Royal Commission on Environmental Pollution

The Quarry Products Association has examined copies of the papers distributed in respect of the expert round table into the above study. We view some of the emerging themes with concern. I have been asked to submit the attached paper to you on behalf of our members, which picks up our major worries on the direction that part of this study may be taking.

There is no objection to this response being made public.

Introduction
The Quarry Products Association is the only Trade Association representing the UK aggregate industry. Our members produce over 90% of aggregates quarried in the UK and are thus totally dependent on the efficient working of the planning system for the planning permissions that enable aggregate production to be maintained.

Response
We have studied the brief background report appended to your letter of 13 August and the longer discussion paper circulated before the Round Table meeting on 7 September. We view some of the comments in the background paper with some concern as now explained:-

Paragraph 2.6: - there seems to be a theme here and elsewhere in the paper, largely unsubstantiated, that the planning system is too narrowly focused to allowed sustainability to develop. The paragraph starts of "many argue that.." but then only cites TCPA and CPRE. The confusion here about the role of planning and its relevance to sustainability then runs through the whole paper.

"Sustainability" is elevated almost to the status of a religion when almost in practice it is, of course a concept which could simply be referred to "good stewardship" of the environment". In terms of planning PPG1 sets out the most common version of sustainability - "development that meets the needs of the present without compromising the ability of future generations to meet their own needs". To be clearer still, sustainability is about prudent use of resources and care for the environment. What the background paper misses is that planning is but one agency involved in the delivery of sustainability and is not even necessarily central to that.

Paragraphs 3.11 - 3.1.4 emphasises this conclusion and how far the background paper has gone off the rails. In 3.11 for instance one of the primary, non land-use sustainability policy objectives is improving water quality. That is correct. However, water quality is principally within the control and management of the Environment Agency and is only peripheral to the planning process. Likewise in 3.14 - "crime, health and safety" are all matters for agencies other than planning authorities.

What the paper has failed to grasp is an understanding of the local authority district/UDP planning system whereby the L.P.A. consult other agencies on their policies and future needs and then prepare a development plan facilitating those needs. It is hopelessly ambitious to suggest that the planning system could and should be redesigned to improve water quality, cut crime, provide for renewable energy and create economic competitiveness.

We feel strongly therefore that RCEP should be advised that the town and country planning system set up under the 1947 Act has stood the test of time and is well able to play its part in delivering sustainability in collaboration with the many other agencies involved. If there are faults they lie at the lack of co-ordination of policies at the national level and with the lack of resources provided to the LPAS at the local level. It was, of course, the essence of the 1947 Act system that as it took away citizens' rights to develop their own land, there was a presumption in favour of the grant of permission, unless there were compelling reasons for refusal. That presumption in favour remains to this day, albeit modified by Section 54A. It would be inequitable and unjustified to reverse that presumption.

Paragraphs 4.45 - 4.49
We totally reject any suggestions that the system of planning gain should be encouraged or widened. What is already happening is tantamount to the buying and selling of planning permissions despite the good advice in circular 1/97. It is entirely wrong to regard the practice of community benefit/ planning gain as a system for topping-up shortfalls in local authority budgets or as an alternative system to the former development land tax.

Conclusions
QPA thus believe there is no crisis in the UK planning system, no philosophical difficulty in facilitating the aims of sustainable development and no need to consider widening the remit of planning to cover such factors as forestry or farming for example.

We also reject the criticism of the system by CPRE at paragraph 2.8. The CPRE's remit is entirely about opposing development and preserving the countryside unchanged, regardless of the consequence. The Government, correctly take the view that sustainable development is both about good stewardship and about maintaining economic prosperity, a view we strongly support.

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