Written evidence from the Royal Society
for the Protection of Birds (RSPB) (ARSS 122)
The Royal Society for the Protection of Birds (RSPB)
is the charity that takes action for wild birds and the environment.
We are the largest wildlife conservation organisation in Europe
with over one million members.
SUMMARY
The natural environment does not respect the administrative
boundaries of districts or counties. This is why strategic planning
has an important role in delivering the Government's aspirations
for biodiversity and sustainable renewable energy. How will the
new planning structures enhance the delivery of the Government's
objectives?
The RSPB's view is that:
The revocation of regional spatial strategies has
removed strategic policies for the natural environment that overcame
such administrative restrictions.
Voluntary arrangements may work well in some areas,
but in others a more formal mechanism for strategic planning may
be required.
The proposed duty to cooperate must extend further
than adjacent local authorities, and must include a mechanism
to resolve disputes.
Local Economic Partnerships must have an environmental
voice.
Environmental data must be kept up-to-date and be
accessible to local authorities and the public.
TARGETS AND
INCENTIVES
1. The RSPB does not wish to comment in
detail on the abolition of regional house building targets or
the Government's plan to incentivise local communities to accept
new housing development. When we commented on the former regional
spatial strategies, we raised concerns about the implications
of significant housing growth in environmentally-pressured regions,
particularly the East and South East of England, and the impact
on biodiversity and water resources. We accept the need to make
adequate plans for future household growth around the country
and the need to do so in a way that commands democratic support,
but we are not convinced that the combination of local decision-making
and financial incentives will achieve this, or be affordable.
2. The decision to revoke regional spatial
strategies (RSS)s appears to have been almost entirely driven
by the contested nature of housing targets, particularly in the
south and east of England. However, the revocation has swept away
a raft of policies on other issues, such as the natural environment,
that were largely not contentious and were the product of close
cooperation between local authorities and other interested parties.
It has also removed part of the statutory development plan for
those authorities that have already adopted Development Plan Documents
(DPD). This potentially undermines their effectiveness until these
DPDs can be revised.
3. Regional spatial strategies provided
a spatial framework within which to address the restoration and
creation of priority habitats and the recovery of species populations.
Facilitating that process, the biodiversity fora in each region
identified the best areas of opportunity. For example, the South
West Nature Map, a habitat opportunity map prepared by Biodiversity
South West, was incorporated into the draft regional spatial strategy.
The map identifies landscape-scale blocks of land termed "strategic
nature areas" where most of the major biodiversity concentrations
are found and where targets to maintain, restore and re-create
wildlife might best be met. Its inclusion in the RSS would have
helped local authorities to meet the requirement to "identify
areas or sites for the restoration or creation of new priority
habitats..." in their local development frameworks, as set
out in national planning policies (paragraph 5(ii), Planning Policy
Statement 9).
4. Strategic planning does not necessarily
need to be located at a regional level, and the evidence and guidance
assembled in regional spatial strategies on matters such as biodiversity
can continue to be used following their revocation (although see
our comments on data and research below). However, the loss of
regional spatial strategies has removed an essential driver for
local authority plans and decisions. For example, the previous
government had intended to negotiate regional renewable energy
targets. This raises the question of how local authorities will
together make adequate contributions to national renewable energy
targets.
LOCAL AUTHORITY
COOPERATION
5. The natural environment does not respect
the administrative boundaries of districts or counties. One should
consider the role and functioning of species and habitats within
whole landscapes or ecosystems. This is why strategic planning
is essential for the delivery of the Government's aspirations
for biodiversity and sustainable renewable energy (eg ensuring
appropriate location of wind farms). Voluntary arrangements may
work well in some areas, but in others a more formal mechanism
for strategic planning may be required. In our experience conflicts
over the shared protection of the natural environment have arisen
between local authorities where their respective interests are
not aligned.
6. Areas statutorily designated for their
biodiversity value illustrate this need. Many designated Special
Protection Areas (SPAs), part of the Natura 2000 network, fall
within multiple local authorities; 28 SPAs in England contain
no fewer than five local authorities, and six SPAs contain at
least ten. In these areas, special arrangements may be required
to ensure that development can take place which respects the environment
and the legal obligations of the Birds and Habitats Directives.
7. For example, the Thames Basin Heaths
Delivery Plan, part of the arrangements for delivering housing
growth around the Thames Basin Heaths SPA, involves no fewer than
eleven local authorities. Prior to the preparation of the Delivery
Plan, the development of even small-scale housing was problematic
because satisfactory mitigation measures could not be put in place.
For the Delivery Plan to work all of the authorities must adopt
a common approach to mitigation, otherwise house building around
the SPA will not be possible, even where local authorities wish
to see that development go ahead. The Plan was until recently
given a statutory framework by policy NRM6 of the South East Plan.
It is uncertain whether an effective mitigation solution could
ultimately have been developed in the absence of the policy requirements
of a formal tier of strategic planning.
8. The proposed duty to co-operate may help
to address this issue. However, it must be more than a mere duty
to consult, and it must extend to all authorities which share
protected environmental features. An analysis of SPAs in England
shows that many, like the Thames Basin Heaths SPA, cover multiple
local authorities. Many are in areas of development pressure where
local authorities need to work together to ensure that development
can take place whilst continuing to protect these important wildlife
sites. Nevertheless, we have found that not all local authorities
will willingly do so. The duty to co-operate must therefore also
include a mechanism for resolving disputes between authorities.
Upper tier authorities could have a role to play in this, but
upper tier authorities may themselves be interested parties (the
Thames Basin Heaths Delivery Plan, for example, involves two county
councils and three unitary authorities).
9. Strategic working arrangements will vary
and must be tailored to the needs of the sector, for example,
cooperation amongst local authorities in the same river basin
districts. Certain sectors should be considered together because
they are complementary, for instance, waste and minerals restoration
may assist flood alleviation and contribute to biodiversity targets
through habitat creation or restoration. The challenge will be
to create appropriate groupings, based on an understanding of
who needs to work with whom, and for what purpose. As discussed
above, it is essential that local authorities work together on
joint issues, to deliver shared solutions which are more cost
effective and can provide more benefits for residents and the
natural environment.
LOCAL ENTERPRISE
PARTNERSHIPS
10. Our engagement with regional development
agencies showed us that they did not have sufficient in-house
capacity, experience or expertise to deliver economic development
within environmental limits. With their narrower remit and lack
of funds, we consider that it is unlikely that Local Economic
Partnerships (LEPs) will be able to bridge this gap in capacity
and skills either. This takes place at a time when the need to
halt the loss of biodiversity and degradation of ecosystem services,
and ensure their adaptation and resilience to climate change,
is most urgent.
11. Previously regional sustainable development
champions (e.g. sustainable development roundtables) and social,
economic and environmental partnerships (SEEPs) have provided
valuable advice and helped to shape regional policies. These were
often hosted by the regional assemblies. That they have continued
to exist in various forms after the assemblies' demise is a testament
to the strengths of the partnerships that have been created. For
example, in the East of England, "Sustainability East"[148],
an independent sustainable development champion body, is running
a joint event with Business in the Community to ask "how
can we deliver the Big Society sustainably?" This forthcoming
event is oversubscribed—illustrating the vacuum left by
the abolition of the regional tier. The decentralisation minister
recently said that he welcomed the involvement of voluntary organisations.
The RSPB calls for emerging LEP proposals to build on their strengths
and include environmental partners.
12. The RSPB believes that it is essential that
environmental, as well as social and economic, representatives
continue to have an effective voice in decision-making and help
ensure genuine improvements in environmental and social wellbeing.
However, we do not have all the answers. We ask the Select Committee
how they consider the environmental voice should be included in
local decision-making in the absence of the RSS.
DATA AND
RESEARCH
13. Significant gaps remain in the data available
on environmental resources across England, for example, on the
location of key species, and the condition of local wildlife sites
and Biodiversity Action Plan habitats. A robust evidence base
must assess the state of the environment as well as that of the
local economy. Therefore, finding a new home for regional environmental,
economic and social data is a key priority. Much of this data
is currently held by a variety of organisations in a number of
different formats and is often difficult to access. While evidence
will need to be "owned" and kept up to date by appropriate
groups, information previously gathered from the regions should
be kept in one place, and be accessible to local authorities and
the public.
September 2010
148 http://www.sustainabilityeast.org.uk/ Back
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