Environment, Food and Rural Affairs CommitteeWritten evidence submitted by The Royal Institution of Chartered Surveyors (RICS)

The Royal Institution of Chartered Surveyors welcomes the Natural Environment White Paper inquiry by the EFRA Select Committee, in order to get as wide a possible range of opinions on the future of the natural environment, enabling a green economy and the future management of land. It also provides an opportunity to look at how the NEWP and its provisions operate within the web of other government reforms and initiatives, rather than being analysed in isolation.

Broadly the Institution welcomes that the NEWP is a move away from seeing the natural environment as a separate “special interest” and is trying to integrate it with wider economic policy and land use planning.

The emphasis on green economy, natural capital and the valuation and management of eco-system services is one that land agents and surveyors believe has the greatest chance of engaging a rural England that is primarily managed through private ownership.

The NEWP is also not just about designated sites; it is advocating a much more holistic approach to land management and the economy. This is something the RICS welcomes and applauds – but it is right to ensure that it is pragmatic and dynamic in its application.

The following response is the considered thinking of a group of RICS members drawn from our Countryside Policy Panel and our Rural Professional Group Board, representing the views and priorities of RICS members involved in land and natural environment management in the UK. These members work in organisations from the public, private and third sectors; all of whom are required by our Royal Charter to put forward their opinions as an RICS group, considering the public interest.

About RICS

RICS is the leading organisation of its kind in the world for professionals in property, construction, land and related environmental issues. As an independent and chartered organisation, RICS regulates and maintains the professional standards of over 91,000 qualified members. It regulates and promotes the work of these property professionals throughout 146 countries and is governed by a Royal Charter which requires it to act in the public interest.

RICS is the most significant body of UK surveyors and land agents, engaged in all aspects of land, forestry and property management in rural areas. RICS sets out its approach to rural communities, farming, forestry and natural environment, in its Rural Vision: http://www.rics.org/site/download_feed.aspx?fileID=8223&fileExtension=PDF

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?

1. The NEWP needs to be firmly linked to other government policies and strategies, the most glaring of which is the National Planning Policy Framework. Without considering one in the context of the other, the government will not achieve the sustainable development and growth that the country requires, whilst expanding the green economy based on the valuation and management of increasing eco-system assets.

2. We would support the adoption of a more pragmatic approach towards land management, including reduction of regulation and an increased in the understanding of markets. Civil Society in particular needs to have increased information explaining opportunities in both local and global markets, to increase its understanding of natural environment economics. This is not presently considered in the UK Ecosystem Services approach.

3. The delivery of the NEWP will depend heavily on partnership working. This will need to be stimulated, promoted and led. And not just at national level between government departments and countrywide organisations, but also with new Local Nature Partnerships and the local authorities and communities they encompass.

4. RICS has been encouraging Local Enterprise Partnerships to set-up sub groups that look specifically at how land management and development can contribute to economic growth. In some cases we have been successful. DEFRA have decided to set-up parallel nature partnerships to LEPs, who have the potential to be natural adversaries to each other if vested interests prevail in either.

5. This will cause a fault line in terms of the management and valuation of eco-systems services by either LEP or LNP. To this extent we believe that the National Ecosystem Assessment must be used to factor in the value of eco-system services.

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?

6. The decreasing funding for Natural England, Environment Agency and Forestry Commission is likely to make them more reliant upon a regulatory based approach and less so upon market creation and effective partnerships (which cost money and resource to develop and consult upon). Decreasing funding and the advent of Local Nature Partnerships have the potential to negate many established partnerships, as their members will have to chase funding for their projects elsewhere, whilst looking to LNP to set regional and local priorities.

7. As many County Councils have significantly reduced or removed their biodiversity/ecological staff (eg Hampshire CC, Oxford CC) the structure of the LNPs and NIAs are only advantageous to large natural conservation NGO’s and local authorities. Given the amount of land that is in private ownership and management in England, and much of our most environmentally valuable land managed by small private estates, LNPs need to be as open to the private as the public and third sectors. Without this balance, there risks the creation of decision making that is not in the public interest or integrated with other needs, such as economic development. A large question now hangs over the appropriateness’ of LNP decision making and implementation of NIA on the ground.

8. There is a lack of clarity as to whether DEFRA, CLG and BIS have jointly run scenario planning to look at how LNPs and NIAs would interact LEPs and EZs, preferably under the reformed planning system. Turning to the NIAs and LNPs in particular:

9. NIA: We believe there will need to be more than 12 NIAs to make a significant difference, and these would have to be on a landscape scale and not restricted in size such as the Enterprise Zones, which LEPs can create. NIAs need to be focused where they can make the most difference for ecological enhancement not just the already designated areas. Consideration needs to be given by DEFRA and CLG to weighting and planning status. The focus would ideally be on positive opportunity as well as protection.

10. LNP: LNPs need to work closely with LEPs, including joint working groups on land management and eco-system services, and not operate as separate economic and environmental silos. LNPs need to reflect the ambitions of NEWP and not just be a reconstitution of existing bodies such as Biodiversity Action Plan groups under a different name. LNPs need to foster co-operation and partnership working in strategic policy terms as well as land management on the ground. LNPs need to take an integrated approach to land and consider natural resources and ecosystem services as well as wildlife; in terms of scale this lends itself to County Councils.

11. The other designations outlined in the NEWP, such as local green spaces, have the capacity to create further confusion and complexity. Greater simplification must be an aim otherwise administration and management costs will use up more of the scare resources, rather than actual delivery and action.

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?

12. There needs to be a full study on the economic impacts of the approach outlined in the NEWP and what impact it will have on rural and environmental businesses, green jobs/employment, markets and skills. Critically does the White Paper approach improve the cost effectiveness of land management delivery or does it make us more dependent upon grants and subside.

13. There are also excellent examples of Green Infrastructure strategies working in relation to the planning system. The RNRP Green Infrastructure and Environmental Character Suite is an excellent example of where natural environment planning has worked very effectively and achieved real results: http://www.rnrpenvironmentalcharacter.org.uk/

14. RICS can contribute its recently produced an information paper entitled “Green infrastructure in urban areas”. This underlines that the NEWP should not miss the opportunities for increasing natural capital in urban areas, both for its own biodiversity benefits, place making potential, but also reducing the impact of climate change.

15. Amongst other measures, green infrastructure comprises trees, green walls, green roofs, open spaces and the networks that emerge from linking these together. The provision of all of these gives rise to areas of practice where RICS surveyors have a key role to play in offering professional advice not just at the scale of the building but at the level of the city. A key focus of this information paper is to understand not just the intrinsic value of green infrastructure but also its economic value.

16. Green Infrastructure is also a key part of the rural sector and in many cases it will be delivery within the rural areas that will facilitate the delivery of many of these large projects. The interface between rural and the urban environment is key and does not seem to be recognised in the NEWP. This will also be critical for the delivery or piloting of any bio-diversity offsetting projects.

17. What the surveyor contributes, to choices about the various types of green infrastructure, is a keen understanding of the relationship between costs and value. The decision to invest in green infrastructure is one with long-term implications. It requires expertise on the appropriate measures to be taken in particular conditions, as well as an ability to provide value for money solutions. Whether surveyors are specifying roof covering, costing drainage schemes or appraising a development proposal, understanding the implications of green infrastructure is essential.

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?

18. As the valuation profession, and the one that provides surveyors, land agents and asset managers, we’d be concerned at creating an eco-system service market where there is no agreement on the difference between worth and value, let alone agreement on how to value eco-system services.

19. In the present debate we have economists, ecologists and sociologists attempting to define the value of eco-system services, without the input of the valuation profession. Our members will be the operators called upon by business and others to value eco-system services when business attempts to operate in this market. The risk is that a market will be created but that it will be artificial and that values will not drive the increase in environmental condition and bio-diversity that Government wish to see in the green economy.

20. RICS has produced guidance on the valuation of water and valuation of forestry (and also on valuation of trees and woodland for amenity value) but these are stand alone documents and not a comprehensive answer

21. In DEFRA’s recent technical consultation paper on bio-diversity indicators, page 11, they are seeking sources of knowledge for the “Valuation and accounting for biodiversity”. RICS is happy to discuss further assistance to government in this area as outlined above. Furthermore we are about to initiate a large scale piece of research looking at the valuation of non-market goods (with a strong focus on eco-system services).

22. This will all help towards the assessment of natural capital too, though we would contend that there’s a substantial difference between attributing an economic worth to natural capital, and then assigning eco-systems a monetary value and constructing a market for their trading.

23. The eco-systems asset approach will require new skills and new partnerships developed to better integrate rural business and environmental enhancement. If this can be done through LNPs and LEPs, then professional land management expertise can develop and promote new approaches to land management and novel partnerships between the owners of land and rural entrepreneurs.

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 forre-engagement?

24. The recent cuts to government departments have the potential to create further barriers to general environmental education and recreation, as well as more bespoke approaches and projects. This has not been defined in the NEWP or sufficiently addressed. 

25. Cuts in County Council rights of way departments (for instance) will result in degraded PROW networks for cyclists, horse riders and pedestrians. Cuts in Forestry Commission and Natural England are ending well established education services linked to a range of priority habitats, species and rural businesses. Cuts in the Public Forest Estate, National Parks, County Council and Local Authorities will reduce the potential of national and local tourism thus restricting the “paying back” potential to the nation.

26. The emphasis that is put on volunteers risks being inappropriate where volunteers may be responsible for delivering services previously managed by retained professionals, rather than expanding and deepening their reach into society.

28 September 2011

Prepared 16th July 2012