Memorandum submitted by The Environment
Agency
SUMMARY
The Environment Agency welcomes the opportunity
to respond to the Business & Enterprise Committee inquiry
into the "future role and responsibilities of Regional Development
Agencies" (RDAs). Through the reforms announced in the Sub-National
Review (SNR), RDAs will have a more strategic remit in co-ordinating
the development and delivery of Single Regional Strategies (SRSs),
in association with Local Authority leaders forums and input from
wider stakeholders. This presents a variety of opportunities and
challenges, and the Environment Agency looks forward to working
with RDAs in their evolving role.
Our main points are summarised below:
— We believe the policy reforms enshrined
within the SNR are a key opportunity to ensure that sustainable
development is placed at the heart of regional planning, decision-making
and subsequent delivery activity.
— The reforms should facilitate the
much needed shift to sustainable economic development, ultimately
leading to a more resource efficient and lower carbon economy.
They should also ensure that future RDA interventions deliver
a wider set of economic, social and environmental outcomes.
— As the RDAs take on a more strategic
and less project based role, it is essential that they are able
to conduct effective stakeholder engagement.
— We are concerned that RDAs may not
have fully the capacity, in skills and resources, to discharge
their new responsibilities. Expertise and champions for spatial
planning, within the context of sustainable development, must
be established at a Board and technical level. RDAs must also
have access to expertise on key environmental issues including
climate change.
— We are concerned that the proposed
timetable for developing SRSs provides insufficient time for necessary
environmental checks, including proper evidence gathering, appraisal
and examination in public.
— New regional scrutiny and monitoring
arrangements of RDAs must include an assessment of the extent
to which sustainable development and climate change objectives
are met. Defra should have a role in assisting Business Enterprise
& Regulatory Reform (BERR) in setting the tasking framework
and assessing how effectively RDAs are performing their functions.
— We believe that the existing RDA
performance indicators must be revised to reflect their wider
functions. The delivery of sustainable development and indicators
which track performance in moving to a resource efficient/low
carbon economy should be explicitly reflected within RDA targets.
— Overall the RDA tasking framework
must drive an integrated approach to sustainable development,
supported by leadership and a cultural shift throughout the organisation.
1.0 INTRODUCTION
1.1 The Environment Agency is the leading
public organisation for protecting and improving the environment
in England and Wales. We work across all levels of government,
with staff at regional and local level. We welcome the opportunity
to respond to the inquiry into the role of RDAs.
1.2 Our interest in the future role of RDAs
is based on the potential implications for the environment and
our ability to undertake our functions. This response is informed
by our work at a regional and local level, and our direct involvement
as a statutory consultee in the preparation of Regional Spatial
Strategies, Local Development Frameworks, Strategic Environmental
Assessments and on planning applications. Our comments are grouped
under the main areas addressed by the inquiry.
2.0 MAIN COMMENTS
The need for a level of economic development/business/regeneration
policy delivery between central and local government
2.1 Spatial planning at a regional level
provides an important bridge between national and local planning
policy. It should help put planning policy within the context
of a region's particular characteristics, including geography,
population and environmental conditions. It plays an important
role in addressing cross boundary issues, helping to make provision
for critical infrastructure and should ensure sufficient environmental
safeguards are established and maintained.
2.2 We believe the policy reforms enshrined
within the SNR are a key opportunity to ensure that sustainable
development is placed at the heart of regional planning, decision-making
and delivery. The proposals will bring about major changes to
both regional bodies and policy. In particular, RDAs will become
the Regional Planning Body. Government, (see Planning Policy Statement
1: Delivering Sustainable Development) has made clear that
the statutory purpose of planning is to deliver sustainable development.
Therefore as RDAs take over the regional planning function, they
will have a crucial role in co-ordinating regional planning policy
to plan for and facilitate sustainable development. This includes
ensuring that development is planned in a way which successfully
adapts to the unavoidable impacts of climate change.
2.3 The SNR sets out an ambition for regional
institutions and policy to focus on promoting economic growth.
Whilst this is of course a central objective, we are concerned
that it must be set in the context of accompanying social and
environmental objectives. The aim must surely be to secure the
best achievable sustainable development, rather than simply focusing
on raising Gross Value Added (GVA). The reforms are an opportunity
to drive England's response to climate change and this should
not be missed through too narrow an economic focus.
2.4 There now needs to be a fundamental
shift in thinking which recognises that environmental sustainability
is an essential component of economic development, rather than
a constraint. For example, resource efficiency leads to enhanced
business competitiveness ie reducing consumption of energy and
water, and production of waste, and thereby cutting running costs.
The policy reforms should facilitate the much needed shift to
sustainable economic development, making the wider connections
to achieving a low carbon, resource efficient economy.
2.5 We welcome the SNR references to the
need to move to a low carbon economy and efforts to define sustainable
economic development, in particular the reference to environmental
limits. In addition they should help ensure that RDA interventions
on a policy and project basis (eg sector support programmes, physical
regeneration activities etc) deliver a wider set of economic,
social and environmental outcomes in an integrated way.
The effectiveness of RDAs and their role in adding
value
2.6 In some regions, for example in the
South East, we have worked closely with RDAs and this has led
to some positive results, such as on physical regeneration projects,
as well as water and waste policy. Yorkshire Forward has also
contributed to funding opportunities, providing around £3.5
million for flood defences around the Humber Estuary. It has also
contributed financially to projects in Leeds, the Dearne Valley
and North Yorkshire and has recognised the need for local investment
in flood defences by contributing to the local levy. However,
in other regions we have found it a challenge to establish an
open dialogue and effective partnership working.
2.7 Our experience in working with RDAs
reveals that the degree of buy-in to the sustainable development
agenda can be dependent on individuals which presents a risk to
its widespread take-up. In taking forward the SNR reforms, it
is clear that sustainable development needs to mainstreamed and
embedded throughout the organisation.
2.8 We also note the recent Environmental
Audit Committee (EAC) report into Climate Change and Local Government.
This highlights that local and regional Government sometimes face
contradictory national messages on climate change. The Environment
Agency reiterates the EAC recommendation that Government must
minimise the inconsistencies between policies and ensure departments
have a joined up approach to climate change.
2.9 As the RDAs take on a more strategic
and less project based role, it is essential that they are able
to engage in effective partnership working and stakeholder engagement,
through the ability to respond to a wider interpretation of sustainable
development. We look forward to working in partnership with RDAs
to help implement the SNR proposals and recommend that innovative
methods of partnership engagement are considered.
2.10 One option for enhanced partnership
working is through secondments. These can help ensure a better
dialogue between partners and an exchange of skills. For example,
the Environmental Planning Manager in the Environment Agency Midlands
Region will be seconded to Advantage West Midlands (AWM) to work
in their SNR transitional team. We welcome this as a positive
step forward and recognition of the need to bring in other stakeholders'
expertise and guidance during the SNR transition process.
RDA expertise
2.11 The EAC report into Climate Change
and Local Government also highlights a concern that RDAs pay insufficient
attention "to the economic risks posed by climate change
impacts" and that regions "should have a strategic overview
of climate change". This needs addressing when considering
the future roles and responsibilities of RDAs. In addition we
support their calls for the Government to review how the SNR addresses
sustainable development and ensure that the opportunities it offers
for improving local and regional co-operation on climate change
issues are taken.
2.12 We are concerned that RDAs may not
have the capacity, in skills and resources, to fully reflect and
discharge their new responsibilities. Expertise and champions
for spatial planning, within the wider context of sustainable
development, must be established at Board and technical level.
RDAs also need to ensure they have sufficient expertise on important
environmental issues, including climate change mitigation and
adaptation. A key challenge remains in mainstreaming this expertise
across RDAs, something that could be encouraged by the integration
of environmental objectives for the organisation as a whole. Their
more strategic role also requires RDAs to have the expertise and
skills to facilitate effective stakeholder engagement.
2.13 RDAs need to be well positioned to
help facilitate the much needed shift to a low carbon economy.
For example, this will require access to experts on renewables,
resource (including energy and water) efficiency and waste minimisation.
Where appropriate, the Environment Agency will seek to support
RDAs for example in the provision of advice, information and data
etc. We may also be able to input to sector specific projects
which relate to our core activities and where we have a particular
specialism. For example, environmental technologies (innovative
fish pass design), food and drink (environmentally-benign agricultural
practice), tourism and leisure (angling participation and fish
stock improvement) and livestock (best practice).
The consequences of expanding RDA remit to include
new functions
2.14 There is potential that the RDA-focussed
reforms could result in economic development being given a higher
prominence, with environmental issues given (or perceived to be)
a lesser priority. We are concerned that this may result in policy
and/or investment priorities that do not adequately protect the
environment or maximise opportunities for delivering genuinely
sustainable development. As highlighted above, RDAs need to be
equipped with the expertise to ensure they can discharge their
new responsibilities effectively. More widely, a culture change
is required to ensure that the new responsibilities are not just
regarded as a "bolt on", but integrated throughout the
entire organisation.
2.15 As highlighted in our response to the
recent SNR consultation, in principle we support the development
of the national sustainability framework as a means of ensuring
that SRSs take an integrated approach to economic, social and
environmental issues. It is important that this sustainability
framework is delivered sufficiently ahead of SRSs being developed,
to ensure that it influences thier content and plans for delivery.
It will also be important to test the SRS against the appropriate
Regional Sustainability Framework, ensuring that different regional
priorities are considered and accounted for.
2.16 When considering the process for developing
the SRS, it is important to give regional stakeholders sufficient
flexibility to ensure the very necessary environmental checks
are made. We are concerned that the proposed timetable for developing
a SRS provides insufficient time to allow for proper evidence
gathering, appraisal and examination in public. In their co-ordinating
role, RDAs need to be given sufficient time to ensure that a meaningful
Sustainability Appraisal/Strategic Environmental Assessment (SA/SEA)
is conducted. This will avoid the potential risk of non-compliance
with statutory SEA requirements.
2.17 The SNR also proposes to devolve responsibility
for allocating funding to Local Authorities. We are concerned
that with the emphasis on promoting economic growth, there is
potential for regional Sustainable Development and Climate Change
expertise to be weakened. Safeguards must be put in place to ensure
that at a minimum these are maintained, and ideally strengthened.
This is likely to require financial support from central government
departments.
2.18 We are actively engaged with some RDAs
on EU funding. This involves being present on high level committees
and sub-groups. We welcome this partnership approach and believe
this should be given a stronger emphasis in determining future
arrangements for the delivery of EU funding. This will enable
RDAs to utilise other organisation's skills and expertise to supplement
their own. A subsequent challenge is to ensure that high level
commitments to embed environmental sustainability in EU Funding
schemes are delivered in practice.
The accountability of RDAs
2.19 New regional scrutiny and monitoring
arrangements of RDA performance must include an assessment on
the extent to which sustainable development, climate change and
wider environmental objectives are being met. A robust relationship
with partners, to feed in their expertise and experience, is also
vital. Regional Assemblies had access to a range of social and
environmental partners whose expertise they could draw on to help
scrutinise RDA performance. It is unclear how the proposed Local
Authority leaders forums will precisely discharge their scrutiny
responsibilities. Clarity also needs to be provided on how Regional
Select Committees will interact with the region.
2.20 As the lead department for delivering
the Government's Sustainable Development Strategy (Securing
the Future, 2005), Defra should have a role in assisting BERR
in assessing how effectively RDAs are performing their functions,
and making an appropriate contribution to the achievement of sustainable
development. We also believe that Defra has a wider role in helping
BERR set the RDA tasking framework and recruiting board members.
How performance has been measured in the past
and will be in future
2.21 Measures to assess RDA performance
have largely been based on narrow economic development indicators.
Examples include jobs created, brownfield land reclaimed and the
number of business start ups. Performance indicators are critical
to driving core activity and opportunities to take a more integrated
approach, eg delivering projects in a way which maximises benefits
for the local community and environment, may not always have been
secured.
2.22 We believe that the indicators on which
RDA performance is assessed must be revised to reflect their wider
functions. The SNR ambition to drive sustainable economic development
should be explicitly reflected within RDA performance indicators.
Measures to promote genuinely sustainable economic development
cannot just focus on raising GVA. They must include a range of
environmental and social indicators, including decoupling targets,
a reduction in carbon footprint, alongside a specific reference
to climate change adaptation. Concepts such as the Index of Sustainable
Well-Being and Ecological Footprint may, in the long term, be
used as measures of progress. Overall the RDA tasking framework
must drive an integrated approach to sustainable development,
supported by leadership and a wider cultural shift within the
organisation.
2.23 We believe the existing RDA purpose
"to contribute to the achievement of sustainable development
in the UK where it is relevant to its region to do so" is
too weak. This duty should be strengthened to ensure that contributing
to sustainable development is central to their emerging strategic
role. This could be linked to the Government's four priorities
for action on sustainable development: sustainable consumption
and production; climate change and energy; natural resource protection
and enhancement; and sustainable communities.
19 September 2008
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