Royal Commission on Environmental Pollution

Introduction
1.       The Ulster Farmers' Union welcomes the invitation from the Royal Commission on Environmental Pollution to respond to the issues raised on Environmental Planning.

2.       The membership of the UFU stands at approximately 13,000 farmers, hence we represent 50,000 farmers and their families in Northern Ireland. The Union therefore represents the views and opinions of a considerable proportion of the rural population in N Ireland.

3.       The aspects which are addressed within the scope of this study of environmental planning are of concern to farmers and their businesses, in particular the regimes relating to pollution control, agri-environment and biodiversity.

4.       The UFU is therefore in a strong position to respond to the issues identified by the Royal Commission in its study of environmental planning.

Environmental Sustainability
5.       Within any aspect of environmental planning, recognition must be made of the need to provide adequate payment for farmers supplying social goods, rather than the general expectation by society that farmers will do so out of their own finances. The issue of agri-environment and protection of biodiversity must be treated as another aspect of agricultural business and as such society must be made aware of the need to pay for these 'outputs' from the agricultural sector.

6.       Appropriate standards do need to be set for some environmental objectives, but they must apply to all industries and sectors. Blame must not simply be assumed to rest with a particular industry. Any decisions made to devise standards, and to which industries they are to be directed, must be made on sound, complete and accurate analysis of all the factors.

7.       Any regulatory approaches to be made in order to protect the environment will be considerably more effective if information and incentives are provided along with the regulation. The legislative type of approach has a certain degree of success, but if the approach is taken is based on incentive and regulation, a much more positive attitude will be generated by all parties involved. The long-term effects for the environment are considerably greater as a consequence.

8.       Land use planning must achieve a better balance between environmental sustainability and economic development. However, while planning decisions must take all factors into account, proposals to improve or increase economic development, especially in rural areas must not be hampered or delayed in receiving planning permission. The Prime Minister gave his assurance that planning guidance would be revised to give clear encouragement to diversification.

9.       The current arrangements for environmental planning should, but currently do not, sufficiently take into account the cumulative impacts of developments. The system currently puts too much power to make decisions into the hands of individual local planners. To add to this problem, the procedures in place are too complex and involved to allow any institution to cope adequately with the demands placed upon them.

10.       We would suggest a 'layered' approach, where decisions are taken from an overall level through to the individual local planner, to facilitate effective environmental planning. Effectively this could provide a basis for interim planning decisions for certain circumstances (to be confirmed at a later date) and fast tracking where little controversy may be involved.

11.       Planning will no doubt have a part to play in limiting the extent of damage from unavoidable climate change. It will also have a part in reducing the amount of climate change as a result of reducing the level of outputs of greenhouse gases. Decisions taken within planning systems will, in the near future, have to consider both the impacts of climate change and the possible options that could be employed to reduce this impact within the theme of environmental sustainability.

12.       Placing time limitations on permitted uses to achieve environmental sustainability could have positive or detrimental effects on the objectives set down. Pressure would undoubtedly be placed on the system and this would have the effect of pushing the processes forward. The Union supports any measure that would make the planning process move more quickly. However, time limitations may also place pressures on the processes such that the system struggles or cracks. That is when costly mistakes could be made.

13.       Many of the factors that would lead to a sustainable environment, and a vibrant rural economy, have been addressed in Agenda 21. Chapter 14 includes a series of measures, which form the core of SARD (Sustainable Agriculture and Rural Development), some of these measures also relate to environmental sustainability. The Royal Commission should take account of these measures in its review of environmental planning.

Boundaries
14.       Administrative boundaries must not be allowed to impede suitable environmentally sustainable planning. Boundaries could potentially be a particular problem where a feature, e.g. a river catchment area, runs through more than one administrative area. In such instances all the administrative areas involved must work together to develop an environmentally sustainable plan, which deals with all the issues affecting the feature.

15.       If certain processes in the planning system are employed by one administrative area and not by other, ways to address this potential problem, that will not delay the planning process, must be found. It may be feasible to have a common approach, developed by the division dealing with planning policy, for implementation when instances such as these occur. Macro policy must be developed to allow enough flexibility so that for each instance the plan could to be tailored to suit the requirements of the particular feature and geographical area.

16.       The land use planning system will have a role to play in helping to deliver other policy targets, but it must be recognised that it will serve in conjunction with other policy systems and will not necessarily have the lead role.

17.       When any decisions are taken, in any situation, they must be made on the basis of sound and accurate information. The use of GIS is one way of using the technology now available to us to more accurately record and utilise information for environmental planning.

18.       However, before any work begins on collating data, evaluations must be carried out to determine if the collection and recording of the required data is financially viable, in terms of the expected information output. Maintaining the database will be an essential element of working such a system and as more information is collated and stored, care will have to be taken to ensure that the GIS is of use rather than another administrative burden.

19.       Agriculture and Forestry are already subjected to a huge number of controls and regulations, placed on them both by EU and UK policy. Another level of control over their business activity will only further serve to stifle productivity and enterprise.

20.       Under the Rural Development Regulation all agricultural businesses will have to be even more environmentally aware than they have been previously. This should be achieved through the use of both incentive and regulation.

21.       As we have commented earlier, a regulatory approach alone is not the most successful way of achieving results. More effective is the use of incentives in conjunction with regulations, where deemed necessary, and only on the basis of sound scientific evidence.

Integration or co-ordination?
22.       Present arrangements for planning are too slow. The processes involved must be streamlined to allow the whole process to be as efficient and cost-effective as possible, while also meeting the aims and objectives of the planning systems.

23.       Both as a country and within the agricultural industry, we are already subject to a plethora of taxes and duties above and beyond income tax. Due to the nature of agriculture revolving within rural areas, living and business costs are higher. For example, the increased level of duty on fuel has had a greater impact on rural areas, as vehicles are necessary items for everyday business as well as for social activity. As no alternative option is available to the use of a personal vehicle, transport costs for those in rural areas are higher than in urban areas.

24.       The agricultural industry cannot support further taxes placed on it for work that is already being carried out.

Subsidiarity and democracy
25.       Obviously the planning service must be able to serve the interests of the public it works for. There are however, occasions where the public is not in a position to understand what the community needs as opposed to what it wants. The planning service must therefore be able to stand back from planning proposals, objectively consider all factors and assessments of the proposals, and possible outcomes, and finally make an informed judgement for the good of the public.

26.       In the interests of developing the rural economy, economic generation must be one of the overriding themes in the consideration of any proposal for business development in rural areas. Business must be allowed, and indeed be encouraged, to start up, develop and expand in rural areas. The planning service must ensure that rural areas do not become simply dormitory areas for urban workers who do not contribute to the social infrastructure and economy of the rural community.

27.       In order for a rural community to survive, and flourish, every possible avenue to sustain it must be explored and used to its' full potential by the planning service.

Assessment approaches
28.       This subject in N. Ireland is currently at the centre of a major debate involving the entire community. The Department of Environment has published a range of documents under the central theme of 'Shaping our Future'. This is essentially a draft strategy for regional development, which takes full account of the effects from spatial, social and economic viewpoints. As such it is a revolutionary approach which provides a basis for a much more comprehensive assessment.

29.       Following a period of consultation, there was a then process of an 'Examination in Public'. This was also a revolutionary instrument that much enriched the debate.

30.       The UFU believes that this will, for the first time, provide a much more radical basis for widely based and comprehensive assessment in the future.

Conclusions
31.       The Union would wish to ask the Royal Commission to note that in practical terms the whole matter of Environmental Planning is tackled in N Ireland rather differently than in the rest of the UK. Planning is a matter for the Department of the Environment for N Ireland (formally) and more recently the Department for Regional Development to action. Local authority democracy has only an indirect effect on the planning process.

32.       As such the system in the Province may warrant closer attention on the part of the Royal Commission.

33.       Nevertheless, the Union recognises that this study in concerned with principles and approaches. The Union would welcome further involvement, should further clarification of its views be required.

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