Royal Commission on Environmental Pollution

Thank you for seeking the views of the Local Government Association on your current study on Environmental Planning. My apologies for these comments not reaching you by the 29th October.

The Local Government Association presented a summary of points to be included in this submission to the Planning Executive on the 18th October, which were subsequently supported by members.

Holistic Nature of Sustainability
The holistic nature of sustainability needs to be recognised by the study. In particular, the commission should investigate the relationships between social, economic and environmental issues that impact upon environmental planning. This should generate sound valid guidance for planners upon which to make informed decisions on sustainable development, as well as information for the public.

Co-ordinated Sustainability Appraisal Framework
The issue of sustainability in relation to environmental planning is a complex area, where individual experts are involved in examining a single issue within the study. Accordingly, a coordinated sustainability appraisal framework needs to be developed to ensure a consistency of approach to assessing sustainable development. This should develop into a plan-led system which is based on shared visions for environmental planning led by a set of agreed objectives, and based upon objective scientific evidence.

Co-ordination of Land Use Planning and Community Planning
The interaction and co-ordination of land use planning and community planning to achieve sustainable development needs to be examined. in particular, a bottom-up approach should be implemented to encourage greater community consultation. The relationship between a 'top-down' and 'bottom-up' approach, and the need for planning systems to be more responsive to changing approaches to sustainable development are also important.

Transparency of the Process
The sustainability appraisal process should be transparent for all parties involved, including local communities.

Good Practice Guidelines
There is a need for the implementation of good practice guidelines in the translation of policy. At all levels of planning, those involved must be aware of current good practice. This framework should reflect current ideas on sustainable development and needs to be updated regularly. Specifically, good practice for planners is required to examine the impact which wider environmental considerations will have on the planning system.

Presumption in Favour of Development
Although the Local Government Association supports entirely the 'plan-led' system of sustainable development, there is a need for the study to examine some of the fundamentals of the current planning system, such as the presumption in favour of development (e.g. the Planning Inspectorate).

Decision-making by Local Authorities and National Bodies
The extent of the decision-making power as relating to the roles of local planning authorities versus national bodies on issues of environmental pollution also needs to be investigated by the study. There is the threat for potential conflict between various levels of planning and the methods by which co-ordination between these groups can be achieved should be addressed.

Definition of Environmental Planning
A definition of 'environmental planning' and how this differs depending on various stakeholders (i.e. at the local and national level), and also between environments (e.g. coastal areas, forests etc.). Contrasting planning methodologies will also view 'environmental planning' differently (hence the need for a co-ordinated sustainability appraisal framework).

I hope that the above comments are helpful. Please contact me on 0171 664 3045 should you have any further queries.

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