Royal Commission on Environmental Pollution

In response to the invitation to comment on the forthcoming study of environmental planning, I would like to make the following comments.

In broad terms I am in agreement with the topics to be covered and see them as all being important. In particular, I feel that topic f) can be of great benefit in the relatively short-term because of duplication in areas such as Environmental Impact Assessment (EIA) and Integrated Pollution Prevention and Control (IPPC). This comment also impinges on topic i).

One concern I have in relation to the use of the term environmental planning, and a consideration of sustainable development all at the same time, is that sustainable development is about much more than the environment (as should be environmental planning). It really would be a bad mistake to concentrate on the natural environment alone at the expense of social issues and economic issues because it ultimately makes decisions impossible. All these issues need considering together rather than in isolation where there must inevitably be a winner. (For example, do we want jobs or an SSSI?). In this regard, tools like EIA can help, but are potentially dangerous. If EIA embraces social impacts, health impacts and economic impacts as well as environmental impact, it is truly a useful tool for environmental planning and can be a tool for sustainable development. At present it is not this - but it can be!

I do feel that what is missing from the list of topics is a consideration of where Local Agenda 21 fits into environmental planning? It strikes me that the various initiatives which take place round the country are highly variable in nature and in terms of true backing from authorities. Research has shown that local authorities are embracing LA21 but in different ways with and for different reasons. It seems that a review such as this might be able to suggest a sensible foundation for LA21 within local authority work which might formalise the work taking place and help to integrate democratic control referred to in topic a). The research referred to is included as Appendix 1 to this letter [The Appendix is not reproduced on the website, but is available on request from the RCEP Secretariat].

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