Royal Commission on Environmental Pollution

Initial submission

Friends of the Earth (FOE) welcomes the opportunity to offer its views to RCEP on the scope and direction of its inquiry into environmental planning. As a national public interest environmental pressure group with some 230 local voluntary groups, and an active member of both Friends of the Earth International and Friends of the Earth Europe, FOE has wide-ranging relevant experience and expertise on environmental planning.

We are pleased that RCEP has recognised that environmental planning extends beyond the remit of land-use planning, as experience with the pursuit of 'sustainable development' over recent years indicates that more has been demanded of the land-use planning system than it can deliver. In our view, this has resulted from two principal factors: the lack of any consistent framework for effective national environmental planning to ensure 'joined-up' planning; and the effects of outdated procedures and imbalances in economic and political power within the development planning system.

National Environmental Planning

Friends of the Earth Europe has been at the forefront of developing methods for national environmental planning since 1992, when, in preparation for the Rio Earth Summit, Friends of the Earth Netherlands produced its 'Action Plan - Sustainable Netherlands', applying the concept of environmental space' to the Netherlands. Since then, with the assistance of the Wuppertal Institute (Spangenberg, 1994), Friends of the Earth and associated groups have applied this approach to 30 European countries. In the UK our findings - using the most up-to-date and sophisticated environmental space methodology - were published as an Earthscan book (McLaren et al, 1998).

The environmental space approach compares a country's consumption of key environmental resources: fossil energy, land, water, timber and selected non-renewable materials with a 'fair share' of the sustainable level of use of those resources to set long-term objectives or targets for rates of resource consumption. The implications are dramatic for national planning in areas such as energy and transport, land-use, minerals and water. Two European countries - the Netherlands and Denmark - have taken a lead in using environmental space analysis to shape - or help shape - strategies in such areas.

The approach has influenced the Dutch Government's series of National Environmental Policy Plans, which have delivered substantial environmental improvements on many fronts. Denmark's national energy plan (Danish Energy Agency, 1996) has set ambitious targets for reductions in greenhouse gas emissions and for rapidly increasing the share of renewable energy generation. Such targets have implications for many policy areas, including land-use planning. In the UK we estimate that environmental space targets for energy could be achieved by 2050 by installing renewable energy generation capacity (wind, solar and wave) of 275TWh, improving energy-efficiency in the building stock by 50%, in industry by 45%, and in road transport by 70% and reducing road traffic volumes by 40%. Such shifts can only be achieved by harnessing the market, and directing it, through a series of planning tools, including taxes and spending, regulation and land-use planning. Without a sense of the overall objectives, it is highly unlikely that such a package of measures could be developed.

Two examples are outlined below. Each demonstrates the urgency of reform of the land-use planning system, along with the need for a wider and deeper approach to national environmental planning.

Planning for climate change
A range of land-use measures are required - policies and land allocations to encourage renewables, compact redevelopment of cities, protection of flood-plains and land for managed coastal retreat. Such measures are urgently needed if the Government's manifesto promise to cut UK C02 emissions by 20% by 2010 is to be met. Nonetheless, to effectively plan both to minimise and to mitigate climate change will require a wider package, including energy and fuel taxation, reform of the regulatory framework for the energy utilities, revised building regulations and energy efficiency standards (and labelling); and investment in public transport (McLaren et al, 1998). These all affect the economic environment faced by producers and consumers of energy, at various timescales. Land-use planning is critical because of the direct link with energy-use in transport. For example, new homes need to be well placed in relation to public transport, as well as meeting high energy efficiency standards, while the energy efficiency of existing homes needs to be radically improved which again will require targeted investment as well as potentially, innovative measures to impose 'least-cost' planning via the development control system (see for example, Marvin, 1992).

Planning for biodiversity
Accelerated loss of biodiversity is another long-term trend that requires a combination of strategies to reverse. Whilst land-use change is probably the major cause of biodiversity loss world-wide, the land-use planning system has leverage over only limited parts of the problem. Improved land-use planning controls over minerals extraction, and development on both green- and brown-field sites of nature conservation value (including, but not limited to SSSIs) are urgently required. Clearance of forest or conversion of grassland to arable use tends to dramatically reduce biodiversity - but in the UK, neither is covered by the land-use planning system. Nor is the introduction of invasive species or for that matter, biotechnologically altered genes - both of which pose significant threats to biodiversity. More generally, the positive management of semi-natural habitat (often in use for agriculture, forestry or recreation) is critical to the long-term survival of the UK's biodiversity, not least to deal with the impacts of climate change on natural habitats.

As its highest priority therefore, the RCEP should examine the scope for the development of national environmental planning tools for the UK, based on the environmental space methodology as a way of promoting 'joined-up' policy to promote sustainable development..

The politics of development planning

Without the congruence of national policy in these various areas, neither development plans nor development control procedures will be capable of making development sustainable. The land-use planning system will not encourage energy companies to sell efficiency packages instead of building gas-fired power stations, nor local services to be located in communities by shopping-centre developers when not only do the short-term financial pressures favour of the unsustainable option, but the developers have all sorts of political leverage over planning authorities.

As far as land-use planning is concerned, environmental planning must be seen as a part of planning for sustainable development, which requires a wide-ranging modernisation of the development planning system - widening the remit of both development planning and development control (beyond strictly 'land-use' issues), ensuring a positive and participatory rather than negative and adversarial approach to development, all within a policy and planning framework that is 'joined-up' from the neighbourhood to the nation (embracing national transport plans, regional policy and regeneration initiatives). As the recent TCPA Inquiry into the future of planning concluded: "planning for sustainable development will require nothing less than a complete change of culture for planning and planners" (TCPA, 1999).

This suggests a very wide ranging agenda for the RCEP, and in the context of the development planning system we would advocate a number of key issues for consideration, which are outlined below.

A new economics
As stressed above, the economic context in which development proposals are developed is critical if fewer undesirable proposals and more positive sustainable proposals are to come forward. Earlier we noted the need for national fiscal and expenditure policy to help steer the nature of development proposals. Two aspects of taxation policy overlap with the existing development system. First is the question of land taxation. As an element of a broader tax base, and as an incentive for the more efficient use of land, the RCEP should examine options for land taxation (including the so called 'green-field' levy) to allow for reductions in other less desirable taxes.

Second is the question of betterment, and impact fees. Unpublished research for FOE (Campbell et al, 1999) suggests that the current system of planning obligations is profoundly inequitable, and demands reform. Within the context of an examination of the case for land taxation, the RCEP should examine options for betterment taxation, and the separate levying of impact fees.

Planning and regeneration
Business interests and some academics tend to deride any form of planning as a source of economic costs and thus lower overall social well-being. Friends of the Earth firmly refutes any such view. Planning has a strong social purpose in that it can help ensure the fair distribution of economic activity, both spatially and socially. Current practice however, does not deliver the economic and other development needed in areas of social exclusion and deprivation. Of course, development planning alone cannot be expected to deliver on such ends, but it is critical to ask how it can contribute positively to regeneration. Friends of the Earth does not hold the view that this requires the subjugation of development planning (through regional planning guidance and development plans) to the Regional Development Agencies economic strategies, but that closer coordination is needed between regeneration expenditure by RDAs and development planning, with shared objectives of sustainable development (Jenkins and McLaren, 1999).

The RCEP should examine the role of development planning in steering regeneration expenditure and initiatives, both regionally and nationally, where the clearest test of planning and regeneration initiatives can be seen in the contrast between overheating southern suburban locations, suffering from congestion and threats to greenfield sites, and stagnating northern cities, increasingly characterised by empty property and blight.

Environmental justice
As noted above, planning obligations have negative distributional consequences. So do other mechanisms of the current development planning system. Recent research by FOE confirmed that in the UK, the most polluting factories are concentrated in poor areas (McLaren et al 1999). Research by the London School of Hygiene and Tropical Medicine has suggested that traffic pollution levels (determined in part by the location of new development) are highest in poorer areas with the low car ownership (Stevenson et al, 1999). These environmental injustices cannot be dealt with purely by the development planning system, but must become a key concern for it. This implies a wider remit than land-use, including, in particular, ambient pollution levels.

The RCEP should examine how development planning can be reformed to help eliminate environmental injustice in the UK.

The mechanics of the system
Last, but not least we turn to the procedures for rebalancing the system. All of the foregoing has operated on an assumption that the national objectives of 'sustainable development' which inform regional and local planning include the principles of active participation by communities. There are a range of possible reforms here, and Friends of the Earth suggests that the most urgent include the end of the presumption in favour of development, the removal of the limitation of material grounds for rejection to 'land-use' concerns, the introduction of third-party rights of appeal, and the elimination of 'predict and provide' policies for housing and minerals.

The RCEP should examine reforms to the development planning system which would give communities much more influence over both plans and development control and therefore the incentive to participate positively in the system.

References

Campbell, H., H. Ellis, C. Gladwell and J. Henneberry, 1999. Betterment Taxation and the Environmentally Efficient Use of Land. A Report for Friends of the Earth. University of Sheffield Department of Town and Regional Planning.

Danish Energy Agency, 1996. Energy 21. See http://www.ens.dk/e21/e21uk/index.htm

Jenkins, T. and D.P. McLaren, 1999. Regions and Sustainability: Making regional policy sustainable and sustainability regional - the key role of Regional Development Agencies.

Friends of the Earth. Paper to Oxford Brookes Regional Planning Seminar 18` May.

Marvin, S.J. 1992. Towards sustainable urban environments.: the potential for least-cost planning approaches. Journal of Environmental Planning and Management 35(2) pp 193-200.

McLaren, D.P., S. Bullock, and N.Yousuf. 1998. Tomorrow's World: Britain's share in a sustainable future. London, Earthscan

McLaren, D.P, 0. Cottray, M. Taylor, S. Pipes and S. Bullock. 1999. Pollution Injustice. http://www.foe.co.uk/pollution-injustice/

Spangenberg, J. (ed) 1994. Towards Sustainable Europe. Brussels, Friends of the Earth Europe.

Stevenson, S., C. Stephens, M. Landon, T. Fletcher, P. Wilkinson and C. Grundy. 1999. Examining the inequality and inequity of car ownership and the effects of pollution and health outcomes.

Environmental Epidemiology Unit, London School of Hygiene and Tropical Medicine. Paper for the Healthy Planet Forum, June 1999.

TCPA Inquiry into the future of planning, 1999. Your place and mine: reinventing planning. London, Town and Country Planning Association.

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