Royal Commission on Environmental Pollution

I refer to your previous correspondence on the above study and now provide the following comments in response. This does not address each question but gives a general view of those areas which are central to achieving sustainable development.

The core issue that requires to be addressed is the need to develop an integrated approach to those areas which are considered to be the main elements of environmental planning.

1.   Environmental Sustainability

a.   There is currently not a common understanding of the concept of environmental sustainability and while this can in part be remedied through statutory mechanisms, there also requires to be a sustained programme of awareness raising and education. This should develop a greater knowledge of the longer term implications of not including environmental components along with economic and social components.

b.   If environmental issues are to be successfully integrated with environmental and social issues there must be a commitment to achieving a balance. There will however be circumstances where environmental objectives are imperative. This can only be determined if appropriate status is given to these objectives in both national and local policy and if necessary incorporated within legislation.

c.   there must be a strong commitment to the principles of the polluter pays supported be a clear intention to take appropriate action where environmental damage is caused. Currently the environment has a low local political profile and is regarded as low priority particularly in relation to social issues. While appreciating that it is difficult to quantify landscape and amenity it is necessary to put a value, albeit subjective, on these areas to enable them to be properly considered in conjunction with those areas that can be measured.

d.   Land use planning can only contribute successfully to environmental sustainability when there is a clear requirement and commitment for this to be achieved. The plan-led system will contribute to this but it must be supported not only throughout the process but by all stakeholders involved in it.

e.   In practice planning regimes still tend to focus on predict and provide.

f.   There is a move for environmental planning to take into account the cumulative impacts of developments. The importance of this is not yet however fully addressed in all environmental policy areas.

g.   effective environmental planning is hindered not only by a lack of resources, but by a lack of and integrated approach. There are a number of organisations with responsibilities in relation to this.

2.   Boundaries.

a.    Where administrative areas exist there is a need for voluntary partnership working in relation to environmental planning.

b.   different plans being produced can only lead to confusion particularly for the public.

c.   the land use planning system should be central to delivering policy targets in other areas. This is already happening in relation to transport and nature conservation.

d.   GIS can contribute to environmental planning by providing a co-ordinated data base.

e.   there are benefits in bringing activities such as agriculture and forestry within the control of land-use planning. This would however require to be adequately resourced. It would enable the more effective delivery of a range of environmental objectives including proposed actions through Local Biodiversity Action Plans would provide more direct control over areas such as landscape and amenity.

3.   Integration or co-ordination

a.     There are a number of grey areas where there is not a clear responsibility this requires to be resolved and complimented by a requirement for an integrated approach to environmental planning.

d.   if the land use planning process is sped up it will inevitably result in reducing the effectiveness of environ mental protection, particularly where a number of agencies are involved in the process. There already is a tendency to sacrifice quality in the need to meet tighter deadlines.

4.   Subsidiarity and democracy

a.     While there is greater commitment to environmental planning at the national and international level this is not yet being successfully filtered down to the local level. For this to succeed there needs to be a local political commitment to it.

5.   Assessment approaches

There requires to be a clear commitment to ensuring that the range of environmental issues are fully considered throughout the process.

Should you require to discuss any aspect of this response further please contact Jennifer Gough on the above extension.

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