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Evidence from the Countryside Agency
to the Environmental Planning Study


From: Rick Minter, The Countryside Agency, Headquarters, John Dower House, Crescent Place, Cheltenham, Gloucestershire GL50 3RA

4 July 2000

The Countryside Agency and the planning system
1. The Countryside Agency works for people and places in rural England. It seeks to:

  • Conserve and enhance the countryside;
  • Promote social equity and economic opportunity for the people who live there;
  • Help everyone, wherever they live, to enjoy the countryside.
2. The Countryside Agency welcomes this opportunity to contribute to the RCEP environmental planning study. We are centrally involved in current debates on the future of the planning system, and have recently worked closely with the Town and Country Planning Association, the Local Government Association, and the UK Round Table on Sustainable Development on this topic.

3. The Countryside Agency, in its forthcoming policy on the future for planning, Planning for People and Place, calls for development plans to address the following points in order to make planning a more effective tool to achieve sustainable development:

  • consider what development is needed for a sustainable countryside as well as where it should go;
  • integrate policies so plans look first for solutions where there are economic social and environmental benefits, and then for solutions which mitigate or compensate for adverse impacts. There should always be a net gain and no significant losses from development;
  • use positive objectives as the basis of planning; not predict and provide;
  • encourage high quality applications which are good enough to approve, rather than ask if applications are bad enough to refuse;
  • give a positive role to communities and community planning;
  • respect the character of all landscapes and protect the best.
Sustainable development
4. Our comments below reflect and amplify many of the recommendations in the above summary of our planning statement. Rather than cover the full scope of the study's questions we have focused our points around your 'environmental sustainability' and 'assessment approaches' sections.

5. We think that the RCEP's use of the term 'environmental sustainability' is unfortunate. Putting prefixes on 'sustainability' and 'sustainable development' undermines what the concept is about: the integration of environmental, social, and economic objectives. We support the need to address and understand environmental protection, and environmental resource management, but for clarity we would rather use those terms than 'environmental sustainability'.

6. We believe that the Government's sustainable development strategy, A Better Quality of Life, provides a clear definition of sustainable development:

"Sustainable development means meeting four objectives at the same time, in the UK, and the world as a whole:

  • social progress that recognises the needs of everyone
  • effective protection of the environment
  • prudent use of natural resources
  • maintenance of high and stable levels of economic growth and employment"
7. Those who are uncomfortable with the economic growth objective in the definition should not forget that it must be conditioned by meeting the other three objectives.

8. We believe it is unhelpful to think in terms of environmental imperatives (RCEP's 1b) as static reference points. Instead we believe that development and change should be governed by conditions and limits, which might be environmental, social, or even economic ones, and these will vary according to the development (or change) itself, and the host site or locality. The criteria for these conditions and limits need to be rigorous and transparent. (see 'the Capital approach' below)

Integrating sustainable development objectives
9. The challenge for the planning system is to implement such a system of conditions and limits, and to conceive development proposals, and policies for development and change, by integrating the objectives of sustainable development. Our provisional thinking on achieving such integration is set out in paragraphs 10 - 15 below.

10. Approaches to the integration of policies which have been used in development plans are summarised in the box below. It is not just a question of weighing economic against social, or environmental against economic. Many of the gains versus losses will be within each of the three themes.

SOME POSSIBLE INTERPRETATIONS OF INTEGRATION

Having it all or win-win-win
WWW
Solutions which meet some social, economic and / or environmental objectives without harming any others.
Net gain or no net loss
NG
Advances in some aspects of social, economic or environmental objectives outweigh any losses.
Conflict minimisation
CM
Solutions which reduce the potential conflict between different objectives.
Policy Compatibility
PC
Policy objectives within a plan are not working against each other.
Strategic co-ordination
SC
Plans for the same area support each other and take a co-ordinated approach to achieving common objectives.

11. We believe a better approach is to require development to show a net gain for the social environmental or economic interests of the area, with no significant losses to them. Policy integration can achieve this result if decision making at the plan level is done in two stages.

  • The first stage is to identify those solutions for meeting development needs which provide gains for economic, social and environmental objectives. eg. affordable housing on a brown field site as part of regenerating a market town, or encouraging the reuse of vernacular farm buildings close to villages for workshops and housing.
  • the second stage is to make sure that remaining development needs, which do for example take greenfield sites, mitigate or compensate through associated measures any significant adverse impacts so there are no significant losses. eg. the landscape benefits which hedgerows or woodland provided are retained or new landscape features offering a similar benefit are provided, informal recreation sites are kept or re-created, or new habitats developed so that the wildlife values of the area are retained.
12. Para 15 shows how these two stages might fit within a RPG, Structure or Local Plan process.

13. This approach does not mean:

  • any element of the environment is 'tradable'. Ancient woodland, to take one example, cannot be re-created. Some of the benefits such a wood provides can be provided elsewhere, but not the habitat represented by the wood itself;
  • all losses are significant. Losing an arable field may not be a significant environmental loss, losing an ancient hedgerow or an SSSI would be. The views of the local community will be important in establishing local significance;
  • the countryside and its rural communities are preserved in aspic.
14. This approach does mean:
  • benefits which are important locally must be replaced locally;
  • significant social and economic losses must be replaced as well as environmental ones.
15. To achieve a systematic and transparent approach to overall net gain with no significant losses, the preparation of development plans should include a process which:
  1. clearly identifies the most significant social, economic and environmental assets in the plan area, eg market town and villages services, major sources of employment, valued habitats and landscapes;
  2. identifies the level of significance attached to each scale - international, national, regional, local; and involves local communities and stakeholders in determining this;
  3. identifies needs to be met, based on defensible evidence;
  4. estimates the land and resources needed to meet these needs
  5. compares strategic options to identify those which are best at meeting multiple objectives and achieving net gain;
  6. explores whether management measures can reduce demand, making links to other strategic plans (Local Transport Plans, for example), which can influence demand management;
  7. explains the criteria used for detailed site selection to meet needs, and mitigate or compensate for any significant losses;
  8. indicates how social, economic and environmental impacts of planning decisions will be monitored.
Setting conditions and limits for development - The Capital approach
16. The Capital approach identifies conditions and limits on development by identifying the benefits to human wellbeing of environmental, social, and economic assets which will be affected by a proposed development. It provides a rigorous way of determining the importance of these benefits, and of considering how, if at all, they can be substituted if lost or damaged. Where important benefits cannot be substituted this should form a limit on the development. A more full explanation is set out below.

17. The term capital is used as a metaphor to emphasise the need to invest in environmental, social, and economic assets, to reap a flow of benefits.

18. The aim of maintaining and enhancing economic capital is already entrenched in the planning system through, for example, guidance and policies on protecting employment land and transport corridors. The Countryside Agency believes the planning system should give as much weight to maintaining and enhancing environmental and social capital which, as the Government's sustainable development strategy A Better Quality of Life argues (paras 4.2-4.6) are equally important for sustainable development.

19. The Capital approach is based on the joint Countryside Agency / English Heritage / English Nature / Environment Agency work and testing of this subject over the past three years.

The Capital approach and environmental assets
20. In applying the Capital approach to environmental assets we are considering the stock of environmental assets, including, human-made or influenced objects and places as well as natural ones, which produce benefits for human wellbeing.

21. For example a water meadow might produce a range of benefits including:

- recreation - perhaps both quiet strolling and organised ball games;
- biodiversity;
- framing a view of a historic town centre;
- grazing;
- impounding flood water and thus helping prevent more damaging flooding downstream.

22. Different benefits may matter to different people and to different degrees. For example grazing benefits farmers; strolling benefits local people; football local children; the view may be famous to visitors but more taken for granted locally; biodiversity may matter as part of the ecological resilience of a wider area. It is the benefits that matter not necessarily the stock in itself. For example there would not necessarily be any advantage in making the water meadow bigger, so long as it was managed to provide enough of or indeed increase all the benefits described.

23. The Capital approach uses the following steps to evaluate the importance of the benefits, and to inform the policy response to the development proposal:

- at what scale do they matter?
- how important (high, medium, or low) are they at this scale?
- do we have enough of them (recognising any explicit targets, and society's values and preferences)
- could anything substitute for the loss of any particular benefit?

24. Focusing on the benefits allows practitioners to consider how the thing which confers these benefits (whether a protected woodland, or open fields which might accommodate a new settlement) could be managed and/or planned differently to yield the benefits in similar or different ways, sometimes in bigger quantities but never in lesser quantities.

25. The Capital approach has been tested in over 15 trial examples relating to development plan policy, new development schemes, and management plans for the multi-use of land. The practitioners have found that it adds value to processes such as Environmental Impact Assessment and sustainability appraisal. Most experience has focused on the benefits of environmental assets, but work is now taking place on the application to social and to economic assets, following the principles in paragraphs 26 and 27 below.

The Capital approach and social assets
26. Social assets can by analogy be defined as the stock of social assets which produce benefits for human wellbeing. A widely accepted view breaks 'social capital' down into:

-  trust
-  norms
-  reciprocity
-  networks and connections.

27. To illustrate, a village shop or post office might provide a focus for a wide range of people to meet, chat and make arrangements with each other. This might build links between people who might not otherwise get to know each other (networks and connections), provide an informal, unselfconscious way for people to exchange little favours and errands (reciprocity) and as a result the habit and expectation of neighbours helping each other (norms - that is, shared standards of behaviour) and their readiness to trust each other to do so (trust) are maintained over time.

Public participation, community planning, and the environment
28. The Countryside Agency believes that the Government's proposals for community planning have real potential to improve the quality of decisions and outcomes for the development process. Progressive participation processes will begin with the needs and opportunities of a locality and its stakeholders. The participation process should allow stakeholders to work together to shape and to influence change and development. The Countryside Agency sponsored Village Design Statements provide such a mechanism. VDSs are produced by local people with the help of a facilitator. This involves meetings and surveys to identify the features and characteristics which define the locality. These are recorded in the VDS and developers are asked to reflect these features and characteristics in proposed developments. The process involves input from the local planning authority, which is asked to adopt the VDS as Supplementary Planning Guidance.

Linking the planning system to environmental resource use
29. The planning system has few powers and mechanisms to influence the use and management of environmental resources such as soils, water and air quality. This means for example, that the system cannot directly steer new development in relation to potential use of water resources. Rather than await wholesale changes to the planning system to account for this, the Countryside Agency recommends the use of a widely owned sustainability appraisal for each development plan. This would involve all relevant public bodies and utilities working with the local planning authority to devise a sustainability appraisal. The appraisal would identify responsibilities and actions required of each participating body to ensure the wise management of environmental resources as the development plan was implemented.

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