Memorandum submitted by The Woodland Trust
1. The Woodland Trust welcomes the opportunity
to submit evidence to this inquiry. The Trust is the UK's leading
woodland conservation charity. We have four main aims: no further
loss of ancient woodland, restoring and improving woodland biodiversity,
increasing new native woodland and increasing people's understanding
and enjoyment of woodland. We own over 1,000 sites across the
UK, covering around 20,000 hectares (50,000 acres) and we have
300,000 members and supporters.
2. We have set out below a number of the
key issues for us emerging from the consultation and our proposals
for improvements.
3. THE EFFECTIVENESS
OF RDAS
AND THEIR
ROLE IN
ADDING VALUE
3.1 We believe the RDAs are at their most
effective where they are supporting regional and local delivery
of projects which deliver genuinely sustainable development.
3.2 Their future role in relation to the
delivery of sustainable development, which will necessitate a
wide ranging refocusing, rather than the existing economic preoccupation
in our view, is discussed below, but in terms of their effectiveness
to date, we would make the following observations:
There is a need for greater attention
to good practice with regard to stakeholder relations. RDAs are
very effective at hosting one-off workshops but there is a need
to work at the maintenance of relationships over a period of time
and ensure that stakeholders continue to inform decision-making.
There is a need to increase the transparency
of the current decision making processes within the RDAs and a
need to address the concern that there is a tendency for area
and functional teams to operate in silos. We recognize that some
RDAs are seeking to address these concerns
There is a lack of clarity as to
what RDAs are trying to achieve in some areas.
4. RDA EXPERTISE
The consequences of expanding RDA remit to include
new functions, as proposed by the sub-national review, including
the delivery of EU funding
4.1 The shift to Single Regional Strategies
means that the RDAs need to change from being primarily economic
bodies to ones which are focused upon sustainable development
in the round, treating economic, social and environmental issues
equally and together. We therefore believe that the RDAs should
be re-styled as "Regional Sustainable Development Agencies".
4.2 If further evidence were needed of the
case for such changes then it is amply provided by the Government's
own aspirations for the breadth of the Regional Strategies. It
states that it:
will, however, be looking for the regions
to develop strategies which, while meeting these objectives, do
so in a way which secures an integrated approach, without prejudicing
other Government priorities. For example, the Stern Review highlighted
the strong economic case for taking action on climate change as
well as the opportunities that arise from decoupling growth from
greenhouse gas emissions. In setting out the long-term vision
for sustainable economic growth and housing supplyalongside
key strategic transport and other infrastructureit will
be vital that regional strategies ensure this is done in ways
that support the move to a low carbon economy, delivers the objectives
set out in the Climate Change and Energy Bills, and is in line
with the recently issued Planning Policy Statement on Climate
Change." (Prosperous Places page 30, para 4.11)
4.3 It goes on to state that:
"Each region will need to determine its
priorities to achieve sustainable economic growth and development
over the period of the plan. In terms of policies and spatial
priorities we propose that every regional strategy should cover:
an overview of the key regional
challenges over the plan period;
how economic growth can best be
delivered having regard to employment and the key drivers of productivity
as well as regeneration;
a distribution of housing supply
figures as well as targets for affordable housing and achieving
quality homes for all, including vulnerable and socially excluded
people;
how the region would manage the
risks and opportunities of unavoidable climate change, achieving
development in a way which is consistent with national targets
for cutting carbon emissions;
those areas within the region
identified as priorities for regeneration investment and intervention;
and
strategic requirements and provision
for transport, waste, water, minerals, energy and environmental
infrastructure, insofar as these are not already specified in
national policy." (Prosperous Places, page 31,
para 4.13)
4.4 The breadth of these aspirations clearly
illustrates in our view that there is a need to reform the statutory
sustainable development duty of the RDAs which is at present too
weak. We believe that the new RSDAs should have a new and improved
statutory duty on sustainable development which provides for scrutiny
on this by Ministers, Parliament and the public. This clear new
duty would help to ensure that these RSDAs are truly "fit
for purpose" when they take over from Regional Assemblies
particularly with regard to control of land use planning and spatial
development.
4.5 The proposed conferring of land use
planning powers upon the RDAs is a good example of why such change
is necessary since the planning system is central to the achievement
of sustainable development within the English regions.
4.6 The fundamental purpose of planning
(as stated in PPS1) is to balance social, environmental and economic
factors to secure outcomes that benefit society generally and
improve quality of life.
4.7 Given this backdrop, the Government's
plans to give the RDAs control over spatial and land use planning
is inevitably causing serious concern given that RDAs have such
limited experience of planning matters and their approach has
remained resolutely focused upon the achievement of economic objectives.
4.8 If the Government wishes to proceed
with this model, change will be necessary both to the statutory
basis of RDAS and to their skillset and culture as discussed above.
There is also a need to ensure that the necessary resources are
in place and that Regional Planning Body funding is transferred
across in full.
4.9 Attention should also be paid to the
composition of RSDA boards in order to ensure that expertise is
in place at the highest level to reflect the new breadth of responsibilities.
4.10 We would also add that when tackling
the range of challenges set out in Prosperous Places, it
should be recognized that the challenge of climate change is not
the only environmental challenge to be tackled in the regions.
Tackling issues of habitat loss and the provision of new green
spaces for people and wildlife are essential to quality of life
in new and existing communities, and to securing key ecosystem
services upon which we depend as a society.
5. STAKEHOLDER
ENGAGEMENT
5.1 It is essential that provision is made
for the continued meaningful involvement of social, economic and
environmental partners (SEEPs) in order to allow their expertise
to continue to contribute to regional policy development. One
example is that of the North West where they have been given full
membership of the proposed new Leaders Forum.
5.2 It will be important for RDAs/RSDAs
to build on the good practice which has been built up to date
since the advent of Regional Assemblies for engaging community
and voluntary sector interests. Getting this right will be key
to building consent in civic society for the Government's regional
policy intentions and for the RSDAs themselves. The SEEP partners
can often contribute not only technical expertise but also a regional
perspective. Including this in the new structures would complement
the local knowledge provided by democratically accountable councilors.
5.3 Greater clarity in this area would also
be a step forward in terms of ensuring "fit for purpose"
engagement of stakeholders following the SNR, especially given
that the consultation paper suggests that each RDA can devise
its own working arrangements to suit the needs of their region.
We believe that one of the best ways of doing this would be the
provision of a set of minimum standards for engagement so that
stakeholders can be engaged in a meaningful way in the development
of policies and strategies.
6. THE ACCOUNTABILITY
OF RDAS
6.1 We believe that the lack of public accountability
of RDAs and the potential democratic deficit this produces in
some key areas of strategic planning needs to be addressed as
a priority.
6.2 Having created new Regional Ministers,
we believe it is essential that Government gives them an explicit
role within their remit to ensure that sustainable development
is actually delivered in practice and that civic society is properly
engaged in the formation of regional policy and strategy. It would
also be sensible, given the growing importance of the regional
tier and to reinforce the importance of the role of Regional Minister,
if they were to be dedicated to this role rather than sharing
regional responsibilities with other ministerial portfolios.
6.3 We therefore do not believe that it
will any longer be sufficient for BERR alone to be the chief line
of accountability for RDAs/RSDAs. To improve accountability and
give public confidence in the process there should be cross-cutting
central Government responsibility which could mirror the shared
regional ministerial responsibility for sustainable development.
6.4 The Government should also set out from
the outset, the procedures and mechanisms which will enable Local
Authorities to avoid potentially conflicting dual roles of scrutinising
RDAs/RSDAs at the same time that they may be both seeking funding
from them and delivering on the regional strategies.
7. HOW RDA PERFORMANCE
HAS BEEN
MEASURED IN
THE PAST
AND WILL
BE MEASURED
IN FUTURE
7.1 We believe that there is a strong case,
given these wider social and environmental responsibilities, that
the RDAs should also be exploring alternative means of measuring
performance in addition to GVA. One alternative worthy of exploration
is the Index of Sustainable Economic Wellbeing (ISEW) which is
being increasingly drawn upon by a number of RDAs.
19 September 2008
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