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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