Abolition of Regional Spatial Strategies: a planning vacuum? - Communities and Local Government Committee Contents


Written evidence t for Lancashire, Manchester & North Merseyside (ARSS 119)

SUMMARUMMY

Whilst acknowledging the demise of Regional Spatial Strategies, there is a demonstrable need for a level of planning at a greater than district/unitary level. A higher level policy framework is necessary for the repair of ecosystem services by reversing landscape scale fragmentation of wildlife habitats and populations and tackling the impacts of climate change on these.

The summary removal of a strategic layer of planning for nature conservation in the absence of effective replacement arrangements and structures would suggest that Defra and CLG are not working together on our Government's declared intention to be the greenest ever.

PREAMBLE

This submission focuses principally upon "the arrangements which should be put in place to ensure appropriate cooperation between local planning authorities on matters formerly covered by regional spatial strategies (eg waste, minerals, flooding, the natural environment, renewable energy, &c.)" It deals specifically with the implications for the natural environment of the revocation of the Regional Spatial Strategy in the North West.

The loss of the North West RSS has substituted strong regional policy on the natural environment with weak national guidance provided by CLG's Chief Planning Officer on 6 July. This has no force of policy behind it and was not consulted upon, unlike the policies it replaces.

The UK Government's precipitate abolition of Regional Spatial Strategies seems to have been based mainly upon opposition to the regional housing allocations imposed upon local authorities. These allocations certainly raised some fundamental questions here in NW England as to whether this region's ecosystem services have the capacity to supply the drinking water and flood and effluent management that such levels of new development would entail. Indeed, following the Public Examination of RSS, the Government Office for the North West (GONW) belatedly began an assessment of the region's environmental capacity. However, our fear is that "the baby has been thrown out with the bathwater" with regard to many useful and effective policies relating to the natural environment.

The revocation of this Regional Spatial Strategy leaves a gap in the planning system, as for the first time since 1947 there will be no strategic planning policy layer. A strategic layer of planning is necessary to ensure that issues such as sustainable transport, investment in "green" and "grey" infrastructure, flood prevention, biodiversity loss, climate change mitigation, sustainable development and reducing inequality are addressed at a suitable level. These issues cross boundaries, and co-operation and co-ordination on a more than local scale will be needed to tackle them effectively. Without a strategic layer of planning, such issues cannot be dealt with properly and must either remain unaddressed, or be addressed in an uneconomical, piecemeal and ineffective manner by already hard-pressed local authorities.

There is a demonstrable need for some form of strategic planning at a greater than local level to tackle biodiversity loss, adaptation to climate change and the strengthening of ecosystem services. Indeed, this seems likely to be the conclusion of the independent Lawton Review Making Space For Nature, to be presented to Government imminently. It is already alluded to (page 18 & page 20, third paragraph) in the Government's Discussion Document, An Invitation To Shape The Nature of England (July 2010).

THE SITUATION UNTIL 27 MAY 2010

Regional Planning Policy for the Natural Environment followed policy laid out as referenced in Sections 2 and 3 of national Planning Policy Statement 9 (see Appendix 1 for wording—incidentally, a CLG consultation on a proposed replacement Planning Policy Statement: 'Planning for a Natural and Healthy Environment' closed on 10 June). This policy required RSSs to:

"(i)  incorporate biodiversity objectives;

(ii)  address regional, sub-regional and cross-boundary issues in relation to habitats, species and geomorphological processes through criteria-based policies;

(iii)  include policies to conserve and enhance biodiversity at the regional and subregional levels;

(iv)  include targets for the restoration and re-creation of priority habitats and the recovery of priority species populations, linked to national goals; and

(v)  identify suitable indicators for monitoring biodiversity."

These policy drivers were translated into the North West RSS in a comprehensive policy for the natural environment (see Appendix 2 for the full text).

RSS Policy EM1a stated:

"Plans, strategies, proposals and schemes should secure a "step-change" increase in the region's biodiversity resources by contributing to the delivery of national, regional and local biodiversity objectives and targets for maintaining extent, achieving condition, restoring and expanding habitats and species populations. This should be done through protecting, enhancing, expanding and linking areas for wildlife within and between the locations of highest biodiversity resources, including statutory and local wildlife sites, and encouraging the conservation and expansion of the ecological fabric elsewhere."

This policy built on PPS9 by requiring all local authorities to be pursuing a net increase in the region's biodiversity resource. It was a very progressive policy on the natural environment, securing landscape scale biodiversity protection and enhancement in Local Development Frameworks and facilitating cross-boundary cooperation between local authorities. There were targets for restoration and recreation of Priority Species and Habitats of the North West to deliver a better environment for the people of the region and to make the ecosystem services provided by the natural environment stronger and more resilient in the face of climate change.

The oversight brought by the RSS system meant that it was possible to keep track of plans and projects which were taking place within the region; so gaps in provision could be identified and effort targeted on areas which were most in need of conservation management, enhancement and creation.

POST REVOCATION

Post revocation there is no longer a strategic planning tier between local authorities and the UK Government.

Unitary and district authorities do not generally have the resources, expertise or oversight to consider the landscape and natural environment as a functional whole and are unlikely to look outside their own borders for a wider view because of costs, gaps in expertise and personnel constraints; particularly as they look to achieve major reductions in spending in the coming years. There was increasing momentum for joined up thinking and cross-border working on the environment with local authorities and their partners from across the region. This is now likely to stall and may even go into reverse. For example, the "Key Statement: Biodiversity" in the recent Ribble Valley Core Strategy consultation (page 27) addresses only the biodiversity resource of protected sites in isolation rather than a landscape scale approach to enhancement and restoration of priority habitats and species populations.

In the CLG guidance issued on 6 July 2010, the advice in Section 18 of the Question and Answer document on Regional Policies for the Natural Environment is that "Local authorities should continue to work together, and with communities, on conservation, restoration and enhancement of the natural environment—including biodiversity, geo-diversity and landscape interests. Authorities should continue to draw on available information, including data from partners, to address cross boundary issues such as the provision of green infrastructure and wildlife corridors."

This advice raises a number of questions:

Are the resources for this "working together" to come from reduced local authority budgets.

What co-ordinating body will ensure the work is undertaken?

Are local authorities to undertake this work on a district-by-district basis without any strategic level of coordination?

How will it be ensured that effort is not duplicated? Surely cost savings accrue from economies of scale. For example, if all local authorities decided to create their own green infrastructure guide or Local Wildlife Site systems when in the past this work has been carried out on a more strategic basis, there will be a net increase in costs due to inefficiencies of scale.

What body will oversee the collation and provision of "available information" in place of the regional bodies that have been undertaking this work up until now? This information has to be curated by someone; who will be the curator now that the GONW is likely to be abolished? If data is curated at a regional or sub-regional level how might this be resourced? If each local authority curates its own data, again there are losses of economies of scale, and also loss of a strategic oversight and consistency as different systems and approaches are adopted.

If there is no compulsion to work together in the form of policy, how will it be ensured that conservation, restoration and enhancement of the natural environment on a cross boundary and landscape scale is undertaken? This already fails to happen across the Cumbria/Dumfries & Galloway border and now risks being replicated across NW England, the Pennines and the Cheshire/Shropshire Meres & Mosses.

What happens to the body of work, research and data collection that the GONW accrued over the time it was in existence? To "throw it all away" appears to be wasteful in the extreme. If it's not to be lost, who will take on the responsibility?

Warrington, Cheshire West & Chester, and Cheshire East unitary authorities all have in-house ecologists providing advice on planning matters in their areas; with the exception of the Peak District National Park area of the latter, which is covered by that National Park Authority's ecology team. Halton unitary authority restructured and deleted its ecologist post a year or so ago. Following this decision, Cheshire Wildlife Trust was able to negotiate a Service Level Agreement to provide ecological advice on planning matters direct to Halton planning department. However, this only covers smaller applications not requiring an Environmental Impact Assessment. There is no provision in Halton for the latter.

In Greater Manchester, Lancashire and Merseyside, with one exception (Lancashire's Pendle Borough Council, which has no ecologist), district/unitary authorities have pooled resources to provide a Greater Manchester Ecology Unit, Lancashire Natural Environment Service (provided by Lancashire County Council), and Merseyside Environmental Advisory Service respectively. The Merseyside and Greater Manchester bodies replaced the service provided by ecologists in the former Metropolitan County Councils when the latter were would up. The Lancashire County arrangements are more recent.

However, there is no such arrangement in Cumbria, where the county council's ecologist only provides advice on applications for county council planning decisions—principally relating to minerals and waste management outwith the Lake District and Yorkshire Dales National Parks. The Cumbrian district authorities have no ecologists and no buy-in of ecological advice for their day-to-day planning work. The Lake District National Park Authority has two ecologists although they don't have the capacity to look at all planning applications. The Yorkshire Dales National Park Authority has one ecologist who specifically deals with planning issues in that area of Cumbria/North Yorkshire.

Because advice from Government was not to repeat regional policy in Local Development Frameworks, excellent policies pertaining to the natural environment in the North West RSS have not been incorporated into the Core Strategies of local authorities many of which must now, perforce, fall back on "saved" natural environment policies from outdated Local Plans/Unitary Development Plan Part 2's produced in conformity with now absent Structure Plan or Unitary Development Plan Part 1 policies and guidance and revoked Planning Policy Guidance Note 9. This means that there is a large hole in the environmental policies of the local authorities in the region. As there is no longer a driver for a step change increase in biodiversity, local authorities have no policy lever to encourage developers to incorporate biodiversity enhancement.

The regional basis for working meant that groups of NGOs such as North West Environment Link and Voluntary Sector North West were able to work together to influence policy and large scale schemes and developments as well as input into documents such as the North West Green Infrastructure Guide. The loss of the strategic level of planning means that it will become almost impossible for many of these groups to influence the 42 local planning authorities in the North West where once it was possible to feed comment into one place in the region. "The Big Society" was already happening in the North West with NGOs and voluntary groups involved in both policy making and service delivery on a region-wide basis. This policy input and delivery of services will become far more difficult for the voluntary sector in a future with no strategic layer. For instance The National Trust has one member of staff employed to engage in policy discussion and implementation in the North West region. This was possible at a regional level. However it will not be possible for this staff member to engage with all 42 local authorities in any meaningful or coherent fashion and there are not enough resources available to provide more staff. Similar difficulties are affecting the CPRE, FoE, the RSPB, the three local Wildlife Trusts and the Woodland Trust.

In short, a strategic level of planning is necessary where there is the need to set out priorities for investment and solutions to environmental problems which must inevitably be addressed beyond the boundaries laid out by the "localism" agenda. It is essential to ensure that investment in green infrastructure, renewable energy, climate change mitigation and protection and enhancement of ecosystem services (to name but a few larger than local issues) is undertaken in a cost-effective, joined-up and sustainable manner. It needs to be aimed at a level where intervention can be most effective, and in many cases this is just not appropriate, efficient or practicable at a solely local level.

APPENDIX 1

REGIONAL SPATIAL STRATEGIES IN PLANNING POLICY STATEMENT 9

2.    Regional planning bodies should liaise closely with regional biodiversity fora or equivalent bodies, English Nature or its successors and the Environment Agency to identify the current regional and sub-regional distribution of priority habitats and species, internationally and nationally designated areas, and broad areas for habitat restoration and re-creation. Regional planning bodies should also liaise with the British Geological Survey and, where appropriate, local Regionally Important Geological/geomorphological Sites groups on geodiversity issues. Over time the distribution of habitats and species, and geomorphological processes and features, will be affected by climate change and such change will need to be taken into account.

3.    Regional spatial strategies should:

(i)  incorporate biodiversity objectives;

(ii)  address regional, sub-regional and cross-boundary issues in relation to habitats, species and geomorphological processes through criteria-based policies;

(iii)  include policies to conserve and enhance biodiversity at the regional and subregional levels;

(iv)  include targets for the restoration and re-creation of priority habitats and the recovery of priority species populations, linked to national goals; and

(v)  identify suitable indicators for monitoring biodiversity.

APPENDIX 2

NORTH WEST REGIONAL SPATIAL PLANNING POLICY ON THE ENVIRONMENT

POLICY EM 1 INTEGRATED ENHANCEMENT AND PROTECTION OF THE REGION'S ENVIRONMENTAL ASSETS

The Region's environmental assets should be identified, protected, enhanced and managed. Plans, strategies, proposals and schemes should deliver an integrated approach to conserving and enhancing the landscape, natural environment, historic environment and woodlands of the region.

Plans and strategies should define spatial objectives and priorities for conservation, restoration and enhancement as appropriate, and provide area-based guidelines to direct decisions and target resources. These will be founded on a sound understanding of the diversity, distinctiveness, significance and sensitivity of the region's environmental assets, and informed by sub-regional environmental frameworks. Special consideration will be given to the impacts of climate change and adaptation measures.

Priority should be given to conserving and enhancing areas, sites, features and species of international, national, regional and local landscape, natural environment and historic environment importance.

Where proposals and schemes affect the region's landscape, natural or historic environment or woodland assets, prospective developers and/or local authorities should first avoid loss of or damage to the assets, then mitigate any unavoidable damage and compensate for loss or damage through offsetting actions with a foundation of no net loss in resources as a minimum requirement.

With regard to specific elements of this integrated approach, the following should be taken into account:

POLICY EM1 (B): NATURAL ENVIRONMENT

Plans, strategies, proposals and schemes should secure a "step-change" increase in the region's biodiversity resources by contributing to the delivery of national, regional and local biodiversity objectives and targets for maintaining extent, achieving condition, restoring and expanding habitats and species populations. This should be done through protecting, enhancing, expanding and linking areas for wildlife within and between the locations of highest biodiversity resources, including statutory and local wildlife sites, and encouraging the conservation and expansion of the ecological fabric elsewhere.

Broad locations where there are greatest opportunities for delivering the biodiversity targets are shown on the Indicative Biodiversity Resource and Opportunity Diagram (see Diagram 9.1). More specific locations will be informed by sub-regional biodiversity maps and frameworks of statutory and local wildlife sites.

Local authorities should:

develop a more detailed representation of this spatial information for use in their Local Development Frameworks; and

develop functional ecological frameworks that will address habitat fragmentation and species isolation, identifying and targeting opportunities for habitat expansion and re-connection. Active arrangements will be needed to address ecological cross-boundary issues within areas such as the Pennines, Solway Firth, the Mersey Estuary, the Lune Estuary, the River Dee Estuary and the Cheshire Meres and Mosses, as well as including biodiversity policies in any developing Marine Spatial Planning System in the Irish Sea."

Policy EM1 (D): Trees, Woodlands and Forests

Plans, strategies, proposals and schemes should:

support the aims and priorities of the North West Regional Forestry Framework and sub-regional forestry strategies;

encourage a steady targeted expansion of tree and woodland cover and promote sustainable management of existing woodland resources to enable the delivery of multiple benefits to society;

support the continued role of community forestry; and

identify and protect ancient semi-natural woodland and veteran trees.

September 2010



 
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