Written evidence submitted by the RSPB (LRS0038)
The RSPB is the largest nature conservation charity in the UK, with a membership of more than 1.2 million people. Our mission is to promote the conservation of nature and the natural environment. We own or manage 158,300 hectares of land for nature conservation across 218 reserves throughout the UK, providing vital havens for a huge range of species, and spaces where people can get closer to nature. The RSPB’s policy and advocacy teams work to protect and conserve nature by influencing the political, policy and legislative context that supports nature conservation at a national and sub-national level, covering a wide range of issues including biodiversity, planning policy, climate change, energy, and water.
The RSPB’s aspiration is a world richer in nature, with a healthy environment that benefits both wildlife and people. A thriving natural environment is essential to our lives, and investment into conserving the planet will therefore make a valuable contribution to achieving a sustainable economic recovery from COVID-19. While in the past nature conservation has often been seen to be in conflict with economic development and job creation, it is now widely accepted that protecting the environment can benefit the economy, create employment and have far-reaching positive impacts on health & wellbeing. We are therefore calling on national, devolved and local governments across UK to deliver a green recovery that has nature and the climate at its heart.
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Local government organisations have a vital role to play in turning around the state of nature, yet their performance is difficult to measure. In 2006 Section 40 of the Natural Environment and Rural Communities Act 2006 placed a duty on all public bodies – including local and regional government - in England. Known as the Biodiversity Duty this requires that a public authority ‘must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity’. However, in the words of the House of Lords Select Committee Select Committee on the Natural Environment and Rural Communities Act 2006, ‘the duty is ineffective as it stands, as a result of limited awareness and understanding among public bodies, weak wording, and the lack of clear reporting requirements and enforcement measures .
As a result of these weaknesses there is an absence of existing evidence with which to measure the performance of regional and local government, and the Duty has failed to deliver tangible results - since its introduction the decline of biodiversity has continued unabated. Nature will play a vital role in any sustainable economic recovery from Covid-19 so it is more important than ever that we protect and invest in the environment. The need for a strong and effective Biodiversity Duty that requires local government and other public bodies in England to conserve and enhance biodiversity, and to report on the steps taken to comply with this duty, has therefore never been greater.
The new Westminster Environment Bill currently proposes strengthening the duty via three welcome steps: (1) it expands the duty to have regard to the need to enhance biodiversity; (2) it creates an obligation to plan for appropriate actions to fulfil the duty; and, importantly, (3) it requires certain public authorities to report on actions pursuant to the duty. However, the provisions in the duty still remain too open ended to guide everyday action – national Government must consult on and publish guidance for public authorities on how the duty should be fulfilled.
The lack of data availability on the distribution and abundance of species at a local level is hugely detrimental to the development of strategies and plans to recover nature. As mentioned above, our economic and environmental recoveries can and should go together side-by-side. Adequate species’ monitoring and recording data will therefore play a vital role in achieving a sustainable recovery from COVID-19, and UK Government should work with local government and other stakeholders to ensure that the quality of our local biodiversity data across England is maintained and strengthened.
Local government has been stripped of funding over the past decade (c25-33%) and many local authorities are unable to afford in-house ecological expertise. Local Nature Partnerships have sometimes coordinated funding for local records centres and data observatories, but levels are below where they will need to be to deliver the UK Government's aspirations for Local Nature Recovery Strategies across England to underpin a nationwide Nature Recovery Network, as well as a front-loaded zonal planning system requiring much higher levels of data (breadth and granularity) early in the process. Properly funded Local Records Centres could be a solution.
In our experience there is a large amount of variation in the level of stakeholder engagement as local and regional government draft their plans. For example, the London Recovery Board that co-ordinates the planning for London's future post-COVID includes in its membership representatives from multiple sectors including education, faith groups, health, small businesses, and the RSPB’s own chief executive Rebecca Speight representing the environmental sector. Other city leaders have chosen to limit involvement in the development of their recovery plans to political and business leaders. In order to effectively forge a path out of this crisis, development of economic recovery plans will require broad engagement across all sectors of society. We will achieve so much more and see greater benefits for people, the economy and the environment if business and industry, local and national government, NGOs, and local communities all work co-operatively.
Local government structures in England form a fragmented pattern which is often seen as confusing by the public and stakeholders alike - recent polling by YouGov reported that less than one in five (18%) of people find it easy to understand what services their local councils provide, with over two-thirds unsure of how local government is structured. While we are not in a position to advise on the optimal structure for local and regional government, we share below some reflections and experiences from working with local and combined authorities in England in order to deliver our conservation objectives.
In our experience there can be inefficiencies and disconnect - both in policy making and delivery - in the two-tier approach to local government. This is caused by functions being split, and in some cases duplicated (e.g. economic development), between county and district councils. Whatever the local or regional government structure in an area, it is vital that overlapping responsibilities are avoided, with transparency on what is being delivered by whom.
Maintaining democratic and community links is an important role of local government. District and borough councils tend to maintain close links with local people, who find it easier to understand the relevance of the council’s work to their lives, resulting in a higher level of public scrutiny. However, we have observed that the larger and more powerful an authority, the more distant it becomes from the people it represents. As a result, unitary authorities tend to function more as a delivery arm of central Government, often at the expense of local decision making. The trade-off, of course, is the ability to act strategically across larger geographies, which enables those larger authorities to deliver effectively.
We are aware that an announcement by Local Government Minister Simon Clarke at a Northern Powerhouse event earlier this year suggested that the English Devolution White Paper – expected in the autumn - will focus on removing borough and district councils in favour of ‘super-unitaries’. Given our comments above, we are concerned that such a focus could actually lead to increased centralisation as opposed to devolution. Through working with these local councils, the RSPB has seen a lot of successes for nature through practical action on the ground. For example, a national partnership between the RSPB and Barratt Developments Plc has had success working at a local level with Aylesbury Vale District Council to deliver an award-winning scheme for 2,450 homes at Kingsbrook, setting a new standard for wildlife-friendly housing. The development incorporates nature-friendly elements into the built environment, demonstrating that new homes need not be at the expense of the natural world. It is local partnerships and exciting projects such as this, with demonstrable benefits for residents and for nature, which we must not lose in any future plans for structuring local government.
An RSPB partnership with management company Idverde sees us working primarily with borough councils to improve their understanding of the role communities can play in both discovering and looking after the wildlife in their neighbourhood, along with training to improve the knowledge of their management staff. For example, we work with Bromley Borough Council who have contracted out their greenspace management to Idverde, and in doing so are working with us to deliver the Council’s biodiversity strategy and make the community a greener place that benefits both people and wildlife. The local level at which these contracts operate is important for delivery – there is a risk that the successes we have seen through working with borough councils in this way to deliver biodiversity enhancement and community involvement would not be replicated at “super unitary” level.
We are concerned the proposals in the recently published ‘Planning for the Future’ White Paper consultation will result in decreased levels of public scrutiny in planning decisions. Combining this with any plans to move to a more unitary model risks exacerbating this further. While we appreciate the areas in which the two-tier system can be problematic (see above), moving too far in the other direction risks moving to a system of local government that is too far removed from local communities and local needs.
Almost 12 million people in England now live in one of eight combined authorities governed by an elected metro mayor (excluding London). This relatively new structure enables local authorities to agree to work together formally, pooling their resources and powers in order to function more effectively. As Green Alliance reported in the lead up to the election of these new mayors “their role can be used to tackle some of the most pressing environmental challenges… these include cleaning up toxic air and polluted waterways, developing new energy efficient housing and cleaner, better connected local transport, as well as creating networks of accessible, wildlife rich habitats” . This new scale for action is logical in terms of delivering for the environment – nature does not respect political borders, therefore cross-border working is vital in order to deliver for wildlife at a landscape scale. But a key part of that leadership role is working with the local authorities who are arguably closer to the opinions and needs of the people and places that they represent. It is the combined authority’s role to assess how cross-border working across the region can deliver solutions that fulfil everyone’s needs whilst getting a much bigger “bang for their buck” by doing so over a larger geographic scale. This includes protection and enhancement of the local environment.
However, the powers and approaches taken to strategic planning vary according to the devolution deal that each combined authority has struck with UK Government. This only further complicates the picture, and the different models have not been helpful in securing effective strategic planning across wider geographies. Combined authorities with different devolution deals and different levels of funding have different aspirations, policies and opportunities in relation to, for example, nature and green infrastructure, making it difficult to deliver a consistent approach to environmental recovery across the country.
Indications suggest that Powerhouses such as the Northern Powerhouse, Midlands Engine, and Western Gateway will become increasingly influential over time. These partnerships are perfectly positioned to drive the UK’s response to the climate and nature emergencies and play a leadership role in delivering a green economic recovery across that region (see our response to ‘Sustainable Regional Economies’ below), redefining the economy to work with, and not against, nature by delivering the following actions:
The RSPB has been engaging with UK Government's Oxford-Cambridge Arc proposals, and has observed what appears to be a positive example of different tiers of local and regional government working together via the governance structure created for the Arc. Although we acknowledge that this is a new structure and it is too early to point to any tangible delivery, the overarching leaders group sitting above functional working groups (or “pillars”) appears to be successfully encouraging different tiers of government to work together, and alongside stakeholders, to develop a larger-than-local approach to planning growth in the Arc. We hope that it will not be long before outputs such as an Arc-wide spatial plan and sustainable growth strategy that includes restoring nature are available to demonstrate the benefits of cross-authority working.
The forthcoming Environment Bill is expected to legislate for the creation of Local Nature Recovery Strategies (LNRSs) to influence planning and spending decisions across England. Done properly, LNRSs could deliver this whilst also coordinating a number of the commitments set out in the UK Government’s 25 Year Environment Plan. Collectively, these strategies will cover the whole of England, and by identifying and mapping local biodiversity priorities and opportunities through a consultative process involving multiple local authorities, local communities, and other stakeholders, LNRSs have the potential to make a truly positive contribution towards nature’s recovery. However, proposals so far are for these to work at either a county, combined authority or National Park level. Consideration must be made as to how any proposals for the future of local government structures tie into the delivery of LNRSs. An overriding framework from national government is also required to ensure a consistent, coherent approach across these different governance structures, allow the different strategies across England to talk to each other, and ensure that they lead to practical delivery on the ground. See our response to “Regional Funding” below for our comments on the need for authorities to be adequately resourced to prepare and deliver these.
See our response to “Evidence Base” above for our comments on stakeholder engagement.
One example of a positive approach to stakeholder engagement is the West Midlands Combined Authority’s recent consultation on “WM2041” – the region’s environment and climate strategy. The consultation was well publicised to businesses, organisations and members of the public, with the WMCA Head of Environment attending various meetings of stakeholder groups to present the Strategy in the lead up to the consultation, and news of the consultation appearing in local press. While the online form for submissions was a simplified set of questions to encourage responses from local communities, there was an option for organisations such as ourselves – whose responses were likely to be longer and more detailed – to e-mail in their submissions rather than being tied to specific questions. In addition to the more traditional request for email/online submissions, the Combined Authority conducted a Facebook Messenger questionnaire and worked with the Democratic Society to run in-depth workshops, both of which presumably enabled them to reach a wider audience than otherwise would have been the case.
Another example of best practice is the Greater Cambridge Local Plan consultation process, which has got off to a positive start with strong outreach to residents and clear environmental targets that, rather than being siloed into a separate section, are used throughout in a way that clearly demonstrates how they contribute to economic growth and benefit residents.
SUSTAINABLE LOCAL ECONOMIES
At the RSPB we have been encouraged by the increasing recognition by leaders and decision makers of the need for a green recovery. It is impossible to miss the role that nature has played in providing a source of comfort and relief for so many during this difficult time, and we can expect that nature will continue to support us as society begins to recover. A thriving natural environment is essential to our lives, and by protecting and enhancing the environment we will benefit the economy, create employment, and have far-reaching positive impacts on people’s health & wellbeing. Investing in measures that benefit nature as well as the economy will underpin future prosperity for years to come.
The results of a recent YouGov poll conducted on behalf of the RSPB were striking in their demonstration of overwhelming public support for increased access to nature-rich greenspace as part of our recovery from the impacts of the pandemic, with 89% of respondents in England agreeing that doing so will improve people's general health, well-being, and happiness. The survey also highlighted clear inequalities in access to nature between households with the highest and lowest incomes, and between urban and rural areas, suggesting that the impacts of the virus have not fallen equally across society.
Local and combined authority leaders have an important role to play in leading the economic recovery in their regions, and as advocates for stronger and greener policies and legislation at a national level. In considering who is best placed to provide the leadership of local net zero and skills-based priorities, it may not be so much about tiers, as functions. For example, the planning and transport authorities having key roles in delivering net zero.
In order to respond to the findings of the above poll, ambitious targets for protecting and increasing nature and natural greenspace must be placed at the heart of all national, regional and local recovery plans. The RSPB recently wrote to all metro mayors to share these findings and ask them to work with local communities and stakeholders to take steps to build nature into their economic recovery. The template letter sent to mayors, which includes examples of measures that will benefit nature whilst simultaneously supporting people’s health and wellbeing as well as the economy, can be downloaded here.
If local and regional government are to successfully deliver the green recovery outlined above, it is vital that they have the necessary skills, expertise and resources. Working as part of the Wildlife & Countryside Link coalition we are calling for Government to invest in a ‘National Nature Service’ scheme that will create jobs, improve the health of nature, people and the planet, and contribute to a green, sustainable recovery. This employment and training scheme would see tens of thousands of jobseekers, particularly young people and those from underrepresented and disadvantaged groups, employed and trained in environmental projects designed to level up access to nature, address social and health inequalities, and bend the curve on nature’s decline. The idea has amassed considerable cross sector support from environment charities, youth unions and diversity groups to businesses, local authorities and farmers. We are currently working up the details of a delivery model and would be happy to share this with you when available.
TARGETED REGIONAL INVESTMENT
Shovel ready projects
Investment in nature conservation can stimulate local and regional economic benefits by providing a short-term boost in employment, opportunities for volunteering and green tourism, and creating a more resilient economy. All in addition to delivering statutory responsibilities for designated habitats and landscapes.
Working as part of Wildlife & Countryside Link the RSPB has been involved in the development of a compendium of shovel-ready projects across England in order to demonstrate the scale of opportunity. These 330 projects can create around 5,000 FTE jobs in the environment sector, 5,000 FTE jobs in delivery, plus supply chain benefits, and would deliver a significant boost towards Government nature and climate targets.
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Local and regional priorities for nature conservation should be identified utilising a long term and strategic approach to environmental planning that translates national ambition into local delivery on the ground. The Local Nature Recovery Strategies outlined under “Local Structures” above will provide a new system of spatial strategies for nature covering the whole of England. By agreeing priorities for nature’s recovery and mapping both existing habitat as well as opportunities for creating or improving habitat, each of these local strategies will enable more coordinated, practical and focused action to recover nature. This process should bring together relevant public authorities, local stakeholders and experts, along with the necessary resources, in a co-ordinated and effective way. All public bodies should then be obliged to take these maps and plans into account in planning and spending decisions.
The result should be local priorities that support delivery of national commitments from the UK Government’s 25 Year Environment Plan, including mandatory biodiversity net gain and the ‘Nature Recovery Network’, all of which will contribute to the delivery of a green economic recovery. However, it is also important that local and regional government are empowered to take a leadership role by going further than statutory requirements where possible.
The main difficulty that many public authorities have in enhancing biodiversity is severe financial constraint. In planning their actions to abide by Biodiversity Duty (see our response to ‘Evidence Base’ above) Local authorities should be required to set out an estimate of the likely budgetary needs and constraints, which should be submitted to HM Treasury.
The forthcoming Westminster Environment Bill is expected to place a number of additional burdens on local government, including the development and delivery of Local Nature Recovery Strategies (see “Local Structures” above) and the delivery of biodiversity net gain in the planning system. National government must ensure that local authorities – many of whom are already financially constrained - are adequately resourced to deliver these additional duties. Funding should include provision for adequate staff, the right training, ecological expertise, and any new systems required.
UK Shared Prosperity Fund
The UK Shared Prosperity Fund (UKSPF) will need to be at least as strong for wildlife as the EU funds it replaces. It will need strong environmental targets and criteria if it is to deliver the government's objectives and legal commitment, which cannot just be left to smaller environment-only funding streams, valuable though they are.
EU conservation investment through the LIFE programme has contributed to regional economies: in our experience creating 1FTE for every £70k of govt investment, spread widely around the country. It is vital that conservation investment addresses regional equality, as many of the UK's greatest nature areas are in parts of the country that would benefit from levelling up.
The most effective way of securing an economic levelling-up agenda is through delivering a true green recovery. Some parts of society have been more badly affected than others. Many communities that have been disproportionately affected by the pandemic have suffered further from limited access to safe, wild spaces nearby. The establishment of a National Nature Service (see our response to ‘Sustainable Regional Economies’ above for more detail) should provide employment, skills, and access to nature-rich greenspace across the country for all sectors of the community, especially the most disadvantaged and marginalised communities in need of work and training.
It is our belief that Whitehall should provide the strategic framework within which to allow local areas to function through the exercising of democratic processes. Within this framework the principle of subsidiarity should apply. There has been an increasing tendency for decision making to become too centralised, impacting negatively upon local democratic processes. All too often effective strategic policy making frameworks are lacking, as evidenced by the lack of statutory land-use planning beyond a local level.
Many skills do exist at local/regional level to undertake this work. However, a skills audit is required as much this local capacity, talent and experience has been lost due to the stripping away of funding and powers from local/regional government. There is a need to reinvest into these areas and give local/regional government roles and functions that allow them to regain their former effectiveness. In doing so, talent will be re-attracted to this level.