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

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 areas;

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 approach—Whilst 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 Partnerships—NPAs 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 organisations—including 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.  Policy—Government 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 sub-regional levels.

9.  National Policy Framework—we 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 context.

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.

September 2010

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