Royal Commission on Environmental Pollution

Thank you for your letter to the Permanent Secretary inviting the Department, along with other organisations, to make an input to the scoping of the Commission's new study of environmental planning. 1 have been asked to reply, but must apologise for the length of time it has taken to do so. You have had a number of discussions with colleagues here so at least 1 know the content of this letter will not be a surprise.

Though the Department welcomes this wide-ranging and ambitious study, it's broadness and, what seems to us, a lack of focus, causes us to question its manageability.

We think that the Commission's goals are somewhat ill-defined. Environmental planning is described in the project outline as the interaction between land-use planning, environmental protection and other environmental plans. However, the interchange between references to environmental and sustainable development objectives leaves us unclear about how you propose to examine these linkages, and where the study might lead. We have two concerns about the study's probable focus: one, arising from the policy direction that Government is heading, is that we would not want the study to focus on achieving environmental policy objectives as opposed to sustainable development objectives. The other, arising from the particular emphasis in your outline on the role of the planning system, is a concern we have about the capacity of the planning system, particularly as it is operated at the local level, to continue to absorb and deliver on goals that run far wider than the use of land.

We recognise that land-use planning has a crucial part to play in securing sustainable development as part of an integrated approach to policy delivery. As part of the Modernising Planning initiative, the Department is making efforts with other government departments to knit together various regulatory regimes, for instance, getting a more integrated approach with DTI to renewable energy and with MAFF on rural development, including agri-environment matters. However, as you rightly point out, there 'may be good reasons for not attempting to cover all aspects of the environment in a single comprehensive procedure'. If the Commission's intention is to examine the scope for further integration of the environmental planning 'toolkit', we would expect you, as a preliminary step, to address the question of whether further integration can be achieved without overloading an already heavily loaded planning system.

Against this background, we are happy for you to examine whether present procedures for environmental planning, taken together, are adequate to achieve sustainable development; or if there are indications of problems arising or missed opportunities at some of the existing interfaces. Therefore, we would encourage the Commission to focus its energies on item (f) in the topic list, the extent of gaps, duplication, co-ordination and conflict in present arrangements.

There are issues here about the robustness of policy and the extent of real 'joined-up thinking' across the various regulatory regimes in the face of problems like climate change, water supply, pollution control, energy use and efficiency, and construction. A subset of issues for examination would include:

• how effective the land-use planning system is as a tool for helping deliver sustainable development;


• what changes, if any, need to be made;


• whether there is a need for better integration and/or rationalisation of the various planning and control regimes, including the non-statutory ones; and


• how the current arrangements, and any changes the Commission might suggest for adding an environmental responsibility to planning procedures, will help deliver the Government's Modernising Planning objectives for a faster, more efficient planning system.

Equally important is the status of and relationship between these plans and the range of bodies that produce them. The UK biodiversity framework, for instance, is largely non-statutory and dependent on voluntary co-operation, but it has a strong relationship to, and is often reliant for its implementation on, a range of more formal arrangements. These include statutory development plans as well as international agreements and obligations.

Devolution has added another dimension to inter-governmental relationships and how targets are set and related to local action. Building a better relationship between different tiers of government and different levels of activity must be a priority.

We hope the above suggestions will be of help in sharpening and making more manageable the study. Colleagues here look forward to participating in your 'joining up environmental planning' seminar on 3 February, which should be useful in these respects. Please also feel free to come in at any time to discuss particular aspects of the study.

We look forward to some very useful outputs.

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