Environment, Food and Rural Affairs CommitteeWritten evidence submitted by Hampshire County Council

1. Introduction

Hampshire County Council has been invited by DEFRA to submit views to the Environment Food and Rural Affairs Select Committee on a number of aspects of the Natural Environment White Paper. The comments set out below are based mainly on comments provided on the pre-White Paper consultation in October 2011 and on subsequent briefing papers and decision reports to Members.

2. The Pre-White Paper Consultation

When the pre-White Paper consultation was published, the County Council welcomed the commitment to addressing the environment in an integrated way but expressed a number of key concerns and observations. These can be summarised as:

The scope of the consultation document was too narrow, with a focus on the natural environment at the expense of other aspects of the environment (such as the built and cultural environment and depletion of natural resources) and did not take account of the totality of people’s connections with their environment.

The terms “nature” and “natural environment” are open to misinterpretation and misuse.

The language of ecosystem management will not engage people.

One of the most effective means of securing multiple benefits from the environment is through Green Infrastructure planning, which has a wider remit than the natural environment.

Connecting people with their local environment will require investment of resources from local government at a time when those resources are being depleted.

The delivery of the White Paper objectives is in part dependent on effective structures for the delivery of “localism” and these are not yet in place.

3. Response to Questions from the Chairman of the EFRA Select Committee

3.1 What actions are required across Government Departments, from local government and by civil society to deliver the White Paper’s proposals to grow a green economy and reconnect people with nature?

3.1.1 There is a cost to the national economy, both in the short and the long term, of not reducing the impact of our activities on the environment. These costs will emerge as a result of higher prices for raw materials and natural resources, higher costs in treating poor health and higher costs in mitigating the impacts of climate change. There is therefore a benefit to the national economy as a result of businesses and individuals reducing their environmental impact. However, there is often a cost to businesses, in terms of competitiveness, in changing management, manufacturing or transport processes that benefit the environment, and those costs should be offset, at least in part, by increasing incentives.

3.1.2 The challenges are in developing the evidence base for the real value of natural capital at a local level, in translating what that means, and in developing a “strategy” that is embedded into economic planning. It is unlikely that, at present, those with the remit to develop the economy locally (ie local authorities, business organisations and businesses themselves) have the knowledge to embed the value of natural capital in the economy, or how to apply the principles. Until the Government develops its own thinking on this and engages with those organisations it will be difficult to respond to the White Paper’s objectives.

3.1.3 It will be important to maximise and build on existing initiatives. Sustainable business growth has been at the heart of the activities of the Hampshire Economic Partnership for many years. The County Council supports the Hampshire and Isle of Wight Sustainable Business Partnership which in turn supports businesses in adopting more sustainable practices as part of their activities.

3.1.4 In terms of reconnecting people with nature, area based management plans and strategies, prepared with cross-discipline and community involvement, provide the mechanism for articulating the values attached to the environment, whether economic, social or environmental. The approach to producing management plans in National Parks and AONBs is a model for this kind of working.

3.2 Will the institutional framework outlined for delivering the proposals (in particular Nature Improvement Areas and Local Nature Partnerships) be effective? Does the proposed Natural Capital Committee have sufficient powers?

3.2.1 The County Council supports the principle of Local Nature Partnerships, provided that it is a single partnership that covers the whole of Hampshire, that it replaces the Hampshire Biodiversity Partnership, that its remit and membership is extended to embrace all interests (social, economic, cultural and biodiversity) and that its focus is on delivery of projects on the ground.

3.2.2 The open invitation to bid for funding to set up Local Nature Partnerships has resulted in competition between areas where a single partnership bid would be more practical. Multiple Local Nature Partnerships within a County would place unnecessary demands on the resources of partner organisations, and the Government is encouraged to take this into account when considering bids.

3.2.3 Once established, a Local Nature Partnership can be an effective forum for the planning and delivery of integrated working. However, it should not be the sole mechanism for achieving action, and those activities, initiatives and programmes that develop outside the Local Nature Partnership but still deliver White Paper objectives should not be disadvantaged in terms of access to funding streams.

3.2.4 The County Council is more cautious about Nature Improvement Areas. Whilst the White Paper defines “natural environment” fairly broadly, NIAs, as the key mechanism for delivery, have one driver: to link, buffer and expand biodiversity. Any other benefits that derive from this are spin-offs rather than central to delivery. This undermines rather than reinforces the objectives for balanced integration in the White Paper.

3.2.5 The invitation to participate in a competition for NIAs is potentially counter-productive. In order to be able to bid, some form of partnership must be in place, and so the main source of applications will be from the protected landscapes (National Parks and AONBs) which are already receiving funding well above those areas outside. There has been no analysis of where there is greatest need for investment due to biodiversity being under particular pressure, nor of where investment would achieve the most multiple benefits, including for society and the economy. This should be an essential pre-requisite to determining the priorities for investment.

3.2.6 There is also concern that, as with Local Nature Partnerships, NIAs will become the focus for Government investment at the expense of work programmes that are equally valid, equally beneficial and equally capable of delivering White Paper objectives, but which fall outside an NIA. There are examples of such projects and programmes emerging through the Total Environment pilot being undertaken in Hampshire, which fall partly or wholly outside proposed NIAs.

3.2.7 Whilst the value of the natural environment to a strong economy and sustainable communities is recognised, the County Council is concerned about the impact that NIAs may have on essential growth, particularly in rural areas. Analysis of trends in Hampshire shows that there is a need for investment in the economy and housing to address a declining level of sustainability in rural communities. There is a risk that NIAs, with their focus on the expansion of ecological interest, will act as a constraint on essential development or economic activity.

3.2.8 As a result of these concerns the County Council is not actively engaging in NIAs and will be continuing to invest its resources in areas where there are demonstrable needs and where there are committed partnerships working to meet those needs.

3.2.9 With regard to the Natural Capital Committee, the White Paper appears to refer to its role as advisory. It is not clear from the White Paper what, if any, “powers” the committee will have.

3.3 What further research and/or evidence is required to develop practical programmes sufficiently detailed to deliver the White Paper’s ambition to fully embed the value of nature into policy delivery?

3.3.1 This has been touched on in the answer to question 1. In breaking new ground the White Paper introduces new and complex concepts, including ecosystem services, natural capital and biodiversity offsetting. These have been the realm of specialists in those fields and are now being brought into the public domain. There is much to be done by Government to raise the level of awareness of these concepts, to develop expertise within organisations and to provide advice and support to those organisations to help them translate the knowledge into policy and action. This applies to those with responsibility for land use planning, land management planning, economic development and community planning.

3.3.2 One of the key vehicles for addressing the value of nature in policy delivery is the National Planning Policy Framework. Hampshire County Council has submitted separate comments to DCLG on the draft statement. Amongst the County Council’s concerns is the lack of clarity in the policy framework about what constitutes “sustainable” development. It is through the definition and the application of the policies for sustainable development that the value of nature will be recognised. At the present time the National Planning Policy Framework does not reflect or recognise the value of nature or natural capital as it is expressed in the White Paper, and so does not provide a framework for its consideration in planning policy at the local level.

3.4 What evidence is there from other countries that the approaches proposed in the White Paper can be successfully applied in practice?

This aspect has not been considered by the County Council.

3.5 What resources will be needed to fully deliver the White Paper’s ambitions and how can these best be provided? How might the value of “services” provided by ecosystems to beneficiaries be translated into spending that will enhance the natural environment?

3.5.1 It is essential that Government ensures that appropriate structures for local government and “localism” are in place. Currently there is a void between high-level national policy making and local planning delivery. With planning for transport, minerals, waste management, education, social care and flood management (all critical to the delivery of the White Paper objectives) resting with County Councils, and other aspects of land use planning resting with Districts, and both being linked with civil society and local communities, effective coordination between and across all levels of local government, and across sub-regional scale areas, is necessary.

3.5.2 If the White Paper’s ambitions are to be delivered, those with the responsibility for coordinating actions across separate organisations, developing policy, raising awareness, providing advice, implementing actions of the ground and measuring its success will need to be adequately informed and resourced. There are numerous references in the White Paper to the Government working with local authorities, and of local authorities being responsible for aspects of the delivery of the White Paper. Despite the White Paper’s claims that this does not pose any additional burdens on local authorities, the reality is that it will, and at a time when resources have been depleted significantly by reductions in public sector funding.

3.5.3 Much of the delivery of the White Paper will rely on the land management industry, which will need to balance the requirements for food and timber production (provisioning) with the delivery of other ecosystem services. There will be an economic cost to this and the Government will need to incentivise land managers. Similarly, encouraging businesses towards more sustainable ways of working will have an economic cost that will act as deterrent unless there are incentives. The alternative to incentives is for the costs of goods and services that meet higher environmental standards to be passed on to the consumer.

3.6 Does the White Paper set out an accurate assessment of the barriers to public engagement with the natural environment and make the most effective proposals for re-engagement?

3.6.1 The barriers to public engagement have been well articulated in the White Paper, and the ideas put forward would appear to address them. The acknowledgement of Green Infrastructure as a key mechanism for linking people and the natural environment is welcomed. However, it is again the translation of these aspirations into reality that presents the greatest challenge, given the financial and human resources needed.

26 September 2011

Prepared 16th July 2012