Royal Commission on Environmental Pollution

The Chartered Institution of Water and Environmental Management (CIWEM) is the leading professional and qualifying body for those who are responsible for the stewardship of environmental assets. The Institution provides independent comment, within a multi-disciplinary framework, on the wide range of issues related to environmental management.

CIWEM welcomes this study by the Royal Commission on Environmental Pollution, involving a broader interpretation of its remit to include the wider social and political dimensions of environmental issues. We have set out our comments in relation to the main subject headings in the Invitation to Submit Evidence.

1.     Environmental sustainability
Many of the issues involved could be better addressed if common, regime specific definitions of sustainability were agreed, together with objectives and targets.

(a)   As the Commission is fully aware, numerous definitions of the term 'sustainable development' are in use. In CIWEM's Judgement, sustainable development must have regard not merely to protection of the environment but also to the equitable treatment of all human beings. The latter may in some circumstances (e.g. developing countries) entail the use of resources to raise the standard of living of disadvantaged groups, in a manner that has a harmful impact upon the environment.

(b)   Given the need to recognise the demands of equity, CIWEM holds that environmental objectives must always be balanced against other issues.

(d)   Government targets for new housing place pressure on local planning authorities to approve non-sustainable development in river flood plains, when the availability of greenfield sites is limited and / or brownfield sites are costly to remediate.

Development in the floodplain and associated infrastructure needs, such as roads and services, can increase flood risk and adversely affect the natural regime of rivers. This issue is addressed in the Bye Report on the 1998 Easter Floods and the draft revision of DETR's Planning Policy Guidance No 25 Development in Flood Plains, which establishes a presumption against development.

(e)   Government housing targets perpetuate the 'predict and provide' approach. Local Environment Agency Plans (LEAPs), which deal with rivers and their catchments, are based on the 'plan, monitor and manage' principle.

(f)   The cumulative impact of developments is seldom taken into account in so far that development applications are generally dealt with in piecemeal fashion. The natural regime of rivers is cumulatively affected by way of:

-	additional surface water run-off, which increases pollution levels and flood risk, the latter necessitating capital expenditure on often non-sustainable flood alleviation schemes;
-	increased demand for potable water, requiring abstraction from rivers and aquifers, which depletes low flows and damages the ecology, and
-	greater volumes of effluent discharged from sewage treatment works.

Ignorance is also a problem, with many of those involved in related planning regimes lacking knowledge of river catchment issues and planning. Cross-regime education and liaison are essential.

(h)   Whilst environmental planning needs to be a driver, limiting the extent of damage from unavoidable climate change, its effectiveness will be muted unless all relevant planning regimes, regulatory controls, government PR, education etc are integrated and focused.

(i)   In the light of limited knowledge of sustainability, global warming, pollution effects and other matters, it would be advisable to adopt the precautionary principle with permitted uses by applying time limits, where appropriate.

2.     Boundaries
(a)   Environmental processes are not necessarily related to geographical areas and any relationship may change with time. It would therefore be impractical to match administrative areas with processes. The solution is for development plans, such as LEAPs for river catchments, to be subject to extensive consultation and approval by the authorities responsible for all associated planning regimes.

(c)   Yes, CIWEM considers that the land use planning system should be responsible for helping to deliver policy targets in other areas such as transport, energy, etc. Integration of planning regimes and other controls is essential to this end.

(d)   It appears that many organisations have inadequate procedures for keeping GIS systems up to date. For instance, one of the Institution's members was recently shown the GIS based sewer maps of a major UK water company in which the presence of a pumping station was recorded, in spite of the fact that the company had organised the decommissioning of the equipment and installation of new sewers approximately 5 years ago. The company's manual records were, however, correct.

  Despite this, the Institution believes that GIS will aid the integration of planning regimes by allowing the transfer of spatially related information between the relevant authorities.

(e)   River regimes are affected by the lack of control of certain activities, examples being:

-	residual nitrates and chemicals from agricultural fertiliser, herbicide and insecticide applications lower water quality, encourage algal growth and damage the ecology;
-	aforestation and deforestation alter catchment run-off and river flows, and
-	alien invasive flora, such as floating pennywort, legitimately sold in aquatic garden centres, find their way into rivers and water space with often calamitous effects.

3.     Integration or coordination?
(h)   CIWEM has considerable reservations regarding a "betterment tax", whatever its feasibility and desirability from an environmental perspective for practical reasons, as its operation would entail increased bureaucracy, and would be even more subject to evasion than income tax, VAT and excise duty.

4.     Subsidiarity and democracy
(b)   The best way to reflect the range of public opinion, whilst maintaining an appropriate procedural timetable, would be to inform the public via the media and invite responses from the public, whilst also contacting their representatives at the various levels of government involved.

There are occasions when local opinion, sometimes influenced by external organisations and pressure groups, responds to a proposal by rejecting it out of hand, simply because it involves change. Such irrational invoking of the precautionary principle should be overridden in the broader public interest, but only after local opinion has been given the opportunity, though appropriate channels and meetings, to articulate its objections, however irrational, and to hear the case for the proposal involved.

5.     Assessment approaches
Greater emphasis should be placed on the development of techniques for costing environmental parameters for use in benefit-cost analysis. Where this proves difficult, the practice used in the Republic of Ireland, of equating the value of intangible benefits to those of tangible benefits should be adopted.

We hope that you will find these comments to be of use. Should you wish us to clarify or expand upon any of the comments we have submitted, please do not hesitate to contact us.

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