Royal Commission on Environmental Pollution

Please find the views of Warwickshire County Councils' Department of Planning, Transport and Economic Strategy on this study. We haven't responded to all the questions listed but did work through the majority!

1)     Environmental sustainability

a)     pursuing sustainable development is likely to have had unfavourable consequences on the environment - one example is the effect on sites of ecological importance in the development of brownfield sites. Another comment made by a colleague is that all development is unsustainable at some level as it requires the use of materials in construction.

We do no think that it is always desirable to remedy this situation.

b)     Most local plans should include a general policy covering environmental objectives, i.e. all new development should meet certain criteria. Included in this could be the criteria that any new development should not be to the detriment of the environment.

c)     New regulations, e.g. taxes on car use, could be introduced but this may have adverse effects on a regions' push towards sustainable development. For example rural areas have a heavy dependence on car use and, 'limiting' their use in this way, would increase the feeling of social exclusion and could ultimately effect the local economy. In addition, introducing new regulations that would have to be monitored at a local level would have an effect on local resources - local authorities are already stretched and would find it difficult to take on additional responsibilities.

d)     No comment

e)     In practice, a fair way. PPG3 sets out further guidance on plan, monitor and manage mechanisms, e.g. identifying new allocations for a 5 year period on Proposals Map rather than identifying allocations for the entire plan period.

f)     No - at the moment they are site specific with each application being considered on its own merit.

g)     The current procedures are complex and are likely to hinder the process - the planning system should be made simpler. There is a lack of resources - simplifying the process may help overcome this.

h)     Environmental factors should be taken into account when buildings are constructed. However the advice given by experts, e.g. on climate change is constantly changing! The planning system could help to avoid future problems by assessing all the possible outcomes of new development but this may be unpopular.

i)     Time limiting uses is problematic unless there are sound planning reasons for doing so. A big issue is the infringement of people's rights.

2)     Boundaries

a)     There are problems but these can generally be overcome by ensuring there are good channels of communication between all parties. We are unsure as to what, if anything, can be done about it.

b)     A big difficulty is when plans cover a different time period hence becoming out of date at different times. Close working relationships do help in overcoming problems.

c)     Yes!

d)     This could be an excellent resource particularly if it includes descriptions, sketches and photographs. It provides instant up to date information. There are cost implications though.

e)     Probably less so than in the past as many organisations, including those that govern activities such as forestry and agriculture, are becoming environmentally aware, i.e introducing their own 'controls'.

3)     Integration or co-ordination?

a)     The unanimous answer to this was yes but we didn't delve into the complexities of a solution.

b)     There is a hierarchy - the Development Plan, which consists of the Structure and Local Plans, is, in a sense, a hierarchical framework.

c)     Better co-ordination is likely to be effective in ensuring an effective and efficient system. We are unable to comment on the system used in New Zealand as we have no knowledge of it.

d)     We think the present arrangements could be improved (although it would take time) and that there can be reconciliation between the planning process and effective environmental protection.

e)     No comment.

f)     Significant progress has been made within this Department but there is still room for improvement - we need to maintain and enhance current awareness of the work of groups within the Department. Difficulties are caused when plans have different time spans, e.g. 15 years for the Structure Plan, 5 years for the Transport Plan.

g)     No comment.

h)     The concept of betterment in planning is, for many, an ideal but politically unlikely.

i)     Yes - the current system is not perfect but allows disagreements to be aired in a fair way even if they are not resolved.

4)     Subsidiarity and democracy

a)     On balance yes but it depends on the extent of the power of one of the groups.

b)     Democratic structures within local government have recently changed as a result of the Local Government Bill which encourages increased open consultation. At the local level however the timeframe in which to comment on planning applications is short - therefore any mechanism which helps environmental interests to be made within this time frame would be beneficial.

c)     Environmental planning should take place at the lowest level whilst retaining a strategic overview.

d)     New RPG arrangements and in the future new Structure Plan arrangements (possibly along the lines of sub - regions rather than Counties) are needed to provide greater coherence between national and local planning regimes.

e)     No comment.

f)     I am advised that a third party right of appeal exists already but not sufficiently tried and tested as yet to ascertain its 'success'.

g)     In planning there has been a move away from the adversarial court room approach to one which is more accessible and inviting for people to participate in. We think this is a move in the right direction and would not wish to advocate a return to a more formal approach.

5)     Assessment approaches

a)     The most appropriate methodology for appraisal of plans would be a strategic environmental assessment. Care needs to be taken that a broad brush approach, often required for such assessments, does not detract from the quality and value of the assessment. It appears that similar parallels to early EIA's can be drawn - they vary in quality, suffer from lack of available data that is of a useable scale and timeliness and are not audited/monitored or reviewed. The SEA methodology itself can be designed to ensure wider implications are considered, even to the extent that environmental sustainability criteria form the basis of the assessment.

b)     Environmental assessments should be considered for all plans and policies. Considering possible environmental consequences for all issues would both raise the profile and understanding of issues and move the plans in an environmental sustainability direction. The assessment needs to be undertaken by people with the relevant experience and understanding of the issues and appraised by at least one independent person.

c)     The value of the increased use of the other assessment tools would be in providing greater knowledge and understanding of the situation. With plans and policies being more liable to be lead by indicators it is becoming increasingly important to ensure that all possible interactions are considered, i.e. an improvement in an indicator may not produce beneficial consequences for other issues. A greater understanding and appreciation of the environmental capacity, environmental capital and environmental footprint would enable a greater understanding of the inter-relations between issues and move towards ensuring the full impact of possible decisions are better understood.

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