Royal Commission on Environmental Pollution

This response has been prepared by a research team at the Institute of City and Region Studies, Department of Geography, University of Hull which has recently begun work on a project funded by the ESRC (Economic and Social Research Council) titled "Changes in regional planning: a new opportunity for sustainable development". The study will investigate whether new arrangements for regional planning in England assist the planning system to become more effective in addressing the agenda of sustainable development. The research project began in January 2000 and will continue until December 2002.

The team is also receiving funding from the English Department of Environment Transport and the Regions (DETR) to extend the study to explore the effectiveness of sustainability appraisal and the use of indicators and targets to monitor progress towards sustainable development in the English regions.

1.    Environmental sustainability
1a. The effect of pursuing a broad approach to sustainable development on environmental protection is a complex one. Some local authorities, notably county councils in the south east of England, have in fact closely equated sustainable development with the need to protect the environment, and have been criticised for over looking the social and economic aspects of the concept. West Sussex County Council is a case in point with its strong approach towards environmental capacity (see attached paper This is available on request from Royal Commission Secretariat). The Serplan Strategy for the south east was also criticised at the Public Examination last year for placing too much attention on protecting green belt (which often has limited intrinsic environmental value) to the detriment of the economy and the need for affordable housing.

On the other hand it is difficult to see how the government's current definition of sustainable development, with the objective of maintaining high and stable levels of economic growth and employment, can be reconciled with environmental sustainability. In our research into sustainable development in Regional Planning Guidance we are finding that this objective is being used to promote economic development and competitiveness as ends in themselves. In peripheral regions such as the north east, economic development is seen by many policy makers as the primary objective of regional planning, despite a rhetorical support for the principles of sustainable development. There is relatively little attempt in Regional Planning Guidance documents (outside the south east and south west) to make the process of economic development itself more environmentally sustainable by greater efficiency, better environmental management, support for local economic initiatives etc.

1b. Whilst sustainable development requires a balance to be struck between economic social and environmental objectives, it must also be acknowledged that in theory there has to be an environmental bottom-line. Great difficulties have though been encountered in trying to define where the threshold of this bottom line lies and in the past it has proved to be a moving target. Michael Jacob's (1997) report to CPRE, Making Sense of Environmental Capacity, discusses the problems in trying to define environmental limits much more comprehensively than is possible here.

Other approaches have sought to distinguish between critical elements of environmental capital and those that can be traded for gains in other areas. Some of the difficulties in making such distinctions have been demonstrated in the RPG process, however. For example, references to 'critical' and 'tradable' components of natural capital were removed from later versions of the Yorkshire and Humber RPG, following an interim sustainability appraisal and consultation exercise. The current draft acknowledges the need to define critical natural capital in the region, to establish baselines for assessing this and states that a sustainability appraisal of development plans should make the terms of any trade-offs explicit whilst seeking to increase the total value of human and natural assets. The role of RPG should be to assist local areas in defining what is critical and what may be tradable, and ensuring some consistency in the way that this is interpreted across the region so that local development plans are not in conflict and policies are defendable when challenged by developers.

1e. There appears to be some confusion over what is meant by "plan monitor and manage", differences of opinion about whether it represents a better approach for environmental protection, and uncertainty over how it should be applied. In its comments on the revised PPG3 and draft modifications to Regional Planning Guidance in the south east, CPRE warmly welcomed this new approach which "will bring enormous relief to the countryside and help regenerate our towns" (CPRE press release 7th March 2000). Others though argue that it is not in the long-term interest of the environment in the south east to plan for fewer houses than predicted as this will lead to planning by appeal and incremental development. One of the interviewees in our research project, a member of the Town and Country Planning Association, expressed strong concern about the short term nature of the "plan monitor and manage" approach and the detrimental effect it would have on proper strategic planning.

In draft RPG for the north east of England, the Association of North East Councils is planning for a higher number of houses than is needed according to predictions, because its strategy is based on reversing an expected loss of population through outward migration. Whilst this approach could be described as "plan monitor and manage", it is being criticised by CPRE as being inconsistent with this approach because of the negative implications for green belt and countryside. And it is true that if similar aspirations are repeated across the peripheral regions (which largely seems to be the case in draft RPG documents) we may actually be planning for more housing overall than is predicted to be needed in national forecasts.

So whilst perhaps a policy of plan monitor and manage might result in environmental gains in areas of pressure for development such as the south east (and this is disputed by TCPA and others), it could result in losses elsewhere with land being identified for development in advance of predicted need. A similar situation applies to the provision of land for economic development, where the case is being made in advance of need for a number inward investment sites (often on green field land) to enable regions in the north and midlands to be ahead of the game in attracting new jobs (these sentiments have emerged in interviews with policy makers in the regions).

Linked to this (PMM) concept are moves towards a 'sequential approach' for guiding the location of housing (as well as retail) development. Draft RPG in the East Midlands, for example, contains policies and criteria intended to ensure that proposals made in development plans about development locations comply with sustainable development, as defined in the RPG. The RPG requires plans to prioritise development on sites in a strict order of preference, starting with previously used land in towns or cities and ending in locations outside towns and cities well served by public transport. Representations to the public examination of the RPG suggest that this approach is seen as a potentially powerful planning tool for sustainable development, ensuring that the most attractive green-field sites are not 'creamed off' by developers and providing a rigorous 'test' against which sites or development decisions can be judged for sustainability. It may also address some of the concerns of the plan, monitor manage regime, in the sense that a 'sequential test' can be used to counteract any of the more short term or incremental attributes arising out of PMM.

3.    Integration or co-ordination
Early interviews associated with our research project suggest that there is considerable support for more integrated planning at the regional scale (such a plan is in fact being prepared in the east midlands). The government has recognised the need for better co-ordination of regional planning with its proposal for Regional Frameworks for Sustainable Development. These frameworks are intended to provide a sustainable vision for each region and bring together different aspects of regional planning policy. However, it is difficult to see how effective they can be in doing this as they will have few teeth (they are not statutory plans) and they will not be completed until after the most important policy decisions have already been taken in RPG and Regional Economic Strategies. There is also an inherent problem in English regional planning due to the fact that regional assemblies consist of appointees whose loyalties often lie with their own localities, rather than with the region as a whole. There is a feeling amongst many of our interviewees that elected regional government is a prerequisite for effective and integrated regional planning.

5.    Subsidiarity and democracy
5d. Responses to our research to date suggest that more formal spatial planning at the national level, and elected regional government are widely thought to be necessary if we are to have effective and accountable regional planning. Initial interviews with actors in several regions point to the tendency for a 'regional planning view' to be undermined by the priorities of local politics. Although some of these problems may be addressed in regions with a dedicated regional planning team, several regions rely on locally based planners to develop the work on RPG and these individuals can face conflicting priorities in terms of their professional allegiance and individual work loads.

6.    Assessment approaches
We are working with DETR to assess the effectiveness of sustainability appraisal at the regional level and also its use in monitoring progress towards sustainable development in the English regions. This work though has only just begun, and it will be some time before any substantial results are available. The study will explore different roles for sustainability appraisal, i.e. it can ensure that policies are internally consistent and address sustainable development objectives in a technical sense, and also raise the profile of sustainability issues in discussion and debate to help generate consensus before a public examination. The latter role, in particular, relies on the need for SA to carried out early in the RPG process and to consider various potential policy options as well as actual draft proposals. For example, although Yorkshire and Humber RPG helps to provide an effective technical appraisal of policy proposals, it did not assist planners to compare relative merits of alternative proposals as these were not developed in any detail. RPG had in fact reached an advanced stage in all but two regions before the draft best practice guidance on sustainability appraisal was available.

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