
assessment of local economic conditions, and embrace all relevant
evidence. The proposed new economic assessment duty for local
government should be more fully reflective of the sustainable
growth definition in the Regional Economic Performance PSA. Local
authorities should assess the state of the environment within
their sub-region alongside their economic assessment.
Address the current lack of robust data on the
quality of the natural environment
24. We believe that, to be sustainable,
all policy and decisions must be developed and implemented respecting
environmental limits. Environmental limits are not tipping points.
A tipping point, in the context of sustainable development, describes
a point at which natural systems change states, often irreversibly
and with catastrophic consequences. To ensure the effective protection
and sustainable management of natural resources, environmental
limits must be set at a level before the tipping point. Environmental
limits need to be sensitive to the complexity of ecosystem processes,
connections at a landscape scale and the resilience of ecosystems
in the face of cumulative pressures, such as climate change and
over-exploitation. If decision-makers do not fully understand
this complexity, we recommend that they adopt a precautionary
approach when defining limits and invest in further research.
25. There remain significant gaps in data
available on environmental resources across the regions. The current
gap in data needs to be addressed, to allow for the definition
of environmental limits, in context of which regional economic
development can take place.
26. Measuring the quality and condition
of the natural environment at a regional scale is a difficult
task and some significant gaps exist. Particular gaps include
the condition of local wildlife sites and Biodiversity Action
Plan habitats.
27. Furthermore, the collection and management
of consistent regional data on important habitats, non-statutory
local sites and the location of key species remains one of the
key challenges to the protection of biodiversity.
28. We already have considerable evidence
of the value of the natural environment to the well-being of humans,
for example, to our health and through life support systems. However,
we would value a more robust assessment of the contribution the
environment makes to the regional economic well-being and understanding
of the implications (including financial) of any degradation of
its assets.
Develop and promote region-wide facilities for
storing environmental, economic and social data
29. There is a need to invest in the development
of online facilities for storing regional environmental, economic
and social data, including data on important species, habitats
and sites in the regions. Much of this data is currently held
by a variety of organisations in a number of different formats
and is often difficult to access. Easily accessible baseline data
will ultimately facilitate the development of regional strategies
and their appraisal, as well as RDAs' decision-making. Fife Council,
for example, recently launched a one-stop access to a range of
local and national data about Fife called "KnowFife"
in February 2007 (see http://knowfife.fife.gov.uk/).
INTEGRATING NATURE
CONSERVATION INTO
ALL REGIONAL
POLICY AND
DECISION-MAKING
30. A key challenge facing regions is to
integrate environmental considerations and policies into all regional
policy and decision-making at an early stage, informed by a robust
evidence base. In order to integrate the environment as part of
the broader suite of regional priorities to be addressed through
the Single Integrated Regional Strategies, there is a need to
use Sustainability Appraisal, incorporating the requirements of
the Strategic Environmental Assessment (SEA) Directive, and Habitat
Regulation Assessment (HRA) of the Single Integrated Regional
Strategies. This will facilitate and promote the integration of
environmental considerations into SIRSs. The effective use of
these established assessment tools should also greatly facilitate
the collection and use of baseline data.
19 September 2008
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