Memorandum submitted by The Campaign for
National Parks
The Campaign for National Parks (CNP) is the
national charity which campaigns to protect and promote National
Parks for the benefit and quiet enjoyment of all. We welcome the
Committee's inquiry into the role of Regional Development Agencies
(RDAs), in particular how this will be affected by the Government's
review of sub national economic development and regeneration (SNR),
and are pleased to have this opportunity to comment.
Of the Committee's stated areas of interest,
this submission relates to the consequences of expanding RDAs'
remit to include new functions as proposed by the SNR; RDA expertise;
accountability; and general effectiveness and role in adding value.
Our main concerns about the role of RDAs in
light of the SNR proposals relate to:
— Their expanded remit, in particular
their capacity in terms of skills and expertise to develop new
Single Integrated Regional Strategies (SIRS), which will require
them to take on planning functions alongside their existing role
of promoting economic development and could lead to a conflict
of interests;
— Representation of National Park interests,
by National Park Authorities (NPAs), in fulfilling this remit
and the arrangements for partnership working, in particular that
these need to be clarified centrally to ensure that NPAs' expertise
is maintained and there is consistency in approach across regions;
and
— Proper recognition being given by
RDAs, in developing SIRS, not only to the inherent value of National
Parks but also the role that they play in contributing to economic
prosperity and the consequent need to ensure that they are protected.
We have set out below some brief background
on National Parks and NPAs by way of context to the comments that
follow.
In preparing our comments we have consulted
with and support the position of the English National Park Authorities
Association (ENPAA), whose evidence is submitted separately.
BACKGROUND—NATIONAL
PARKS AND
NPAS
National Park purposes
National Parks in England and Wales have two
statutory purposes:[61]
(i) To conserve and enhance the natural beauty,
wildlife and cultural heritage of the National Parks; and
(ii) To promote opportunities for the public
understanding and enjoyment of the special qualities of the Parks.
A wide range of public bodies including RDAs
must take these purposes into consideration when making decisions
that could affect the National Parks.[62]
NPAs' role
NPAs are statutory public bodies and the sole
planning authority for National Parks, with responsibility for
local and mineral and waste planning. They fulfil a role akin
to both "upper tier" county councils and "second
tier" district councils. As section 4(4) Authorities under
the 2004 Planning and Compulsory Purchase Act NPAs are, for planning
purposes, equivalent to a county or unitary authority. They have
statutory spatial planning responsibilities and are represented
with a seat on Regional Assemblies, enabling them to work with
regional partners and scrutinise regional plans.
COMMENTS ON
RDAS' FUTURE
ROLE AND
RESPONSIBILITIES
Developing SIRS
Under the new arrangements RDAs will take on
responsibility for developing SIRS, covering spatial planning
alongside their current role of promoting regional business growth
and investment. We are concerned that this dual function has the
potential for a serious conflict of interest: spatial planning
must deliver a number of public benefits that are not solely geared
towards business and investment interests. In particular it provides
for the sustainable, strategic management of land use and environmental
resources, including environmental priorities such as countryside
and biodiversity protection.
It will therefore be important to ensure that
RDAs are equipped with the skill set required properly to execute
their new spatial planning responsibilities, and to ensure that
there are arrangements in place to address the risk of conflicting
interests. It is especially critical that business growth does
not become the dominant driver of both functions. Spatial planning
must continue to deliver wider public benefits.
We are aware that the Government intends to
work with the RDAs on a Change Management Programme. While this
is welcome, we believe that any such programme must include increasing
RDAs' awareness and understanding of the purpose and role of protected
areas, in particular National Parks, in contributing to regional
prosperity; and developing skills and expertise to take account
of their needs in developing SIRS.
These two aspects of future RDAs—their
internal structure and skill set—will be paramount to their
accountability, level of public trust and general fitness for
purpose under the new arrangements.
Representing National Park interests—partnership
working
As outlined above, NPAs currently have a statutory
role in developing Regional Spatial Strategies under section 4(4)
of the Planning and Compulsory Purchase Act 2004. In fulfilling
this responsibility NPAs bring considerable value to the process,
in particular in contributing expertise on rural social, economic
and environmental issues.
We believe that this role must be maintained
going forward, alongside developing RDAs' own in-house skill set.
At present there is some doubt as to what the Government intends
in terms of NPAs' future role in working with RDAs—it recognises
that a wide range of stakeholders is currently involved in developing
strategies at the regional level and states that this expertise
should be retained. However, it has also stated, both in the SNR
itself and in response to concerns raised through the SNR consultation,[63]
that it intends to leave arrangements for engaging stakeholders
to individual RDAs.
While we appreciate the benefits of some flexibility
as to the detail of joint working arrangements between RDAs and
partners, we consider that certain minimum standards should be
set centrally to ensure that appropriate expertise is retained
and there is some consistency of approach across regions. In particular,
NPAs should continue to have a statutory role both in preparing
SIRS and in the proposed Leaders' Forums. The reasons for this
relate to their role and responsibilities at National Park level
and will be clear from the background set out above. Namely, that
they are the sole planning authority for their area and are responsible
for local and, mineral and waste planning; equivalent to county
or unitary authorities for planning purposes; and that they currently
enjoy a scrutiny role at regional level through representation
on Regional Assemblies.
Also relevant is the statutory duty on all public
decision-making bodies performing any function in relation to,
or so as to affect, land in a National Park to have regard to
National Park purposes. Formally securing NPAs' role in working
with RDAs and others as partners to develop and scrutinise SIRS
could also serve to help RDAs fulfill this duty.
We understand that the experience of NPAs to
date in working with RDAs and local authorities in their region
on the new arrangements has been varied, from full participation
to none at all. This should be a matter of serious concern to
all who have an interest in the protection and promotion of National
Park interests and the contribution they make to the regions,
and we wish to register our view that it will be vital, in maintaining
the credibility and accountability of regional planning, to ensure
that this situation is not left to continue as the transition
is made to the new RDAs.
Recognising National Park value
Closely linked to the two points above, in preparing
SIRSs it will be important that RDAs recognise not only the inherent
value of the natural environment, in particular that protected
by National Park designation, but also that National Parks bring
substantial economic prosperity for businesses in and around them
and for the regions in which they are located. In some regions
National Parks occupy a significant proportion of the total area.[64]
Research commissioned by CNP into the economic
impact of the Yorkshire Dales, North York Moors and Peak District
National Parks on the Yorkshire and Humber region estimated the
main financial benefits to the region as:
— Sales by businesses in the
Parks worth £1.8bn annually, supporting over 34,000 jobs.
— Spend by Park visitors of
£400m annually within the Parks themselves and a further
£260m elsewhere in the Yorkshire and Humber region, supporting
about 12,000 jobs. With "knock on" effects, the total
impact of this £660m expenditure on the region's output is
likely to be almost £1bn.
The project surveyed over 400 businesses in
the Parks and towns around them and found:
— 69% of businesses in the National
Parks believe high landscape quality has a positive impact on
their business performance.
— 26% of businesses think a deterioration
in landscape quality would seriously affect their business.
— Over half of the Parks' businesses
feel that the National Park designation has had a positive impact
on their enterprise.
The project found that economic benefits came
not just from the Parks' environmental qualities but also from
National Park designation itself. This attracted visitors and
businesses, and prompted action by NPAs and other organisations
in the public and private sector.[65]
These results demonstrate the importance of
the National Parks to their surrounding area and underlie our
three main concerns with the role of RDAs under the SNR proposals—the
need to ensure that RDAs have the skills and expertise to understand
National Park interests and reflect them properly in carrying
out their new function of spatial planning, without compromising
this purpose should it conflict with business growth; to ensure
that the role of NPAs in regional spatial planning and their experience
and expertise is maintained in accordance with their other statutory
functions; and to ensure that the full value of National Parks
is appreciated and reflected in developing and implementing SIRS.
21 August 2008
61 As set out in section 5 of the National Parks and
Access to the Countryside Act1949, as amended by section 61 of
the Environment Act 1995. Back
62
Section 11A(2) of the 1949 Act as amended by s62(2) of the Environment
Act 1995. Back
63
Letter dated 5 August 2008 from Pat McFadden MP to Paul de Sylva,
Chair of Wildlife and Countryside Link (WCL), in response to WCL's
submission to the SNR consultation. Back
64
For example, 18% of the total area of the Northwest is covered
by National Park. Back
65
A four-page summary of the report's findings and the full report
may be found on CNP's web site at www.cnp.org.uk Back
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