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Comments from the National Farmers
Union
on the scoping of the Environmental Planning Study
From: Brian McLaughlin, National Farmers Union, Agriculture
House, 164 Shaftesbury Avenue, London WC2H 8HL
27 October 1999 |
Further to my earlier telephone call, I attach a note on our thoughts
about the proposed study on Environmental Planning.
I think our main concern is that the study should not only be manageable
but also fair and even-handed in its approach. Whilst the environmental
agenda is important, that environment, especially in rural areas, is often
somebody's factory floor. These vital economic and social elements need
to be recognised and addressed in the study.
I hope this input is useful.
- The National Farmers Union (NFU) welcomes the opportunity to submit
comments to the Royal Commission on the scope of its proposed study
of Environmental Planning. The increasing use of the land use planning
system to deliver wider environmental policy objectives and the implications
of that for land use policy and decision making is a matter of increasing
interest and concern to NFU.
- We welcome the proposal to initiate a study of this kind although
from the indicative list of topics to be addressed, we believe that
the proposed project is at risk of being over-ambitious. The inter-relationships
between land use planning policy and practice and the wider environmental
agenda are complex and the Royal Commission will need to avoid the adoption
of an oversimplified approach.
- Before addressing the questions and issues, which we believe should
be central to the proposed study; we see merit in unpicking some of
the themes that are implicit in the study title.
Land Use Planning
- As far as land use planning is concerned the study needs to differentiate
between planning as a policy making process at a number of spatial scales
and planning as a development control decision making process. Whilst
the latter takes place at a predominantly local level, it is this interpretation
and implementation of strategic policies at the local level that often
best illustrates the true nature of the relationship between land use
planning and wider environmental policy. In that context, the decisions
of the planning inspectorate on appeals are also critical.
Environmental Policy
- The scope and content of the environmental policy agenda in the UK
has also become increasingly diverse over time. From an initial concern
about protecting visual amenity, the land use planning agenda is now
being used increasingly to deliver policy objectives that relate primarily
to the protection and management of primary resources such as water
air and soil. More recently, the sustainable development and the biodiversity
policy debates have added important intergenerational dimensions to
this process with significant implications for social and economic development
especially in rural areas.
Land Use Planning and Environmental Policy - A Farming Perspective
- Our perspective on the relationship between land use planning and
environmental policy derives primarily from our experience of their
operation in rural areas. Whilst agriculture as a rural land use
remains outside the remit of the planning system, the status of agricultural
development within planning has changed considerably over time. Moreover
the growing importance of the environmental policy agenda for farming
has given us considerable experience of the emerging relationships between
land use planning and environmental policy.
- Based on that experience and our lengthy involvement with the rural
policy agenda over time, we would summarise the relationships between
planning and environmental policy as follows.
- Development Planning
Within the development planning process, the growing importance of
environmental concerns is manifested in
- A tendency for a proliferation of designated areas often with defined
buffer zones and associated policies which emphasise a wide variety
of priorities usually protectionist in intent.
- An increase in "presumption" against policies and/or policies which
are in principle, supportive of development but whose qualifying conditions
impose onerous burdens on applicants.
- An increase in the use of the precautionary principle and the application
of principles of sustainable development based on definitions (e.g.
Brundtland) which are more appropriate to the global policy debate
than to the particular circumstances that prevail within the area
of a local or structure plan.
- Development Control
As far as local planning decision making is concerned, we would identify
the following as emergent trends.
- Local authorities seeking increasing amounts of supporting information
to support applications including a tendency for greater use of Environmental
Impact Statements.
- An increase in the number of approvals with environmental conditions
that at best are costly to implement and at worst render the proposal
economically unviable.
- A tendency to refuse applications on the grounds that they run counter
to the government's sustainable development policies especially but
not exclusively in respect of transport and accessibility.
Key Questions
- Based on the experience outlined above we would identify the following
issues as being worthy of the attention of the Royal Commission in its
proposed study.
- A general lack of scientific expertise amongst many professional
planners often leaves them over-dependent on the advice of specialists
from the environmental agencies. In some cases, the information
sources are environmental NG0s with single-issue agendas. In
view of the increasing use of environmental arguments in planning
policy and decision making, the Committee needs to address the question
of how local policy and decision makers use scientific and other
advice on the environment in policy formulation and decision making.
- The process of plan making is no longer the monopoly function
of the land use planning process. Management plans and strategies
are now an established feature of the work of many environmental
agencies such as the Environment Agency and English Nature. The
preparation of these strategies is often the sole preserve of those
agencies with little effective consultation or partnership with
other stakeholders with an interest in the issue being addressed
or any wider public involvement. Despite that, the resultant management
plans are often adopted as part of the Local Plan and/or used as
the basis of development control decisions. This issue of the
status of such plans within the statutory planning process is a
topic which we believe merits the attention of the Commission.
- Sustainable Development is now an established principle within
government policy and the land use planning system has been identified
as an important policy vehicle for its delivery. As we perceive
it, the main value of this concept is its ability to overcome the
apparent dichotomy between economic progress and environmental protection.
- We remain concerned that, in the UK to date, environmental concerns
have dominated the agenda with the result that the concept of sustainable
development is being widely abused. Too often the "sustainable"
and "development" aspects become separated thus negating the concepts
central economic logic. Consequently, a genuine debate about how
best to ensure that development takes place with proper regard to
longer term environmental consequences is becoming a more narrowly
focused debate about "sustainability" which is usually defined as
a negative and protectionist policy mechanism.
The whole question about how land use planning interprets
the sustainable development agenda and especially the potential
gap between national policy for sustainable development and its
local interpretation in plans and policy decisions is an issue
that merits the attention of the Commission's study.
- Related to the above is the inherent tension that is often apparent
between the essentially long-term nature of the environmental policy
agenda and the timescale within which local decision-making often
takes place. Whilst environmental agencies and NG0s often identify
this tension as being detrimental to environmental interests, our
experience is often to the contrary.
- Even in situations where national guidance is sympathetic to the
interests of rural economic development and regeneration (PPG7)
short term policy-making locally often decrees such guidance to
be detrimental to the interests of sustainable development. In that
context, the Commission should be directed to the research report
entitled "Rural Development and Land Use Planning Policies" published
in 1998 by the (then) Rural Development Commission.
This crucial relationship between the longer term agenda
defined by the Government's environmental and sustainable development
policies and the shorter term political context of local planning
decisions is a matter which merits close examination in the Commission's
study.
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of the Environmental Planning Study
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