Royal Commission on Environmental Pollution

1. The Confederation of British Industry (CBI) - with a direct membership employing over 4 million and a trade association membership representing over 6 million of the workforce is the premier organisation speaking for business in the UK.

2. The CBI welcomes the opportunity to make a submission to the Royal Commission regarding its forthcoming study of environmental planning. The CBI feels that the study could have an important role to play in improving aspects of the current land use planning system in order to achieve wider policy objectives.

3. Our submission will outline the key concerns that business has regarding the current planning system and suggest areas of further study. We hope that these will inform your current consultation process and further the debate on environmental planning.

   KEY CONCERNS

4. Business is concerned that the quality of environmental information which is being used in the planning process is inadequate.

5. It is imperative to improve the methods for assessing the impacts and benefits of developments giving equal weight to environmental, economic and social elements.

6. It is imperative that the role of the Regional Development Agencies is clearly defined, in order to avoid any conflicts between local, regional and national interests.

7. The primary concern of business is to make the existing system work better and to remove unnecessary delays within the system.

   FURTHER COMMENT

   Business is concerned that the quality of environmental information which is being used in the planning process is inadequate.

8. It is imperative that the quality of information is improved. There is a need to establish common standards for submissions of environmental data along with common measures on environmental pollution.

9. Business does not want to supply more information. However, there is a distinct need for more consistency and less duplication or differing requirements for different organisations.

10. Furthermore, the CBI feel that the use of common measures and standards will allow for a better assessment on the environmental consequences of development. Indeed, it would significantly benefit the Government by allowing it to establish clear and understandable targets.

    It is imperative to improve the methods for assessing the impacts and benefits of developments giving due consideration to environmental, economic and social elements.

11. Applying the concept of sustainable development to planning matters remains ambiguous. Indeed, it can be difficult for planners to balance economic objectives with societal and environmental demands.

12. Business does not want to all development to require an Environmental Impact Assessment as this can be extremely costly and prolong the planning process. However, we feel that the economic contribution that development makes needs emphasis and refinement.

13. As a result, the CBI feel that there is a need for micro improvements to refine the quality of information on which decisions based.

    It is imperative that the role of the Regional Development Agencies are clearly applied to planning matter, in order to avoid any conflicts between local, regional and national interests.

10. The emergence of regional development agencies and the recent publication of draft regional economic strategies, could lead to a potential conflict of interests at the local, regional and national level.

11. This is particularly important with so many environmental plans which impact on development at local/regional and national levels (biodiversity action plans/air quality strategies etc).

12. A further key issue is how national/regional/local strategies and responsibilities are integrated and reconciled within a sustainable framework.

The primary concern of business is to make the existing system work better and to remove unnecessary delays within the system.

12. Business has no desire to alter the current planning system, which is widely understood and broadly appreciated as a fair system for reconciling competing land use and development interests resulting from economic, environmental and social demands. The primary concern of business is to make the existing system work better and to remove unnecessary delays within the system. For this reason it is important to impose time limits on the planning processes within the system and encourage all actors to discharge their responsibilities in a timely and efficient manner.

13. The planning system should aim to reduce the barriers to securing the effective, efficient and sustainable use of land which is in the public interest. It should not impose additional controls, excessive information requirements or layers of decision making. The planning system is increasingly the subject of complex procedures and legislative requirements, particularly in areas such as minerals or waste, and the ability of authorities and business to comply with these requirements whilst retaining sight of their main objectives is increasingly burdensome.

14. CBI members are particularly concerned with the Environment Agency as a major source of delay together with other statutory consultees who delay the consideration of planning applications by submitting late or incomplete data. Setting clear standards for data collection and performance from statutory consultees would help speed up the process.

15. It is worthwhile referring to the CBI study on the EA, 'Shaping Up' which cites examples of our concern including a lack of consistency, lack of clarity, duplication with planning and other controls, the submission of late and 'holding' responses which cause delay, slow internal administration, the provision of little advice or support to resolve issues and requests for excessive information.

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