Memorandum submitted by the Wildlife Trusts
(I). INTRODUCTION
(ii) The Wildlife Trusts (TWTs) are pleased
to respond to this inquiry into the role of RDAs, in light of
the changes proposed in the review of sub national economic development
and regeneration.
(iii) There are 47 local Wildlife Trusts
across the whole of the UK. We are working for an environment
rich in wildlife for everyone. With 765,000 members, we are the
largest UK voluntary organisation dedicated to conserving the
full range of the UK's habitats and species whether they be in
the countryside, in cities or at sea. We manage 2,200 nature reserves
covering more than 80,000 hectares; we stand up for wildlife;
we inspire people about the natural world and we foster sustainable
living.
(iv) We are particularly interested and
engaged in climate change adaptation, which we believe is critical
for people and wildlife in the UK. To this end, we are working
in partnership with a wide range of organisations to take forward
a large number of landscape-scale nature conservation programmes
that will contribute towards our vision of A Living Landscape
for the UK.
(v) The Wildlife Trusts work actively at
the regional level in England. We have been instrumental in helping
to shape regional planning policy and its impact on the environment
and climate change. We work closely with Government Offices, Regional
Assemblies and Regional Development Agencies (RDAs) in order to
improve decision-making and project delivery for the benefit of
wildlife and local people.
(vi) We would be pleased to provide further
information in relation to points raised in this response.
DETAILED COMMENTS
The following submission is structured around
6 key proposals that The Wildlife Trusts believe should be considered
in relation to the future role of RDAs as outlined in the SNR.
These proposals are, that:
— The RDA Act should be amended to
ensure that furthering sustainable development is a core RDA objective.
— RDAs should commit more resources
to valuing, protecting and enhancing the natural environment.
— RDAs should have sufficient environmental
and planning expertise.
— RDAs should take more action on climate
change adaptation.
— RDA Boards should contain the full
range of sustainable development skills.
— The RDA scrutiny process should be
more robust and consistent.
1. THE RDA ACT
SHOULD BE
AMENDED TO
ENSURE THAT
FURTHERING SUSTAINABLE
DEVELOPMENT IS
A CORE
RDA OBJECTIVE
1.1 The Wildlife Trusts believe that the
Regional Development Agencies Act 1998 should be amended to ensure
that sustainable development is a core purpose of the RDA going
forward into its potential new role as regional planning body.
1.2 We are seriously concerned about the
Government's intention to use regional planning as a tool to deliver
economic growth through the transfer of the regional assemblies'
planning function to the RDAs.
1.3 As stated on page 20, paragraph 3.3
of Prosperous Places "The RDAs will lead on the development
of regional strategy, ensuring that economic development and spatial
planning are closely aligned". According to the Government's
Planning Policy Statement (PPS) 1 "Sustainable Development
is the core principle underpinning planning" ie planning
should be socially, environmentally and economically sustainable.
1.4 The proposals in Prosperous Places
contradict this core principle and undermine the Government's
commitments as set out in the UK Sustainable Development Strategy:
"Securing the Future" (2005) and "Securing the
Regions' Futures" (2006).
1.5 The Wildlife Trusts strongly believe
that sustainable development must remain the core principle underpinning
planning. At present the purpose of RDAs only extends to "contributing
towards SD", the fifth of five purposes. In light of the
SNR proposals we do not think that this purpose is strong enough
to ensure that sustainable development is fully integrated into
land use planning at the regional level rather than merely being
seen as an add on.
1.6 As an absolute minimum, the first purpose
should be to promote sustainable development. But we would propose
that the objectives of the Regional Sustainable Development
Agencies might be:
— To further sustainable development.
— To further economic development and
regeneration.
— To promote business efficiency, investment,
competitiveness and employment.
— To enhance the development and application
of skills relevant to employment.
National Audit Office Assessment
1.7 During 2006/2007, The National Audit
Office Independent Performance Assessment of RDAs identified that
in many regions the RDA was using a Sustainable Development Framework,
or other sustainable development tools, to assist in the decision
making process for projects and initiatives (Case Study 1).
1.8 Some RDAs had a dedicated team to work
on sustainability (eg EMDA and EEDA) and others had made it a
key theme of the Regional Economic Strategy (eg Advantage West
Midlands).
1.9 However, the NAO assessments also states
that the level of sustainable development knowledge within each
RDA still varies greatly, and is applied inconsistently across
the regions.
1.10 In addition, the NAO reports identified
that some RDAs could do more to show a tangible commitment to
SD, particularly in delivering their own operations (eg SWDA)
and the priority afforded to monitoring SD (eg One North East).
This inconsistency means that it is very likely decisions are
being taken and policies being developed which could lead to unsustainable
outcomes, and so contradict one of the current purposes of RDAs
"to contribute to sustainable development", thus providing
a powerful reason for amending the underlying legislation.
CASE STUDY
1: INTEGRATING SUSTAINABLE
DEVELOPMENT WITHIN
REGIONAL STRATEGIC
AND CORPORATE
PLANNING
The East of England Development Agency has established
an Integrated Sustainability Appraisal (ISA) process for the emerging
RES that brings together the Strategic Environmental Assessment,
sustainability appraisal, equality and diversity appraisal, rural
and urban proofing and health impact assessment into a single
methodology. This methodology could be used as an exemplar to
other RDA's.
The benefit of the ISA, which runs alongside
the RES development process, has been to ensure that critical
evidence, such as the environmental implications of particular
policies and the capacity of important natural assets, were fed
into the strategy as it evolved. This approach has the potential
to avoid lengthy delays and conflicts, if the evidence is taken
fully into account. It should result in a strategy that delivers
positive benefits for the economy, society and environment of
the region.
Sustainable Development Teams
1.11 We believe that the establishment of
Sustainable Development teams in some RDAs has aided and improved
policy development. However, we still believe that policies within
many Regional Economic Strategies could be made more positive,
for example focusing on enhancing the environment rather than
simply avoiding and mitigating damage.
1.12 It is important to note that the presence
of SD teams does not necessarily indicate effective delivery of
sustainable development in the region. For example, we have observed
that in the East Midlands the SD unit had been sidelined, adding
a sustainability gloss onto the economic development case, rather
than integrating and embedding SD into the work of the RDA. This
situation is starting to change but the influence of the SD unit
will always be limited by the organisational context in which
they operate. Amending the RDA Act will reinforce the central
importance of sustainable development, and ensure that the RDAs
resources and influence are channelled to this end.
1.13 If the Government is serious about
sustainable development, then we believe that it should not undermine
the progress that the RDAs have made on SD, by focusing in the
SNR on economic development and housing growth. The Wildlife Trusts
believe that the emphasis on the economy will be at the expense
of communities and the natural environment, and is therefore a
backwards step.
2. RDAS SHOULD
COMMIT MORE
RESOURCES TO
VALUING, PROTECTING
AND ENHANCING
THE NATURAL
ENVIRONMENT
2.1 The Wildlife Trusts believe that, despite
some progress in terms of understanding their role in delivering
sustainable development that the RDAs could commit more of their
resources to understanding how the protection and enhancement
of the natural environment benefits the economy, and to securing
the future of these assets in the long term (Case study 2).
CASE STUDY
2: VALUING THE
NATURAL ENVIRONMENT
The Natural Economy Northwest is a multi-partner
initiative led by Natural England, the Northwest Development Agency
and the SITA Trust (which supports community and environmental
improvement projects).
The initiative seeks to maximise the economic
benefit from existing and new investment in the region's natural
environment. It draws on the expertise of specialists working
in tourism, business development and the environment sector, including
the Wildlife Trust.
The initiative provides direction and leadership.
It enables delivery on the ground, through new approaches to project
planning, training and joined-up funding across the region. The
programme also involves mapping the socio-economic benefits that
the region's natural environment delivers; creating methodologies
for quantifying and reporting economic benefits; supplying training
and skills guidance; integrating natural tourism within the wider
visitor economy; marketing and communications; and facilitating
projects in areas as diverse as biodiversity, wetlands, woodlands
and Green Infrastructure.
2.2 The natural environmental assets of
each region make a significant contribution to attracting investment,
retaining skilled workers and quality of life (Case Study 3).
In addition, the natural environment also provides the basic ecosystem
services that underpin our way of life.
2.3 DEFRA has undertaken research which
makes the case for valuing ecosystem services and outlines a methodology
for establishing their Total Economic Value (Introduction to
valuing ecosystem services (2007)).
2.4 Through their Regional Renaissance activities
the RDAs should have a much greater leadership role in the development
of a landscape scale approach to investment in the natural environment,
using the expertise of conservation partners such as The Wildlife
Trusts.
2.5 There is some evidence of RDA investment
in projects that benefit the natural environment and local economy,
such as the Brockholes Wetland & Woodland Nature Reserve in
Lancashire and the Great Fen Project in Cambridgeshire. However,
RDA funding of this kind is still limited and on many occasions
is not distributed through a structured and well-resourced "Natural
Asset" investment programme.
CASE STUDY
3: REGIONAL INDEX
OF SUSTAINABLE
ECONOMIC WELL-BEING
We are aware of the work being undertaken by
the New Economics Foundation and three English Regional Development
Agencies (East Midlands, Yorkshire & Humberside and South
East England), to develop a Regional Index of Sustainable Economic
Well-being (ISEW).
This Index recognises that happiness is not
based on economic strength alone, and is instead based on an economic,
social and environmental macro cost-benefit analysis of the region.
EMDA has done a reasonable amount to include
social and environmental elements in its assessment of well-being.
However, the environmental element remains weak and focussed upon
avoidance of loss and mitigation, with environmental enhancement
not (yet) recognised as something that can improve economic and
well-being outcomes.
We support the development of this initiative,
and the persistence of the RDA in taking it forward, albeit with
further development on the environmental elements required, and
believe that even more could be achieved if the remit of all RDAs
was widened, as stated above
3. RDAS SHOULD
HAVE SUFFICIENT
ENVIRONMENTAL AND
PLANNING EXPERTISE
3.1 If the RDAs are to take on the planning
function from the Regional Assemblies they will need to be given
sufficient resources to significantly expand their planning and
environment teams.
3.2 It is clear that the preparation of
the new Regional Spatial Strategies has required a substantial
team of regional planners within the Regional Assemblies. Further
revisions of the Regional Spatial Strategies, and the preparation
of the Integrated Regional Strategy, can be expected to build
on the RSS experience and probably require a similar level of
resourcing. It will almost certainly require more specialist planning
and environmental policy staff within RDAs than is currently the
case.
3.3 In the North West Regional Assembly
(4Northwest), for example, there are 8 qualified town and country
planners, 3 transport planners, 2 RSS monitoring staff, a coastal
planning officer and 4 members of the regional housing team, a
total of 18 people. In comparison, the RDA currently employs 5
planning related staff. This difference in staff numbers reflects
the roles the two organisations currently perform, but serves
to illustrate the fundamental shift in RDA internal structures
and culture that will be required to take on the planning role.
Delivering on Natural Environment and Rural Communities
Act responsibilities
3.3 The NERC Act contains measures including
an extension of the Countryside and Rights of Way Act biodiversity
duty to all public bodies and statutory undertakers to ensure
due regard to the conservation of biodiversity. RDAs, as public
bodies, are subject to this duty, which should already be considered
as part of their current functions but also as these functions
evolve as a result of the proposals within the SNR.
4. RDAS SHOULD
TAKE MORE
ACTION ON
CLIMATE CHANGE
ADAPTATION
4.1 As well as reducing the regions' carbon
emissions, the SNR should be concerned with reducing the country's
ecological footprint and enabling regions to adapt to the now
unavoidable impacts of climate change. The Planning Bill requires
local authorities to include policies that contribute to climate
change mitigation and adaptation in their Local Development Frameworks.
This should also apply to regional plans, and RDAs should have
the expertise and skills to include climate change and natural
environment considerations in their work and to produce briefs,
analyse and act upon the results of reports such as Strategic
Environmental Assessments and Sustainability Appraisals.
4.2 The Wildlife Trusts believe that a focus
on climate change mitigation and carbon reduction without a corresponding
emphasis on adaptation, will leave the region's economies vulnerable
to the potential impacts of a changing climate, and result in
missed opportunities to develop the environmental economy.
4.3 The Stern Review identifies the key
role which the economy plays in mitigating against and adapting
to the impacts of climate change. We believe that many RDAs are
showing leadership in terms of mitigation, but could be much more
ambitious in terms of the programme of activity to help their
region adapt to a changing climate.
5. RDA BOARDS
SHOULD CONTAIN
THE FULL
RANGE OF
SUSTAINABLE DEVELOPMENT
SKILLS
5.1 We would challenge whether the RDAs,
as they are currently constituted and given their cultural model,
are the right bodies to carry out regional planning.
5.2 RDA boards are currently made up of
individuals who are appointed by the Secretary of State (SoS),
largely for their ability to direct an organisation focussed on
economic growth. A much broader set of skills will be required
in the future, and the structure and membership of RDAs needs
to be radically reviewed to reflect this fact.
5.3 It is important that the membership
of the board adequately and legitimately represents the communities
and area that they cover. A better model for RDA member selection
may be that of the National Park Authorities. In this case, nearly
one half of authority members are appointed by the SoS to represent
the "national" interests in the park areas, whilst the
rest are made up of local councillors. In addition, the SoS appointed
members should reflect a balance of expertise across the three
pillars of sustainable development, that is, environmental, economic
and social.
5.4 The Wildlife Trusts believe that the
reformed RDAs should ensure that all its decisions are transparent
and accessible, including those on planning. This would require
them to make all board papers available for public inspection;
allow members of the public to attend board meetings where individuals
and stakeholder organisations would have an automatic right to
be heard on relevant issues, and conduct regional road shows,
meetings and workshops around the region in order to be accessible
to communities.
6. THE RDA SCRUTINY
PROCESS SHOULD
BE MORE
ROBUST AND
CONSISTENT
6.1 As far as we are aware, there is currently
no clear standard for scrutinising the RDAs, and we believe this
is a major hindrance to increasing the transparency and trust
of the RDA decision-making process.
6.2 We believe that standards of scrutiny
should be much more robust and that clear standards should be
developed to improve consistency between regions and to ensure
the full range of policies necessary to deliver sustainable development
are developed and implemented.
6.3 The report published recently by the
Modernisation Committee on Regional Accountability identified
"a clear accountability gap at regional level. Effective
scrutiny of RDAs and other agencies operating in the English regions
is lacking, both locally and in Parliament".
6.4 The new system of Regional Ministers
and Select Committees should strengthen some of the scrutiny and
accountability of decision-making of RDAs in the absence of elected
members (other than in London).
6.5 It would be helpful if the Regional
Select Committees themselves conducted part of their inquiries
in their regions to enable the public in the regions to have greater
involvement in the process. The Select Committees could also have
a role in scrutinising the appointments to the RDA Boards. We
believe that the RDAs should be accountable to Parliament through
their relevant Regional Minister.
6.6 We understand that a Regional Private
Office is being established in the Government Office South East
in response to the evolving nature of regional governance throughout
England. This could lead to a more focused approach to the way
in which the GO and Regional Minister engage with the region.
19 September 2008
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