Royal Commission on Environmental Pollution

Our comments at this stage are restricted to key issues rather than to points of detail.

We believe that there are three critical issues to be addressed, all of which bear on the effective implementation of environmental planning.

These are:

• the methods of democratic control

• the knowledge base

• economic viability

Democratic Control
Initiation of development is nowadays almost exclusively commercially based. The purpose is profit and environmental considerations are observed at the minimum level permitted by statute. This level is being steadily raised, not least as a result of EU legislation.

Control of development is primarily by local authorities at County and District Council Level. They operate on a political basis and are made up of lay persons often with very little knowledge or training in environmental matters. Environmental situations have varying boundaries and range from very specific and local to regional or national significance. The smallest are often beyond the notice of a District Council, many others require cross boundary consideration. A democratic structure that can control development or activity at ALL levels from micro to macro is essential. Control, however, is not enough and this structure must also be capable of the initiation of activity that is considered necessary for the public benefit.

Knowledge Base
For the democratic structure to function adequately and effectively, an informed and competent knowledge base is required. There are two elements to this. There is the professional and technical planning support and there is the leavening of public interest and opinion. Widely based planning teams of qualified professionals are needed at both County and District level incorporating environmental experts in varying fields. These should be supplemented by advisory groups on regional matters and local issues (also by inter-authority co-operative action) and leavened by open consultation with the public at local level.

Training in environmental subjects is relatively new in the UK and few administrators in senior positions have such experience. The majority of environmentally qualified graduates do not obtain environmentally related employment and the skill base is thereby depleted. This problem could be addressed in parallel.

Economic Viability
During the 1970's, the heyday of the planning profession, many excellent and expansive development plans were produced by planning departments and consultants teams. Regional, sub-regional, district and local plans abounded. Outside of the New Town Corporations few came to fruition (except in truncated and less effective form) due to economic factors. They could not be afforded!

The same fate awaits environmental plans unless a modified strategy is adopted. Environmental planning teams should include economic, financial and cost advisors and all plans should be thoroughly tested for economic viability. This may involve quite sophisticated techniques of cost benefit as well as social benefit analysis. Issues can be complex, conflicting and controversial!

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