Royal Commission on Environmental Pollution

1. The Natural Environment Research Council (NERC) is the lead UK-wide organisation for basic, strategic and applied research and training across the spectrum of the environmental sciences. It supports scientific research, survey and monitoring at universities and through its own Centres and Surveys: the British Antarctic Survey (BAS), the British Geological Survey (BGS), the Centre for Coastal and Marine Sciences (CCMS), the Centre for Ecology and Hydrology (CEH) and the Southampton Oceanography Centre (SOC - a joint venture with the University of Southampton). NERC is not directly involved in environmental planning, but a wide range of its programmes underpins planning activities.

2. NERC welcomes the opportunity to contribute to the first stage of this new study and is ready to provide more detailed input at the next stage. This response, which draws on input provided by BGS, CCMS, CEH and SOC, follows the headings given in the letter of invitation.

3. NERC has no comment on this issue.

4. Although government is setting national (reduction) targets, eg for greenhouse gas emissions and waste to landfill, local objections often frustrate the national policy and deter business investment. The Royal Commission is well positioned to address the tensions between justifiable local concerns in a democracy and national priorities is critical to allowing joint economic and environmental progress.

5. The Royal Commission might consider the role of regional planning guidance in advising local planners where there are proposals to locate specific industries in sensitive locations.

6. Consideration should be given to the case for statutory procedures to ensure that environmental data are acquired/consulted in the environmental management process.

7. There is an issue of whether, as a result of regionalisation, the principles of good planning and pollution control are being applied consistently across the UK, or even within English regions; and if not, what the benefits might be of issuing regional guidance on both planning and pollution control.

8. The Royal Commission might wish to consider whether there is sufficient monitoring of the outcomes of planning and pollution control decisions so as to learn how well predictions of adverse effects and expectations of good effects were realised.

9. The Royal Commission may wish to consider whether the terms planning, development control and pollution control could be replaced with a single term relating to the sustainable use of natural resources where decisions are based on finding the Best Sustainable Environmental Option (ie an economic development choice that minimises negative influences on the environment, taken as a whole). This would assist in making the process more transparent and accountable.

10. To meet the goal of sustainable development, four objectives must be met simultaneously: social progress; environmental protection; prudent use of natural resources; and stable economic growth and employment. The Royal Commission might explore how these objectives, that addresses local, national and international priorities, can be reconciled.

11. It would be worth exploring whether a more explicit recognition of Agenda 21 principles and good practice would deal with many of the tensions that exist in current arrangements.

12. There is a proliferation of advice on various aspects of environmental resources connected to both the classical concerns of planning (landscape, transport, drinking-water supply, wastewater treatment, amenity and social provision) and more recent ones (such as nature conservation, human health and sustainable development). An analysis of all advice available for a particular region would be important to determine the role of planning in achieving other environmental objectives.

13. NERC believes that it is important for the Royal Commission to consider whether the current planning and pollution control regimes make sufficient allowance for long term changes to the environment due to climate change and other developments. It is also important to consider the long term consequences of the decisions themselves on the environment (eg groundwater pollution).

14. This is an important and complex issue. Several points that are relevant here are made in other paragraphs of this response. NERC hopes that the study will take account of the impact on marine ecosystems of land-based developments, eg pollution run-off, coastal urbanisation.

15. The Royal Commission may wish to consider how planners can use advice, for example from bodies such as Environment Agency, Countryside Agency or English Nature, that is based on neither administrative boundaries, river catchments nor other easily recognised physical features.

16. How are relevant environmental data, information and knowledge identified, acquired, managed and, finally, accessed by the user to enable appropriate environmental planning? Issues such as data availability and adequacy need to be considered in the context of the technological advances in Information Technology.

17. A key issue is whether there is sufficient use in both planning and pollution control of the latest environmental information and ecological, geological and hydrological understanding of the environment at all stages of the process from initial scoping to final decision.

18. It is not for NERC to comment on specific examples of good and bad practice. However, there are many generic examples of bad decisions being taken for the want of adequate provision, or consideration, of sound scientific advice. Examples can be found in the proliferation of building on flood plains and areas of geological instability, the sterilisation of mineral or aggregate deposits by development, and constraints on deployment of renewable energy from landfill gas and waste incineration. The Royal Commission might explore how such practice could be improved.

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