Royal Commission on Environmental Pollution

Further to your recent contact with myself, and my colleague Rick Minter, I am writing to raise a few points which you might like to consider for your scoping exercise for the above RCEP study.

First of all I should state that the Countryside Agency welcomes the RCEP's study. We are involved in several other debates on the future of the planning system, and we hope the RCEP can add value to the messages which are emerging from these.

You suggested to Rick Minter that we keep our points brief, so I offer the following thoughts which might be relevant to the angle from which the RCEP is approaching this subject:

A creative philosophy for planning
The Countryside Agency's recent planning policy statement, enclosed, calls for planning authorities to work within a long term vision for their locality. We believe that planning policies should encourage new developments to enrich our social, economic, and environmental future. So developments should be judged on the overall benefits they bring to future generations, rather than on whether they are acceptable or tolerated. The new philosophy should be 'is it good enough to approve?', not 'is it bad enough to refuse?'

Evaluating 'what matters' in the environment
The Environmental Capital approach, as developed by the Countryside Agency, the Environment Agency, English Heritage, and English Nature, provides a way of identifying and evaluating the benefits provided by different aspects of the environment. Focusing on these benefits, and evaluating them in a consistent way, whether or not they are easy to measure, offers a more subtle approach to managing change from new development, and ensuring change is for the better, not for the worse. In essence the Environmental Capital approach helps to identify what conditions, and what limits, should be applied to proposed development.

A summary of the Environmental Capital approach, and its rationale, is set out in the enclosed article reproduced from EG magazine. [Available from the Royal Commission Secretariat on request]

Managing natural resources beyond the scope of the planning system
The limited scope of the planning system in relation to resources such as soil, air, water, and energy, continues to exercise people's minds. People are looking for effective ways of co-ordinating these factors which should influence new developments and land-use changes. We believe that a system akin to a sustainability appraisal could be developed in order to co-ordinate action on these topics. We suggest that public bodies and agencies responsible for managing and regulating natural resources co-ordinate their input to planning and development decisions, through a matrix indicating responsibility and targets for necessary actions, and indications of their effects, covering all aspects of sustainable development. This process could be co-ordinated by the local planning authority, and its joint ownership would give it a status which supplemented the role of the formal planning system.

We would welcome the opportunity of developing these and related points, either in a further submission to RCEP, and/or in a discussion with your members. Meanwhile, 1 hope these points are helpful.

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