Royal Commission on Environmental Pollution

Main evidence
        Annex 1
        Annex 2

We wish to respond to some of the points raised in the RCEP Annex A, and we have used the numbering system in the RCEP paper.

1.       Environmental Sustainability

1b       Environmental objectives cannot always be balanced against other issues. There are environmental limits (defined in terms of critical environmental capital for example) which must be recognised in decision making. If environmental limits are ignored in decisions or always "balanced" against other considerations, long-term social and economic benefits are unlikely.

1e       The book chapter (Stead, 2000 and attached) illustrates how far the UK planning system has come from "predict and provide" to "plan, monitor and manage". There is still a long way to go, but demand management is now at the centre of much action in a range of environmental planning sectors.

1f       Significant environmental impacts may be the result of a combination of existing stresses on the environment, together with the accumulation of individual minor impacts over time, rather than the direct effect of a single development. The planning system needs to be able to deal with these cumulative environmental impacts. The problem of cumulative impacts and impact interactions are recognised in the 1985 European Commission Directive 85/337 on Environmental Impact Assessment (which by 1988 made the assessment of the effects of certain public and private projects on the environment compulsory). Whilst the analysis of environmental impacts of projects has now been carried out for more than a decade, the assessment of cumulative effects has often been ignored due to difficulties in measurement, assessment and prediction.

Despite these difficulties, cumulative effects assessment (CEA) is likely to be the next step in environmental assessment (Pauli, 1988). CEA will need to address local and/or regional cumulative effects and also take a global perspective. There is as yet little experience of CEA or any agreed methods, but there is a growing literature on CEA at the regional level (e.g. Cocklin, Parker and Hay, 1992; Rees, 1995). There is considerable support for the view that CEA can only be effectively undertaken at the regional level since CEA relates more to strategic environmental management and strategic environmental assessment (SEA), rather than to the management of individual projects and environmental impact assessment (EIA).

Further studies and research is needed if current technical knowledge and understanding on CEA is to be developed. There may also be the need for institutional changes to respond to this issue (particularly at the regional level). Despite problems of implementation, the planning system must address CEA at both the project and strategic levels. Placing project level CEA within a wider regional planning CEA framework provides an opportunity to foster more comprehensive environmental management. The long term outlook is a two tier implementation of environmental assessment. Project level CEA will serve to assess cumulative impacts in relation to multiple large projects, whilst strategic CEA will address the cumulative impacts associated with a larger number of small projects whose individual impacts may not be large and warrant EIA, but whose cumulative effects are significant.

1h       Planning systems can limit the extent of damage from long term risks such as climate change or persistent waste by using least regrets strategies. These strategies need to minimise the risk of long term problems through demand management (such as waste management, transport demand management, energy demand management). Policy scenarios may help to identify least regrets strategies.

3.       Integration or Coordination?

3f       Debates about the integration of land use planning and transport planning have been ongoing for at least 40 years, but since 1994 real progress is beginning to take place. The initial catalyst was the publication of PPG13 (DoT/DoE, 1994; now under revision - DETR, 1999), Good Practice Guides (DoE, 1995; DETR, 1998), other related PPGs (e.g. PPG3 and PPG6), and the new requirements placed on the RDAs. The new proposals in revised PPG13 can be summarised as follows (Table 1) and if implemented effectively in full will lead to much greater integration between land use and transport.

Table 1:       New Requirements from PPG13 for Local Authorities and their Local Transport Plans

The problem here is that the principles are not normally matched in practice for a variety of reasons (e.g. education, training, local politics and organisational/ institutional structures). There are also coordination/integration problems between agencies, as they may be pursuing different objectives, or trying to meet the requirements of different stakeholders, or be in competition with other agencies. The key here is strong implementation which involves raising the awareness and support from all stakeholders. There is now a clear logic established through the sequential approach both as it relates to development and as it relates to modes of transport.

However, the rate of change is still much slower than that needed if environmental planing is to be placed at the top of the agenda and if commitments to global targets are to be achieved. Two issues seem to be at the heart of the debate:

1.       The problem must be tackled at source - decisions relating to the location of new development (e.g. housing) influences the demand for travel in the future. Part of the assessment of all new (major) development must be a sustainability analysis that covers the changes in travel (by mode), the use of energy and the pollution implications. In addition, alternatives should cover the possibilities of linking development with the provision of services and facilities (both transport and non transport) so that the opportunities for local travel (by green modes) is facilitated. This requires more comprehensive analysis, including GIS based models such as ESTEEM (Titheridge et al., 2000 - copy enclosed). It also requires new forms of presentation and communication to and between all actors involved in the development process. At present the separation hinders true integration of intentions - we must move away from sector based analysis towards much more holistic planning analysis.

2.       A much clearer understanding of the barriers to successful implementation of decisions taken on environmental planning needs to be established. Recent research (Banister and Marshall, 2000) has investigated these difficulties and identified seven different situations where outcomes do not coincide with intentions, as it relates to land use and transport - this is particularly important when environmental issues are being debated.

• Non-complementary policies : cases where measures have been unsuccessful because of a lack of complementary policies or due to the presence of directly conflicting policies.
• Direct incentives to travel more: cases in which a particular measure inherently encourages more travel of some sort. For example, subsidies may be devised to increase travel by particular modes.
• Improving system efficiency: cases where travel reduction is activated to some extent, but the very act of removing traffic or journeys frees up more roadspace or vehicles to be used by others. Thus, the initial travel reduction feeds back to generate a net increase in travel.
• Contradictory outcomes: cases where more travel was generated despite the intention of the measure to reduce travel.
• Change without improvement: cases where measures have achieved some change, but where no improvement in terms of travel reduction has been achieved. For example, mode switching from bicycle to walking, destination switching that does not reduce trip distance.
• No evidence or negligible impact: cases where the travel reduction impact of a measure is negligible, or the evidence is weak or inconclusive.
• Non-acceptance or no uptake by users : cases where the measures have not been used by the public.

5.       Assessment Approaches

5a and 5b see responses to 1f (above).

References

Banister, D and Marshall, S (2000) Encouraging Travel Alternatives: Good Practice in Reducing Travel, London : The Stationery Office.

Cocklin, C, Parker, S and Hay, J (1992) Notes on cumulative environmental change 1: Concepts and issues, Journal of Environmental Management 35(1), pp 31-49.

Department of the Environment (1995) PPG13 - A Guide to Better Practice, London : HMSO.

Department of the Environment and Department of Transport (1994) Transport (Planning Policy Guidance Note 13), London : HMSO, March.

Department of the Environment, Transport and the Regions (1998) A New Deal for Transport: Better for Everyone, The Government's White Paper on the Future of Transport, London : The Stationary Office, June.

Department of the Environment, Transport and the Regions (1999) Revision of Planning Policy Guidance Note (PPG13) Transport, Public Consultation Draft, London : DETR, October.

Pauli, S (1998) Beyond standard assessment tests, Town and Country Planning 67(2), pp 77-78.

Rees, WE (1995) Cumulative environmental assessment and global change, Environmental Impact Assessment Review 15(4), pp 295-309.

Stead, D (2000) Unsustainable settlements, in Barton, H (ed) Sustainable Communities - The Potential for Eco-Neighbourhoods, London : Earthscan, pp 29-45.

Titheridge, H , Hall, S and Banister, D (2000) assessing the sustainability of urban development policies, in Williams, K, Burton, E and Jenks, M (eds) Achieving Sustainable Urban Form, London : E& FN Spon, pp149-159.

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