Royal Commission on Environmental Pollution

1.       ENVIRONMENTAL SUSTAINABILITY.

a.       The fact that sustainable development should be at the heart of plan making does not so far appear to have resulted in significant changes to the form of development that is taking place. This may partly due to the fact that the development "on the ground" reflects plans that were formulated prior to the increased commitment to the principles that are inherent in the concept of sustainable development.

Nevertheless, most Local Planning Authorities are attempting to redefine their development plans so that they take on board some of the less traditional aspects associated with environmental planning and this will undoubtedly have some positive impact on the protection of the environment. However, some of the key environmental challenges such as climate change are not being addressed sufficiently within the planning system. The issue of climate change is a good example of an issue that requires radical rethinking over the location and form of development. It will, therefore, raise significant questions for land use planning in the coming decades. There are two aspects to the challenges presented by climate change:

1. The need to alter the pattern and form of development to reduce the contribution of greenhouse gases.
   
2. The need to alter the pattern and form of development to adapt to the climatic conditions of the coming decades and centuries.

b.       There are certain environmental imperatives. Despite attempts, such as the use of cost-benefit analysis, to quantify the significance of environmental "capital" to balance its worth against socio-economic factors it will always be a subjective exercise, particularly when it is acknowledged that placing a firm fiscal value on an environmental resource is notoriously difficult.

c.       The regulatory approaches for protecting water and air have generally been successful; although the increase in emissions from traffic will provide a significant challenge for ensuring that air quality does not decline. It is less easy with environmental issues that are less tangible and with those that are more affected by sectors that lie outside regulatory frameworks. For example, the forestry and agricultural industries have dramatically affected landscape and biodiversity.

d.       The plan led system does give the planning system the potential for achieving environmental sustainability. However, this will only be realised if plans contain strategies and policies that give this a priority as opposed to economic or household growth. Broader environmental issues need to be incorporated into development plans and not just traditional land use planning issues, such as landscape. Despite the plan led system there will often be a presumption in favour of development because the overall framework is political and political aspirations still strongly favour economic growth.

e.       It is too early to judge the difference that the plan, monitor and manage approach will make to the planning regime and its ability to address environmental sustainability. In theory this is a better approach because it gives some flexibility in the system. Monitoring the outcome of development and the effectiveness of policies has been a weakness in the system. The need to monitor and make changes to the development plan in the light of the monitoring should help to address this weakness.

f.       Greater and more effective use of environmental appraisal of plans at all levels (regional, structure and local plans) is required to take the cumulative impacts of development into account.

g.       A lack of resources is hindering environmental planning. Financial constraints can limit the ability of a local authority to "buy-in" additional expertise. However, the pressure on time is just as much of a problem. Environmental sustainability requires innovative approaches and these can take time to develop. With ever more demands on local government, the restriction on officers' time is an issue that is difficult to overcome, particularly as there are financial restraints on employing more staff.

h.       These long-term issues have significant implications for environmental planning. The planning system could be a driver for limiting the extent of the damage but this is not an issue that is being given sufficient attention in development plans at present (see response under 1a).

2.       BOUNDARIES.

a.       Whilst the problems associated with planning within administrative areas is acknowledged, it would be difficult to alter this radically. In theory some of the problems associated with this "geographical" approach rather than using environmental processes is addressed through the production of plans by the relevant statutory organisations, such as Local Environmental Action Plans for rivers produced by the Environment Agency. However, these are rather weak at present and their status does need to be enhanced.

b.       The problems that arise where plans are produced for overlapping geographical areas can be political in nature - e.g. different local authorities with different landuse policies for along boundary rivers and roads.

c.       The planning system should be responsible for helping to deliver targets in the other policy areas listed because these are directly related to land use planning. The importance of these issues needs to be enhanced.

d.       GIS is already making a contribution to environmental planning - maps can be plotted with several layers of information, which allows quick and easy identification of environmentally sensitive areas which can then be avoided during development. As computing power and associated technology advances the capabilities of GIS are likely to improve in the long term. Problems associated with GIS systems include cost and copyright difficulties. In addition, information is not generally cross authority and when joint projects are undertaken difficulties may arise where data is stored in different and incompatible formats. This can be addressed to a certain extent by improving GIS systems to accept a wide range of different data types.

e.       The lack of control over activities such as forestry and agriculture does prejudice the achievement of environmental goals. For example, biodiversity targets are unlikely to be met without changes to these sectors.

3.       INTEGRATION OR CO-ORDINATION.

d.       The desire to speed up the land use planning system could improve environmental protection by making development plans more responsive and give them the ability to adjust more quickly to changes in environmental issues and problems. Nevertheless, the desire to speed up the planning system must also reflect broader sustainable development principles of greater community participation in decision making. In addition any attempt to speed up the land use planning process could result in work being rushed and important data missed, for example information that is only apparent on a seasonal basis.

f.       The greater integration of land use planning and transport planning is certainly long overdue. At present the new regime of greater integration is at an early stage and it is difficult to comment on whether the systems are being better integrated. This is another issue that Local Planning Authorities are finding challenging. The need to encourage alternative forms of transport is not widely supported by the public. This highlights the tensions between national goals and the difficulty of implementation at a local level, where such decisions may be unpopular and, therefore, may not be implemented by local politicians.

4.       SUBSIDIARITY AND DEMOCRACY

a.       The current balance between elected leadership, expert assessment and public participation is appropriate for the time being for both planning applications and allocations. However, public awareness continues to grow, and this coupled with the fact that the planning system needs to reflect the broader sustainable development principle of greater community participation, the balance is likely to change in the future. Work needs to be undertaken to incorporate the need for greater public participation into the planning process.

5.       ASSESSMENT APPROACHES.

a.       "The Environmental Capacity in West Sussex" is a study which has identified a broad spectrum of environmental pressures and issues which affect sustainability. This study is useful because having been carried out at a county level and can be incorporated into plans which evolve at a more local scale. More examples of best practice are required for carrying out "sustainability" appraisals of plans as opposed to a narrower environmental appraisal where the methodology is more established. Generally the appraisal of individual cases does not provide sufficient information about their implications for wider environmental goals. If these are referred to the information is often so broad that it is not very meaningful. In fairness this is sometimes because it is difficult to predict the impact that individual cases will have on wider environmental goals, such as the effect on climate change.

b.       Whilst environmental appraisal adds another operation to plan making it can be a useful tool as its strength lies in highlighting the environmental consequences of plans. It should form an integral part of plan making and as expertise spreads it should not hinder the efficient operation of environmental planning systems. Environmental appraisal should be widely used. The level of detail has to be appropriate to the plan being developed, and will largely dictated by the nature of the plan. For example, if the plan is strategic it will only be possible to give broad indications of the potential environmental impacts of the plan. Although there are disadvantages with those producing the plan carrying out the appraisal, the advantage is that it can be integrated into the plan-making process and therefore, influence decisions made over the content of the plan as it evolves rather than being "tagged on" at the end of the process. If the appraisal is subject to public consultation others will then be given the opportunity to judge the quality of the appraisal. A requirement for more appraisals to be subject to public scrutiny is, therefore, crucial.

c.       There is certainly increased value from sustainability appraisals. As mentioned previously more work is needed on effective methodologies but this can have greater credibility than an environmental appraisal and have wider use as a decision making tool. This is particularly true for Local Government, which now has a duty to improve the social, economic and environmental wellbeing of its community.

d.       More information on this aspect of the assessment process, with a wider distribution to those responsible for negotiating mitigation measures would be useful. For this to be successful there needs to be a commitment for the collection of baseline and monitoring data. The Plan monitor and manage system may help with this and would ensure that mitigation measures are as effective as possible.

e.       The knowledge base within Local Authorities to carry out environmental assessment within the planning framework is not enormous. This is partly due to the fact that incorporation of the various environmental assessment and appraisal techniques into planning is still developing. However, where the need for specific environmental assessment work arises knowledge can be bought in in the form of consultants, or if necessary by employing staff "in-house". In both cases however, financial constraints can severely limit this ability.

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