Written evidence submitted by The Wildlife
approaches to funding that recognise the multiple benefits provided
by the natural environment, eg ecosystem services, would allow
us to restore nature over a much larger area than before. Government
can play a role in enabling new innovative funding streams to
be developed, eg environmental taxes on peat, developer contributions
and payments for ecosystem services;
Wildlife Trusts is concerned that the principle of hypothecation
in relation to some "green" taxes is being diluted or
removed eg Aggregates Levy Sustainability Fund;
Plan for Growth" and the Localism Bill have not provided
the planning policy framework needed for the natural environment
following the abolition of Regional Spatial Strategies. The forthcoming
National Planning Policy Framework and Natural Environment White
Paper must fill that gap.
1. The scope for the taxation system to protect
and increase stocks of natural capital and the possible role of
proposed "natural accounts"
1.1 New approaches to funding that recognise
the multiple benefits provided by the natural environment, eg
ecosystem services, would allow us to restore it over a much larger
area than before. Government can play a role in enabling new innovative
funding streams to be developed, eg environmental taxes on peat,
developer contributions and payments for ecosystem services.
2. Developing a scheme for biodiversity offsetting
and developer contributions
2.1 The Wildlife Trusts have a long track record
of working with local authorities and developers to develop and
deliver Section 106 agreements. In this context, we are keen to
work with Government to develop and pilot the conservation credits
/ biodiversity offsetting concept. We recognise the potential
of biodiversity offsets, currently being developed by DEFRA and
linked to the planning process, to be used to restore the natural
environment through the creation of credits which can be pooled
and used to achieve landscape scale conservation.
2.2 We support the idea of offsetting operating
at a larger geographical scale than Section 106 agreements and
would consider Ecological Restoration Zones (described in section
7.2) as the most obvious focal point of investment through this
scheme. However, we would be concerned if the scheme were to become
too distant from the point of delivery. This risks breaking the
local connection between development impact and compensation.
The Wildlife Trusts believe that it is important for credits to
be invested directly in third sector delivery within each area.
Organisations with a long standing presence and a direct relationship
with local communities value direct relationships with local companies
that may be developing land. This is a key part of building community
ownership and engaging people in shaping the vision for a local
Living Landscape scheme and area, and in supporting them
in taking action. Capacity can also be built by endowments associated
with S106 agreements being directly held by voluntary sector bodies
without a "middle man".
2.3 We support the principles outlined in the
recent Making Space for Nature report (September 2010)
which we believe must underpin the system if it is to be effective.
Our key issues are:
To achieve nature's recovery, the new system should
be triggered by loss of opportunity for restoration and
damage to natural processes as well as damage to
A new system should provide for:
protection for irreplaceable wildlife assets eg SSSIs, Local Wildlife
Sites, as ancient woodlands, ancient soils, peatland etc.
habitat creation and restoration in the best possible locations.
in re-establishing ecological processes to allow natural and semi-natural
ecosystems to function.
value: The land that is to be restored and/or re-created may already
have a pre-existing "value" to nature and/or to people.
This will need to be considered when deciding whether to proceed
and when calculating the mitigation or compensation required.
The governance of a new scheme should allow for:
of developer contributions at a landscape scale,
the proximity principle should be geared around "ecological
restoration zones", opportunity maps or similar that are
locally derived and relevant. It is not appropriate to offset
damage to biodiversity in one part of England with another.
authorities to work in partnership with local delivery organisations
and one another to ensure implementation. New mechanisms may be
needed to ensure for cross-boundary co-operation
between local authorities and ecological expertise must be secured
either within, or by, local authorities.
direct financial and delivery relationships between
companies and charities involved in the contribution and the delivery.
Conservation charities are ideally placed to continue delivering
high quality habitat restoration; and benefit from endowment funding.
and risks of implementation: Compensation
should, wherever possible, happen ahead of development. In determining
the scale of compensatory measures or restoration required, consideration
of the risks to successful delivery must be taken into account,
and a suitable ratio of offset area to impacted area assigned
cost of ecological surveys to remain the responsibility of the
3. The impact of the taxation system in general
on sustainable development
3.1 The Wildlife Trusts is concerned that the
principle of hypothecation in relation to some "green"
taxes is being diluted or removed eg Aggregates Levy Sustainability
4. Aggregates Levy Sustainability Fund
4.1 Until its closure by Defra in March 2011,
The Aggregates Levy Sustainability Fund (ALSF) was a vital funding
stream for the natural environment and for frontline voluntary
organisations such as The Wildlife Trusts. Each year, up to 10%
of the £330 million revenue from the Aggregates Levy had
been distributed through the ALSF by bodies including local authorities
(£3 million per annum) and Natural England (£3.5 million
per annum). The Wildlife Trusts have been able to invest £1
million each year over the last couple of years in local community
initiatives through grants from the ALSF. Wildlife Trusts have
received funding for land purchase, skills training for volunteers,
improvements to nature reserves, education centres and visitor
facilities and other purposes. An independent report assessing
the ALSF for the Government in May 2010 concluded that "overall,
the value for money assessment is good and many areas offer evidence
of excellent potential value for money, particularly in the medium
to long term".
5. Landfill Communities Fund (LCF)
5.1 The Landfill Communities Fund (LCF) has promoted
regeneration, created jobs and improved quality of life in our
local communities. Over the last 10 years, around £50 milion
has been allocated to 500 Wildlife Trust projects through the
LCF. It has supported land reclamation, the provision and maintenance
of nature reserves and initiatives to benefit particular habitats
and species. The LCF is already heavily oversubscribed and The
Wildlife Trusts believe that the Government should increase the
proportion of 1andfill tax receipts diverted to 7%.
6. How policy proposals in "The Plan
for Growth" will affect sustainable development and environmental
protection (ie planning, green growth, low carbon investment,
6.1 "The Plan for Growth" and the Localism
Bill have not provided the planning policy framework needed for
the natural environment following the abolition of Regional Spatial
Strategies. The forthcoming National Planning Policy Framework
and Natural Environment White Paper must fill that gap.
7. National Planning Policy Framework
7.1 The National Planning Policy Framework must
ensure that planning delivers true integration of environmental,
social and economic priorities and objectives. We believe there
should be a common, overarching definition of sustainable development
included within the framework and preferably on the face of the
Localism Bill, rather than leaving this for local interpretation.
The Wildlife Trusts support the definition of sustainable development
given in PPS1 "development that meets the needs of the present
without compromising the ability of future generations to meet
their own needs." and the principles in the UK Sustainable
7.2 In achieving sustainable development, planning
must take a strategic approach to consider the spatial organisation
and use of land and natural resources. Making Space for Nature,
the recent independent review of England's wildlife sites and
ecological network, led by Professor Sir John Lawton, concluded
that "England's collection of wildlife sites, diverse as
it is, does not comprise a coherent and resilient ecological network
even today, let alone one that is capable of coping with the challenge
of climate change and other pressures." This presses home
the urgency of effectively managing the use of our natural resources
and minimising the impacts of development on the environment through
good planning policy and practice. The review makes a number of
recommendations in this regard:
authorities should ensure that ecological networks including areas
of restoration are identified and protected through local planning.
Government should support local authorities in this role by clarifying
that their biodiversity duty includes planning coherent and resilient
ecological networks." (Recommendation 1).
Restoration Zones need to be established that operate over large,
discrete areas within which significant enhancements of ecological
networks are achieved, by enhancing existing wildlife sites, improving
ecological connections and restoring ecological processes. We
further recommend ERZs should be proposed and implemented by consortia
of local authorities, local communities and landowners, the private
sector and voluntary conservation organisations, supported by
." (Recommendation 3).
These recommendations recognise that the natural
environment cuts across administrative boundaries and that planning
for its protection, restoration and creation will require a "larger
than local" approach. The Wildlife Trusts believe that the
NPPF should provide the spatial framework and the mechanisms by
which stakeholders should cooperate to achieve these recommendations
to secure our national ecological infrastructure, building on
existing good practice and initiatives that have already been
developed across much of England (for example regional opportunity
maps and Living Landscape schemes). It is important that the NPPF
recognises that natural "green infrastructure" is every
bit as important to the country as conventional infrastructure
(for transport, energy, water supply & treatment, waste management,
etc). The ecological network is the basic infrastructure that
will enable biodiversity assets to recover from deficit and become
resilient to climate change impacts, and thus deliver ecosystem
services which are of social and economic value.
7.3 Regional planning policy has provided a mechanism
for local authorities and other partners to plan strategically
and develop cross-boundary, sustainable development objectives.
The obligation on the Secretary of State to undertake strategic
environmental assessments prior to revoking the regional spatial
strategies is a significant opportunity to ensure that the best
elements of regional planning (especially, but not exclusively,
those concerning the natural environment) are taken forward into
a new national planning policy framework. With the abolition of
the regional tier, Clause 90 of the Localism Bill introduces a
duty to cooperate. As it stands there is a lack of clarity about
how this will work in practice and whether it will go far enough
to allow strategic planning for nature conservation as an integral
part of sustainable development. Furthermore, we have concerns
that some local authorities may choose cooperate primarily through
Local Enterprise Partnerships, which are economically driven and
lack any environmental remit.
7.4 In the absence of a stronger duty, it will
be critical that the NPPF sets out a new framework for cooperation
between local authorities and other key stakeholders to take a
strategic, spatial approach to sustainable development which includes
the identification and inclusion of Ecological Restoration Zones
in local plans. This will need to draw on local knowledge and
understanding of the area, and involve representatives from across
local government departments, NGOs, landowners, businesses, utility
companies, local communities and individuals.
Making Space for Nature
also recommends that:
policy and practice should:
to provide the strongest protection to internationally important
sites and strong protection from inappropriate development to
greater protection to other priority habitats and features that
form part of ecological networks, particularly Local Wildlife
Sites, ancient woodlands and other priority BAP species"
government should ensure that the remaining areas of high conservation
value that currently are not well protected are effectively safeguarded"
The Wildlife Trusts strongly support these recommendations
and do not wish to see the protection afforded to the natural
environment weakened through the consolidation of existing planning
policy statements and their associated policies and good practice
guidance. The Wildlife Trusts recommend the NPPF provides a strong
presumption against inappropriate development which might affect
any components of the ecological network. This is particularly
important for components of the ecological network such as Local
Sites which have no statutory protection beyond the planning system.
As well as providing the strongest protection for existing natural
assets, reforms to the planning system should retain objectives
for their restoration and creation.
8. Natural Environment White Paper
8.1 The Natural Environment White Paper in June
2011 will need to create a new policy framework to drive nature's
recovery, building on existing statutory protections. The Wildlife
Trusts believe that England needs a new Nature Act to create
the necessary impetus for significant restoration of habitats
and ecological processes on a landscape scale. In particular,
the White Paper should lay the foundations for the establishment
of Ecological Restoration Zones across England and new Local Nature
Partnerships to help drive this process. The key functions of
Local Nature Partnerships would be to:
zones for ecological restoration through enhancing existing landscapes
and national and local wildlife sites, taking action for priority
species, restoring the processes that drive ecosystem health and
restoring and creating new areas of habitat;
land management policies, incentives and decision-making locally
to ensure efficient use of resources and the provision of key
ecosystem services such as clean water, food, flood protection
and control of our climate;
with local authorities to identify ecological networks as part
of the Local Plan, including zones for restoration.
21 April 2011