Memorandum submitted by the Campaign to
Protect Rural England (CPRE)
INTRODUCTION AND
SUMMARY
1. The Campaign to Protect Rural England
welcomes the opportunity to contribute to this inquiry. CPRE works
for a beautiful and productive countryside which is protected
for both present and future generations. We campaign for the more
sustainable use of land and other resources and believe that climate
change poses a major challenge to the countryside. We are a leading
non-governmental organisation in the field of planning and the
protection of the countryside and the integration of these with
land management policy.
2. In this context, we would like to comment
on two of the questions to be addressed by the inquiry:
— how well the overall direction for
work on adaptation has been set, the effectiveness of the statutory
framework (including the use of the Reporting Power and its accompanying
statutory guidance), the allocation of powers and duties and how
well issues like social justice are addressed in adaptation policies;
— funding for specific actions to adapt
to climate change, such as investment in flood risk management
or the resilience of critical national infrastructure.
3. In summary, CPRE believes that a number
of important "first steps" have been taken to begin
to embed climate change adaptation into policy making, but that
the pace at which climate change adaptation is going from theory
to delivery is seriously inadequate, especially in comparison
with climate change mitigation measures. We are also concerned
to ensure that the spatial scale at which adaptation measures
are designed and delivered is environmentally appropriate. Finally,
we feel that the Government needs to do more to tap into the widespread
enthusiasm of local communities, particularly in rural areas,
to tackle climate change.
COMMENTS ON
THE OVERALL
DIRECTION FOR
WORK ON
ADAPTATION
4. From CPRE's perspective, delivery of
physical climate change adaptation measures will take place primarily
through two mechanisms—regulation of and payments for land
management practices for undeveloped land and the planning system
for the built environment. Comments in this section therefore
focus on delivery within these two areas.
Land management
5. Environmental land management policy in England,
although ultimately delivered on the ground primarily through
farming, is developed at a number of spatial scales—the
EU via the CAP; England via Defra, Natural England and the Forestry
Commission, among others; and at lower levels by a variety of
bodies, including land owning charities, AONBs and National Parks.
With the exception of National Parks and AONBs and catchment areas,
the boundaries which these bodies are responsible for are not
often related to the environmental characteristics—such
as habitats, soil types, hydrology, and landscape character—which
will be affected by climate change. At the same time, there is
no single forum at which the wide range of interests which will
be affected by climate change in a particular environmental management
area—private landowners, water companies, and local authorities,
for example—are represented. Because climate change will
not respect existing boundaries, there is a major challenge to
the effective delivery of adaptation measures.
6. Solving the boundaries problem involves answering
two questions—what are the relevant natural boundaries?
And, how can existing bodies effectively coordinate over these
boundaries? It is CPRE's view that the most promising approach
to the first question lies in addressing adaptation at the landscape-scale.
This framework is already the focus of future work on preserving
biodiversity,[43]
and initial analysis suggests that National Character Areas (NCAs)
are the most pragmatic unit for identifying priority work on biodiversity.
Because NCAs approximate broad habitat areas and in some instances
correspond well to other important adaptation priorities, such
as "Best and Most Versatile" agricultural land, we consider
that NCAs should be explored to discover whether they can fulfil
a similar role across climate change adaptation policy.
7. Similarly, we believe that best practice
from AONB management structures provides potential lessons for
how effective environmental policies can be coordinated across
boundaries and in consultation with the wide variety of stakeholders—including
landowners, local authorities, environmental stakeholders and
others.
Planning
8. The boundaries issue, identified above,
is an issue for the planning system as well as for wider land
management, and a good example of the potential difficulties in
delivering adaptation measures across political boundaries is
evident in the take-up of National Indicator 188 across different
local authorities. The map below[44]
shows the local authorities that have selected NI188 as a priority
next to a map showing NCA boundaries.
9. The fragmentation of the take-up of NI188
demonstrates that there is significant potential for landscape-scale
adaptation measures to be complicated by problems of cross-border
working amongst local authorities, especially for spatial planning
across NCAs that fall between local authorities that have not
chosen NI188 as a priority. In fact, future problems may already
be developing: we are aware that UKCIP training on how to understand
climate projections is limited to those local authorities that
have chosen NI188 as a priority measure.
10. The difficulties with relying on NI188
to deliver effective climate change adaptation at a local level
are also increased by the lack of guidance available on how to
deliver NI188. Interestingly, guidance on how to fill out the
self-assessment matrix which is used to report on progress on
NI188 is available,[45]
but over a year after NI188 was adopted as performance indicator,
guidance and best practice examples of actual adaptation delivery
is still lacking. In this context, it should come as no surprise
that 53% of councils have only achieved level 1 of NI188, a level
at which local authorities "will probably not expect to be
in a position to implement many adaptation actions."
11. Although NI188 is usefully focused on
a broad range of policy areas, it suffers from a significant defect—it
fails explicitly to require democratic engagement with the local
communities that will be affected by climate change. Not only
does this create a risk that adaptation policy will not be embraced
by the community, it misses a major opportunity to use climate
change adaptation as a means of showing that climate change is
relevant to the lives of ordinary people. Adaptation policy is
particularly valuable in this regard because it is fundamentally
concerned with maintaining elements of the human environment—cities
that are cool in the summer, moorland that can prevent flooding,
wildlife and landscapes that are essential to well being—that
contribute to individual and community quality of life.
12. By failing to promote community engagement,
NI188 also fails to recognise that individual and community behavioural
change will be essential in delivering effective adaptation policy
as many of the changes required are outside local authority control.
Unlike mitigation measures, which could in principle be delivered
through big-kit technical fixes like renewables and other low-carbon
power sources, effective adaptation will depend on action that
is outside the immediate control of Government, such as preventing
soil sealing on private land, enhancing biodiversity in gardens,
increasing insulation in existing properties and promoting water
efficiency at the household level.
13. Furthermore, as the slow pace of delivery
on NI188 shows, a substantial amount of work needs to be done
to develop effective policies to support climate change adaptation.
Experimentation over adaptation approaches is needed and tapping
into the experience and perspectives of local communities through
effective engagement can go some way to help with this. However,
it is unlikely that a coherent set of adaptation measures will
be developed quickly. Because of this, the overarching framework
within which adaptation policy is pursued needs to allow for increased
flexibility and a risk-based approach to policy development.
14. In the planning system, useful examples
of local approaches to climate change mitigation such as the Merton
Rule and Milton Keynes policy on carbon-neutral development[46]
show that local approaches can deliver tangible benefits for climate
change mitigation, but that a lack of flexibility has been a barrier
to the effective roll out of new policies. CPRE believes that
enabling local authorities to develop adaptation policies more
quickly is essential in meeting future adaptation needs.
15. In the medium term, it is clear that
we need a fundamental rethink of the way in which the planning
system works. At present, the system is designed on the assumption
that the natural environment is essentially static. Climate change
projections show that this is not the case, but these projections
are as yet insufficiently precise to provide certainty about the
detail of future climate patterns. Because new projections are
likely to be produced as the evidence base improves and changes,
the planning system will need to be flexible enough to incorporate
new evidence quickly, and will also need to move to a risk-based
model that encourages greater resilience in response to a dynamic
natural environment. One way of exploring how to reform the planning
system which CPRE would support would be through a commission
to explore ways in which strategic planning can lead the delivery
of a climate proofed, low-carbon future.
16. From CPRE's perspective, a clear example
of where this approach would be most valuable in the shorter term
relates to soil protection. Defra's recently released soil strategy
for England, Saving our Soils, goes some way to adopting
a flexible methodology which enables a periodic review of cross-compliance
measures to incorporate new scientific evidence. However, the
strategy is insufficiently robust in its interpretation of resilience.
Globally, the combination of climate change and an increasing
world population is likely to lead to greater demand for food,
and an increasing danger that food imports may be subject to interruption.[47]
In this context, CPRE would like to see the Best and Most Versatile
(BMV) land planning policy updated and reinforced to ensure that
the high grade agricultural land that may be necessary for future
food production is protected. This update needs to go further
than a simple reassertion of the value of protecting BMV land
to promote new national planning policies and mechanisms to secure
this objective and to incorporate a reassessment of the value
of soils for agriculture in the context of likely changes to the
climate, and the related role that soils can play in enhancing
biodiversity and controlling flooding.
FUNDING
17. A brief overview of the funding available
for climate change shows a substantial imbalance between mitigation
and adaptation measures. At the EU level, CPRE supports an increase
in the range of measures available to farmers to address the "new
challenges" that were recently agreed as part of the Health
Check of the CAP, including those arising from climate change.
However, we are concerned to ensure that an appropriate balance
between funding for mitigation and adaption measures is secured.
Any additional funding allocated to addressing the new challenges
should not result in a decline in funding that is needed to meet
the full range of existing priorities for agri-environment schemes.
18. At the national level, as the National Audit
Office report commissioned for this enquiry shows, a total of
£11 million has been made available to Defra for climate
change adaptation work over two years. In contrast, the Severn
Barrage, a single mitigation project, could cost between £15
and £23 billion, much of which would need to be underwritten
by the public. Funding for mitigation measures is clearly important,
and over the last few years organisations such as the Carbon Trust[48]
have built a body of evidence that mitigating climate change will
deliver net economic benefits to the UK, evidence which alongside
public funding has influenced business to invest in mitigation.
In contrast, relatively little work has been done at a national
level to quantify the potential savings that effective adaptation
policy could create, when compared with the costs of retrofitting
in the future or rebuilding after extreme weather events.
19. At the local level, examples such as
the flooding in Gloucestershire in 2007 show the potential scale
of future costs arising from climate change. The costs of this
single event were greater than £50 million to affected local
authorities alone, and substantial funding has now been directed
toward improving flood defences in the county. Although a focus
on preventing future flooding in Gloucestershire is valuable,
there is a danger that short-term funding will focus on adding
resilience in a reactive way, rather than allocating funding based
on future risks. The fact that Gloucestershire County Council
will receive around £25,000 for 2008-09 and 2009-10 in area
based grant to support the delivery of 35 NI targets, of which
only one—NI188—relates to climate change adaptation
shows the relative lack of funding for developing and delivering
an effective plan to adapt to climate change. It is our understanding
that increased funding for climate change adaptation in Gloucestershire
would go toward identifying the vulnerability of critical infrastructure
to climate change; vulnerability which is currently unaccounted
for in future planning.
20. Finally, we are concerned that much
of the good work that existing funding streams—notably to
UKCIP for both climate change projections and for local authority
training—have achieved may not be taken forward if adequate
funding is not secured over the medium term. Because funding for
adaptation has so far been focused on projections and supporting
a better understanding of how to use these projections, substantial
work is still needed to understand how projections will affect
infrastructure and to develop and publicise best practice examples
of climate change adaptation so that effective adaptation policy
can be delivered.
9 October 2009
43 Natural England (2008), Securing Biodiversity,
Catalogue No NE127. Back
44
Not printed. Back
45
See http://www.lga.gov.uk/lga/core/page.do?pageId=1382860 Back
46
In the case of Milton Keynes, the policy development process took
a total of five years, due in part to objections that "the
local authority was exceeding its planning powers [and] that the
requirement for carbon neutrality had no basis in Government guidance."
See http://www.southeastexcellence.co.uk/casestudies/sustainability/?p_id=1347
for further details. Back
47
See, for example, Thinking About the Future of Food: The Chatham
House Food Supply Scenarios, available from http://www.chathamhouse.org.uk/files/11622_bp0508food.pdf.
Professor John Beddington also warned earlier this year of a "perfect
storm" of food and energy shortages, see http://news.bbc.co.uk/1/hi/uk/7951838.stm
for details. Back
48
See, for example, a recent article by Tom Delay, the Chief Executive
of the Carbon Trust, which highlights the economic benefits of
climate change mitigation: http://www.guardian.co.uk/environment/cif-green/2009/jul/02/low-carbon-economy Back
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