Budget 2011 and environmental taxes - Environmental Audit Committee Contents


Written evidence submitted by The Wildlife Trusts

SUMMARY POINTS

—  New 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;

—  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 Fund;

—  "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.

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 protected sites.

A new system should provide for:

—  Firm protection for irreplaceable wildlife assets eg SSSIs, Local Wildlife Sites, as ancient woodlands, ancient soils, peatland etc.

—  Permanent habitat creation and restoration in the best possible locations.

—  Investment in re-establishing ecological processes to allow natural and semi-natural ecosystems to function.

—  Added 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:

—  Pooling 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.

—  Local 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.

—  Retaining 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.

—  Timing 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 accordingly.

—  The cost of ecological surveys to remain the responsibility of the developer.

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 Fund.

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, regulations etc)

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 Development Strategy.

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:

—  "local 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).

—  "Ecological 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 national agencies…." (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:

—  "Planning policy and practice should:

—  continue to provide the strongest protection to internationally important sites and strong protection from inappropriate development to SSSIs; and

—  provide 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" (recommendation 2).

—  "The government should ensure that the remaining areas of high conservation value that currently are not well protected are effectively safeguarded" (recommendation 9).

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:

—  Identify 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;

—  Integrate 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;

—  Work with local authorities to identify ecological networks as part of the Local Plan, including zones for restoration.

21 April 2011


 
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Prepared 7 July 2011