Written evidence from the English National
Park Authorities Association (ENPAA) (ARSS 30)|
1. The English National Park Authorities Association
(ENPAA) exists to support the policy making process by co-ordinating
the views of the ten National Park Authorities across England.
It is governed by the Chairs of the Authorities. Our submission
represents the collective view of officers who are working within
the policies established by the National Park Authorities (NPAs).
2. National Park Authorities exist to help the
National Parks deliver two statutory purposes:
to protect and enhance the natural beauty, wildlife
and cultural heritage of their areas; and
to promote opportunities for the public understanding
and enjoyment of the special qualities of these areas.
3. In furthering these purposes, NPAs have a
duty to seek to foster the economic and social well being of their
local communities. NPAs seek to achieve these purposes and duty
in an integrated manner. Spatial planning is an absolutely essential
mechanism in helping achieve this. As well as working with their
local communities to realise their ambitions; developing policies
and undertaking development management at a local level, the NPAs
also engage at a strategic level. Such regional and sub-regional
engagement has been critical to ensuring, for example:
that regional policy provides for flexibility in
how housing policy is applied in National Parks;
that local authorities that border National Parks
and AONBs consider carefully the implications of development that
might be in the setting of these protected landscapes; and
supporting a strategic consideration to infrastructure
within a framework that supports sustainable development.
4. The approach to housing delivery in National
Parks is very different to elsewhere in the country and often
relies on bespoke housing initiatives tailored to meet the very
local needs of local communities. ENPAA does not wish, therefore,
to comment on the implications of the abolition of RSS and regional
targets for housing. We do, however, wish to respond to the three
other questions that the Committee raise on sub-regional working,
Local Enterprise Partnerships (LEPs) and data.
5. Our response highlights:
the need for LEPs to recognise the economic value
of the natural environment, especially for sparsely populated
the need to consider plans for growth, infrastructure
and the natural environment within a coherent and integrated policy
framework, rather than in silos, and recognise the environment
as a key driver in the economy;
the importance of retaining landscape scale partnerships
in the face of budget cuts;
the implications for planning at a local level when
regional policies are no longer a material consideration;
the need for National Parks to be properly recognised
within the Government's National Policy Framework;
the need, if LEPs obtain planning powers, for NPAs
to be invited to have a place on a LEP, and for safeguards to
be in place to ensure that its activities when inside a National
Park contribute towards National Park purposes;
the need for LEPs to consider the specific needs
of rural areas; and
for arrangements to be put in place to ensure continued
data collection at sub regional level (including cut to National
Park boundaries), and for bodies to consider our future evidence
needs given a drive towards more landscape scale activity in response
to climate change.
6. Integrated approachWhilst ENPAA
does not comment on the merits of abolishing Regional Spatial
Strategies, we do want to ensure that there is a coherent framework
that will support (and not undermine) national park purposes.
While the Local Enterprise Partnerships provide a mechanism for
authorities to come together to discuss infrastructure and growth
requirements, there are no parallel arrangements for the natural
environment. We do not wish to see sub-regional policy developed
in silos and would prefer that a holistic approach was adopted.
Our early experience suggests, however, that in some regions the
natural environment has taken a back seat and that structural
changes risk exacerbating this unless sufficient checks and balances
are introduced into new arrangements.
7. Landscape Scale PartnershipsNPAs
are large areas covering many local authorities. As such, they
have a strong track record of working with authorities across
administrative boundaries. The National Park Management Plans
that are produced (and are a statutory document) set out a place
specific vision for the National Park (a vision on a landscape
scale); are developed very much through bottom-up community engagement;
and involve a wide range of partner organisationsincluding
local authorities. NPAs value greatly the close working that is
achieved with the local authorities within and neighbouring the
National Parks and would urge that a landscape scale approach
to partnership working be adopted through the operation of LEPs.
8. PolicyGovernment policy has
been that spatial planning policies developed at a local level
should not duplicate those covered in national or regional strategies.
NPAs have, in common with other LPAs, applied this approach and
it has been enforced by the Planning Inspectorate at Examinations
in Public. The quick abolition of RSS does have two immediate
consequences which are of concern to National Park Authorities.
First policies in recently approved core strategies will not,
indeed will have been prevented from, including policies supported
by the NPA but included in the RSS. The abolition of the RSS means
that these policies are no longer a material consideration for
the NPA's Plan. The second consequence of this is that NPAs, in
reviewing their spatial planning policies are likely to need to
add new policies that previously were addressed at regional or
9. National Policy Frameworkwe
believe that it is essential that the Government's proposed single
National Policy Framework document includes proper consideration
of National Parks. This should include the importance of NPAs
as planning authorities; the well established "major development
test"; and guidance to ensure the setting of protected landscapes
is properly considered in decision making.
10. We understand that the LEPs will be the main
basis of sub-regional economic and infrastructure planning. There
is also a possibility that the LEPs will have some planning functions.
NPAs have engaged with their partner local authorities on the
LEP process and supported some of the proposals. Government guidance
provided that NPAs be offered a place on the Leaders Boards that
were established under the Local Democracy, Economic Development
and Construction Act 2009, and we believe we have an important
contribution to make. Various studies have shown the significance
for the economy from sustaining a high quality environment. Some
headline figures from recent studies include:
Data from 2008 shows the 10 English National Parks
support over 54,500 FTE tourism related jobs (the total employed
will be a lot higher) and is responsible for an estimated £3.5
billion of spend in deep rural areas.
A study by the East Midlands RDA found that the Peak
District National Park contributed around £155 million to
the region in economic output (or Gross Value Added) in 2007 and
supports over 14,000 jobs across 2,800 businesses. Entrepreneurial
activity is said to be strong in the National Park with VAT registrations
considerably higher than the national average (eg 45 business
registrations per 10,000 inhabitants in the NP, compared to 39
nationally and 35 in the East Midlands).
The same study in the Peak District included a survey
of 300 businesses within the National Park in 2008. 56% of businesses
felt that the landscape and the environment had a positive impact.
60% of all businesses said they would be seriously affected by
a deterioration in the quality of the landscape, with 40% saying
it would affect them to some extent.
Studies for the Exmoor NPA indicate that the two
million visitors the National Park receives spend around £80
million every year within the local area.
11. NPAs believe that the natural environment
can be an economic driver. This is a theme which has been identified
in the Defra discussion document "An invitation to Shape
the nature of England". ENPAA welcomes this recognition
but believes more may be required to ensure this is reflected
in future planning arrangements.
12. Whilst NPAs will want to engage with LEPs
given our socio-economic duty and ambitions for sustainable rural
communities, ENPAA currently has concerns over LEPs obtaining
planning functions until the role of LEPS is fully tested and
the rational for involvement in planning further explored. We
would highlight in particular, the following:
LEPs bring together planning and key sectors of the
economy. But they are ad hoc in terms of their establishment
(based on past relationships and neighbouring authorities) and
are therefore not going to provide a coherent spatial planning
If a LEP were to have planning responsibilities,
it is unclear how the views of all local planning authorities
(including of National Park Authorities) would be sought and acted
upon? If the LEPs have planning powers, we believe NPAs as strategic
planning authorities for their areas should be offered a seat
(as they were on Leaders Boards).
13. In addition to the above, we will want to
see to what extent LEPs will address the specific needs facing
sparse rural communities and economies? A LEP will undoubtedly
be made up of many communities and it is unclear how smaller/sparser
communities will fare? ENPAA suggests that there should be a requirement
for rural proofing.
14. NPAs have benefitted from the data and research
that has been prepared through regional planning bodies/Leaders
Boards. The abolition of the RSS, coupled with spending cuts,
means that the reasons for compiling such data will at first sight
become less obvious. We would guard against rash decisions being
made that will lead to trend data being lost. We hope that arrangements
will be put in place to ensure such data can be compiled. NPAs
collect, analyse and disseminate a range of data relating to the
National Park when preparing National Park Management Plans. This
information is generally made available to the public and other
bodies to use. We would stress, however:
the importance of collecting data to national park
boundaries rather than just administrative boundaries; and
the need to consider what new data sets are required
as we increasingly move towards landscape scale approaches to
managing land in response to climate change.