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Consultation on a new Planning Policy Statement: Planning for a Natural and Healthy Environment (DCLG 2010)

Submission from ALGAO:England/Planning & Legislation Committee

Questions and response form

1. Do you support the consolidation and streamlining of policies on the natural environment, green infrastructure, open space, sport, recreation and play into a single planning policy statement?

Some consolidation of policies makes sense, and certainly an integrated approach to planning for a natural environment is essential, but could and should take in, or refer to, wider planning issues covered by other PPSs, including PPS5 Planning for the Historic Environment. This would enable `joined-up thinking’ and recognize the complicated and interconnected nature of our entire environment and the management of change within it.

Significant alterations to the natural environment are being proposed, but under other schemes apparently outside the planning process or scope of this PPS, such as Catchment Sensitive Farming - over 40 catchments nationwide identified for programmes of subsoiling, with little, if any, consultation with County Archaeology Advisory Services. These have significant potential to alter the natural environment and damage below ground archaeology. The agencies involved are those most likely to be engaged in delivering a natural and healthy environment, the Environment Agency working closely with Natural England, AONB's and other countryside 'protection' agencies to deliver CSF.

2. Does the proposed PPS address sufficiently all the issues that planners and others face in relation to protecting the natural environment, delivering green infrastructure and other forms of open and green spaces, and land and facilities for sport, recreation and play?

We feel that the tone of this Policy Statement would be best set by using the definition of the landscape in the European Landscape Convention at the start of the statement rather than confined to Annex A; and to acknowledge that our countryside is a product of mankind’s actions on the landscape through thousands of years of settlement, farming, woodland management, industry and abandonment.
We view that the evidence base for plan-making (Policy NE1) is too narrow, and should in particular embrace historic landscapes. Most counties in England are equipped with Historic Landscape Characterisation, as well as historic town urban surveys, that help contextualise understanding of designated landscapes and how they came to be created. Planners, and promoters of schemes, need to be armed with the fullest understanding to inform appropriate policies for the conservation, restoration, enhancement, and enjoyment of the natural environment in their area. The cultural heritage of all landscapes should be recognized, as much as the coasts (NE7.1) and those with National designations (NE8.5), is the term cultural’ intended to coverheritage’?

Many Open Spaces (NE9) are artificial creations, such as parks and gardens, that may have additional protection, and a historic character of their own.

Policy NE7 on the undeveloped coast appears perfunctory and is somewhat overtaken by the Marine and Coastal Access Act 2009 as this sets out the basis of coastal access and establishes the remit of the Marine Management Organisation, which will extend to low water and overlap with local planning authorities. The two should at least be cross-referenced.

3. Do you agree with the requirement for local planning authorities to continue to produce, and keep up-to-date, open space strategies which are based on assessments of local need and audits of existing provision (NE1.3)?


4. We propose that local planning authorities should take a strategic approach to the delivery of green infrastructure (NE4), but not to produce and publish a formal strategy (although they can do so if they choose). Do you agree with this proposal?

Yes, providing that they have an adequate evidence base to inform appropriate green infrastructure, including a full understanding of any impact on the historic environment and how to mitigate for that.

5. Do you agree that the proposed policy NE4 will deliver the Government’s objectives without imposing any significant new burdens?

No comment.

6. The amended wording of planning policy relating to the floodlighting of sports and recreation facilities (NE11) makes it clear to local planning authorities that they should balance the impacts on amenity and biodiversity against the wider benefits to the community in terms of health and wellbeing and the additional provision of facilities. Do you agree with this proposal?

No comment.

7. Do you agree that the proposed policy NE11 will deliver the Government’s objectives without imposing any significant new burdens?

No comment.

8. Do you agree with the conclusions of the consultation stage impact assessment?

No comment.

9. Do you think that the policies in this proposed PPS will have different impacts, either positive or negative, on people because of their gender, race or disability? If so, how in your view should we respond? We particularly welcome the views of organisations and individuals with specific expertise in equality and diversity matters.

No comment.

10. Do you have any additional comments to make on this proposed PPS?

Yes, as follows:

The extensive nature of many natural environment designations and therefore of initiatives to improve them, mean that impacts on the historic environment can also be extensive. This is increasingly the case as larger sums of money and increased mechanisation are applied to such 'improvement' through agri-environment schemes and other initiatives. Examples include:

  • Heathland Restoration - extensive mechanised scraping of heathland to remove bracken and allow heather regrowth and also to create 'bare earth' for invertebrates. This has the potential to impact on relic prehistoric and later landscapes.
  • Wetland Recreation - creation of scrapes, ponds, lagoons etc. - open water and reedbeds - in reclaimed marsh land. This may impact on wetland archaeology, including preserved Bronze Age wooden trackways, and the palaeo-environmental resource.

We would therefore like to see some of these policies qualified with an acknowledgement that the broader impact of potential schemes needs to be quantified in planning for them. Thus:

NE1.2 should include: subject to their potential impact on cultural heritage being recognised and taken into consideration.
NE3.1 should embrace historic environment targets, such as Heritage At Risk (which includes both historic buildings and ancient monuments)
NE8.8 should include: subject to their potential impact on cultural heritage being recognised and taken into consideration.

27 May 2010

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