Written evidence from the Landscape Institute
(ARSS 127)
INTRODUCTION
The Landscape Institute (LI) is an educational charity
and chartered body responsible for promoting the protection, conservation
and enhancement of the natural and built environment for the benefit
of the public. It champions sustainable, well-designed and well-managed
urban and rural environments. The LI's university accreditation
and professional procedures ensure that the designers, managers
and scientists who make up the landscape profession work to the
highest standards. There are 6,000 professional members working
across both the public and private sectors, both within the UK
and elsewhere across the world. Our advocacy and education programme
promotes the landscape profession as one which focuses on design,
environment and community in order to inspire great places where
people want to live, work and visit.
SUMMARY
Our response to the Committee inquiry largely focuses
on the significant role of green infrastructure (GI) in meeting
a wide range of policy objectives, and the need to plan for GI
at a scale that is larger than that covered by local authorities.
The abolition of Regional Spatial Strategies could have a detrimental
impact:
1. The likely effectiveness of the Government's
plan to incentivise local communities to accept new housing development,
and the nature and level of the incentives which will need to
be put in place to ensure an adequate long-term supply of housing.
We believe that sustainable supply solutions will require
high standards and minimal impact from the start to ensure the
widest possible acceptance of schemes by local communities. Some
possible examples can be found in the Landscape Institute's
position statement on the subject of housing.
2. The arrangements which should be put in
place to ensure appropriate cooperation between local planning
authorities on matters formerly covered by RSSs (eg waste, minerals,
flooding, the natural environment, renewable energy).
There is a grave risk of the erosion of landscape character,
local distinctiveness and the functionality of the natural environment
resulting from both the RSS abolition and incentivisation of local
communities to build. The Landscape Institute recognises that
some cross-boundary matters may well be picked up by the Local
Enterprise Partnerships (LEPs), if they are to fulfil a planning
function. However, it is important to remember that it is unlikely
that LEPs will the entire country, nor will they necessarily be
charged with delivering on matters formerly covered by RSSs. Furthermore,
there may well be instances where cooperation between LEPs is
necessary.
3. The adequacy of the proposals already put
forward by the Government, including a proposed duty to cooperate
and the suggestion that Local Enterprise Partnerships may fulfil
a planning function.
The Landscape Institute welcomes this approach. It is crucial
that LEPs, if they are to fulfil a planning function, ensure that
this incorporates adequate consideration of the natural environment.
The natural environment, through the ecosystem services it provides,
has a significant role to play in delivering economic benefits.
1. The likely effectiveness of the Government's
plan to incentivise local communities to accept new housing development,
and the nature and level of the incentives which will need to
be put in place to ensure an adequate long-term supply of housing
1.1 Recent research[156]
commissioned by the National Housing Federation found that up
85,000 planned homes have been scrapped by councils across England
in the wake of the Government's decision to axe regional house
building targets. At the same time, there is a general acceptance
that there is a need to increase the supply of housing.[157]
The Government must therefore put plans in place that respond
adequately to the housing shortage issue. We believe that sustainable
supply solutions will require high standards and minimal impact
from the start to ensure the widest possible acceptance of schemes
by local communities. Some possible examples can be found in the
Landscape Institute's position statement on the subject of housing.[158]
1.2 We are concerned that the proposals for incentivising
communities, as promulgated by Policy Exchange in its document
Making Housing Affordable, are unrealistic because:
It is unlikely that a settle of 2,000 houses could
easily accommodate a further 1,000 houses without significant
impact on the local environment.
It is not just areas of special value, such as AONBs
and National Parks, where consideration needs to be given to impact
on landscape character, local distinctiveness, place-making and
functionality in terms of green infrastructure. A local planning
authority's "off-limit" zones might be quite hard to
defend.
In the example cited, a developer would be handing
over £2 million of their profits to the community and/or
householders.
£10,000 per household is a considerable amount
of money and the Landscape Institute believes it is unlikely that
2,000 existing households would all be willing to contribute such
sums to community facilities such as a park, as suggested, or
reach agreement on how the money should be spent.
Despite ministerial protestations to the contrary,
it will be perceived as bribery.
Revenue must also be available for the management
and maintenance of the facilities constructed from the incentivisation
money.
1.3 The Landscape Institute has concerns that
the Community Right to Build (CRtB) scheme may conflict with previously
developed, non-statutory community plans such as parish plans
and village design statements. It will also be crucial, in light
of proposals that housing development under CRtB will take place
outside of the current planning system, to ensure that adequate
minimum criteria on, for example, design and sustainability are
developed and enforced.
1.4 We feel it will be important to define what
a community is and how it will relate to who is invited to vote
in any referendum under CRtB. This will be very important in terms
of fairness and transparency. For example will the referendum
encompass the entire parish in which the proposed new housing
development is situated, or part of the parish, for example, the
householders in the village? Outlying rural households may house
important community members and it will be important to gauge
their views as well. In particular we feel this is the case if
a parish plan exists as that will be the community aspiration,
into which all the parish will have already had the opportunity
to give views.
1.5 We are also concerned about the sustainability
of community leadership. In our members' experience of community
leadership for projects such as parish plans, parks' friends groups
etc, there is often a reliance on one or two individuals, with
little or no scope for succession planning should something happen
to them. We recognise the CRtB proposes a corporate entity, but
if the initial enthusiasm is vested in a limited number of individuals,
its sustainability could be precarious.
1.6 We also know that parish councils can feel
threatened by what they perceive to be groups that are not democratically
elected, taking the lead in local matters, leading to tensions.
This may well be the case for CRtB groups and this will need to
be taken in to consideration. In our members' experience there
are often different factions even in small village communities;
landowners, those who want development for the betterment of the
settlement, those who do not want development at any cost. It
may be difficult to reconcile such differences. We appreciate
the referendum is the mechanism for deciding. However it would
be resource intensive for local authorities to have to organise
many of these referenda. The wording of the questions on the referenda
will also be important in terms of achieving fairness and transparency;
and this may be a skill not held in house by local planning authorities.
2. The arrangements which should be put in
place to ensure appropriate cooperation between local planning
authorities on matters formerly covered by RSSs (eg waste, minerals,
flooding, the natural environment, renewable energy)
2.1 The Landscape Institute is encouraged by
the content of a recent Defra publication[159]
which, with regards the natural environment, states that:
"Some issues will require partnership working
between neighbouring local authorities, because nature and its
services do not align themselves neatly to administrative boundaries.
For example, on water management, biodiversity and habitat protection,
green infrastructure and air quality."
2.2 Here, the Government has acknowledged that
there will continue to be a need for planning at a "larger-than-local"
level on matters which do not necessarily fit within the administrative
boundaries of local authorities. The document goes on to add:
"
on issues such as planning, food production,
water, flood risk management and biodiversity, where the impacts
of our decisions do not stop and start with administrative boundaries,
we need to move towards more integrated, management approaches
that work at the spatial scale that best addresses the challenge.
These are often call "landscape-scale" approaches. At
the same time, we need to start making decisions that encompass
all of the multiple benefits we receive from the land, rather
than just focusing on one objective at a timean approach
which is wasteful at best and at worst limits our capacity to
manage real risks such as flooding and climate change"
2.3 The Landscape Institute strongly agrees with
thinking expressed here and has made representations[160]
to Communities and Local Government previously, backing the need
to plan strategically in order to minimise any adverse impacts
that may arise as a result of the loss of Regional Spatial Strategies.
2.4 The Landscape Institute recognises that some
cross-boundary matters may well be picked up by the Local Enterprise
Partnerships (LEPs), if they are to fulfil a planning function.
However, it is important to remember that it is unlikely that
LEPs will the entire country, nor will they necessarily be charged
with delivering on matters formerly covered by RSSs. Furthermore,
there may well be instances where cooperation between LEPs is
necessary.
3. The adequacy of the proposals already put
forward by the Government, including a proposed duty to cooperate
and the suggestion that Local Enterprise Partnerships may fulfil
a planning function
3.1 Information
relating to Government proposals that Local Enterprise Partnerships
could fulfil a planning function is limited and, where it does
exist, is not sufficiently detailed to allow for a thorough assessment.
However, the Landscape Institute is encouraged by two resources
relating to this matter.
3.2 The first,
a letter from Eric Pickles and Vince Cable to local authority
and business leaders, dated 29 June 2010, states that:
Local Enterprise Partnerships will need to create
the right environment for business and growth in their areas,
by tackling issues such as:
Planning.
Housing.
Local transport.
Infrastructure priorities.
Employment and enterprise.
Transition to the low carbon economy.
3.3 It is encouraging
that the Government recognise the importance of planning in creating
the right environment for business and growth and the expectation
that Local Enterprise Partnerships will need to pay attention
to this important matter. This is particularly important given
the recent abolition of Regional Spatial Strategies, which played
a key role in planning at the "larger-than-local" level.
3.4 The second
resource, contained within Defra's, An invitation to shape
the nature of England: discussion document (July 2010), states:
"The Government is also considering ways
to support Local Enterprise Partnerships, and provide an opportunity
at this level to further promote the economic benefits from a
healthy natural environment and all its services"
3.5 The Landscape Institute welcomes this approach.
It is crucial that LEPs, if they are to fulfil a planning function,
ensure that this incorporates adequate consideration of the natural
environment. The natural environment, through the ecosystem services
it provides, has a significant role to play in delivering economic
benefits.
3.6 The Landscape Institute believes that the
primary mechanism for achieving this will be through the strategic
planning of green infrastructure (GI) across the geographical
extent to be covered by each LEP. LEPs must recognise the true
value of a multifunctional, (GI) approach in achieving economic
health and sustainability of an area. The Landscape Institute
has outlined previously the economic benefits of GI in its position
statement[161]
on the subject, including:
The positive impact of green space on land and property
values
The creation of settings for investment
Providing a catalyst for wider regeneration
Job creation
Tourism opportunities
3.7 These benefits, broadly outlined in the Landscape
Institute's position statement, are supported by case studies.
One of these, Crewe Business Park, South Cheshire, recognised
from the outset the important role of GI in delivering economic
objectives. In this instance, the business park has generated
£4.5 million in capital receipts and created over 2,800 jobs.
Crewe Business Park has been successful in attracting major companies,
with some explicitly stating that the high environmental quality
played a key role in their decision making process. Furthermore,
the development has acted as a catalyst for wider investment,
such as the Manchester Metropolitan University South Cheshire
Faculty.
3.8 The North West has also been leading on research
into the economic value of GI. One report[162]
finds that the region's environment generates an estimated £2.6
billion in Gross Added Value (GVA), and supports 109,000 jobs.
More recently, work undertaken on behalf of the Mersey Forest
found that GI investment generated, on an annual basis, a gross
monetised benefit of £5.5 million[163].
3.9 The Landscape Institute believes that there
are significant benefits in the LEPs taking a lead in strategic
GI planning in terms of delivering against their economic objectives.
LEPs will, in the main, be the right size of area to be able to
take strategic cross-boundary and less parochial views than one
local authority area, but will still be small enough for meaningful
specific spatial intentions to be spelt out in a way that is readily
understood by communities and developers.
3.10 We are keen therefore that Government promotes
to LEPs, as has been suggested by Defra, the important role of
the natural environment, and therefore GI, in delivering economic
growth.
3.11 The strategic planning of GI, within the
context of LEPs, will be central to achieving this. It is therefore
fortunate that some proposed LEPs already have a basis for doing
just this. For example, the proposed Solent LEP, which brings
together the Partnership for Urban South Hampshire (PUSH) and
the Isle of Wight, has a GI strategy[164]
in place which will partially cover the LEPs geographical extent.
Similarly, a GI strategy[165]
has already been prepared for the Leeds City Region, an area which
we note has also submitted proposals to become an LEP.
3.12 Despite efforts by Government to promote
the role of the natural environment or GI, the Landscape Institute
anticipates that not all LEPs will view the GI approach as an
important priority, nor will they have the skills to undertake
or even commission this work. It is here, that CABE Space's expertise
in GI strategy formulation and CABE's expertise in sub-regional
scale spatial planning will be of particular relevance and would
be a useful centre of excellence for good practice.
September 2010
156 www.housing.org.uk/default.aspx?tabid=212&mid=828&ctl=Details&ArticleID=3092 Back
157
www.communities.gov.uk/housing/about Back
158
Landscape Institute (2010), Making it home: the power of landscape
to create good housing, Landscape Institute. Back
159
Defra (2010), An invitation to shape the nature of England: discussion
document, Defra. Back
160
www.rtpi.org.uk/item/3937/23/5/3
Back
161
Landscape Institute (2009), Green infrastructure: connected
and multifunctional landscapes, Landscape Institute, London. Back
162
Environment Agency (2006), Environmental Economy Report for the
North West, Bridge Economics. Back
163
Regeneris Consulting (2009), The economic contribution of the
Mersey Forest's Objective One-funded investments, Mersey Forest.
Back
164
www.push.gov.uk/push_gi_strategy_adopted_june_10-3.pdf Back
165
www.leedscityregion.gov.uk/uploadedFiles/Leaders_Board/Meetings/Item%208%20Appendix%20A%20-%20Final%20LCR%20Green%20Infrastructure%20Strategy%20V5%20with%20maps.pdf
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