Colne Valley Regional Park                            ESH0062

Written evidence submitted by

Environmental Audit Committee - Call for evidence – Friday 20th December 2024 (updated 4/2/25 to include information previously provided in separate documents)

https://committees.parliament.uk/call-for-evidence/3474/

1. Our response concerns the Government’s proposed reforms to national planning policy (revised NPPF) and the effect on environmental protections and current approaches to sustainable development.  It addresses the planning framework in the recently revised NPPF and five of the questions (1, 3, 4, 6 and 8) posed in the Committee’s terms of reference.  In summary these questions cover:

-          The protection and enhancement of the environment and the ‘presumption in favour of sustainable development’.

-          The promotion of sustainable social and environmental benefits e.g. active travel routes.

-          The protection of the natural environment and the implementation of local nature recovery strategies

2. We applaud recent initiatives to protect and improve Nature, particularly Biodiversity Net Gain (BNG) and Local Nature Recovery Strategies (LNRS) but see a major omission when it comes to policy and decisions affecting the Green Belt on the edge of cities.  The key issue is that neither BNG nor LNRS address people’s access to the natural environment – something assuming greater importance next to large urban areas, with implications for well-being and the economy.
3. We note that the five Green Belt purposes are geared more to preventing things happening, rather than valuing the potential of countryside next to large urban areas to enable people’s contact with nature and countryside with all its potential well-being benefits:

-          For better mental health – research backs this up – with a couple of examples below[1]

-          For better physical health – active travel – addressing the obesity crisis

-          For local food production – connecting people with where their food comes from

4. In our September 2024 response to the Government’s draft NPPF we called for changes which appear to have been ignored.  The wording in the revisions published on 12th December 2024 are even less accommodating of nature and environmental considerations than the consultation draft.  Significantly, two purposes of the Green Belt relating to ‘safeguarding the countryside’ and ‘recycling of derelict land’ have been bypassed when it comes to considering whether land can be regarded grey belt.
5. We provide (in Annex 5) a summary of our September 2024 response to the draft NPPF and (in our Annex 6) some information about the Colne Valley Regional Park. 
6. For your information, we also made a submission to the recent House of Lords short inquiry into so-called ‘Grey Belt’.  This submission can be provided if required.
7. Our approach is a pro-countryside, not an anti-development, one.  We genuinely believe there is now a real opportunity for a ‘win-win’ solution.
8. We urge the Committee to highlight the need for the following changes to national policy:

a)      Adjust the five Green Belt purposes to embrace the strategic green infrastructure (GI) role that it can perform (using the definition of GI in NPPF page 73 – see Annex 3).   This would be consistent with the ambition expressed by the Government, only this week, in its working paper on development and nature recovery (see extract in Annex 4).

b)      Make NPPF policy in para 151 (Annex 1) about positive planning for beneficial use of the Green Belt a requirement, rather than something optional. 

c)      Reinforce the need for workable mechanisms to achieve strategic planning across political boundaries and beyond individual development sites/areas.  Achieving connectivity for active travel and wildlife requires strategies across boundaries and sites.  As an example, this week’s White Paper on Devolution calls for 'Spatial Development Strategies' across mayoral and other areas, but with no apparent reference to cross-boundary co-ordination.

d)      Alter the way policy for ‘Grey Belt’ areas in the Green Belt works to ensure:

• Decisions consider all purposes of the Green Belt, not just three
• Piecemeal land release in the Green Belt is avoided and opportunities for ‘natural corridors’ for active travel and wildlife are grasped.

e)      Widen the ‘Golden Rules’ for Green Belt development to embrace more than housing (new NPPF para 156 onwards) – non-residential growth is a big issue affecting green belt land around cities with significant commercial gain the norm.

f)       Review the ‘Golden Rules’ to include wording from the former NPPF (end of para 147 – highlighted in Annex 2) that required: “…compensatory improvements to the environmental quality and accessibility of remaining Green Belt land…” when land is released from the Green Belt.  This wording to also apply to major developments in the Green Belt that come forward outside of Plans, under ‘Very Special Circumstances’.

9. With further planning reform and detail in 2025 (standard Development Management policies and a shorter, more strategic NPPF) the opportunity exists to remedy errors made in the recent NPPF, thereby achieving a better deal for the natural environment and people’s access to it. 
10. These changes are necessary if the planning system is to result in sustainable development that achieves the right balance between economic, social and environmental objectives.
11. If government is unable to incorporate our changes (a to f as outlined above) into national planning policy then it remains essential that they find the means to safeguard the CVRP's regional importance for people and national importance for wildlife.  Otherwise, 60 years of vision and partnership working across the edge of five counties will be thrown away.

February 2025

ANNEX 1

Revised NPPF (Dec 2024) Paragraph 151

ANNEX 2

Former text in December 2023 Version of NPPF – Para 147 (our highlighting is to flag wording that has been omitted in the December 2024 Version of the NPPF)

ANNEX 3

ANNEX 4

Extract from joint DHCLG & DEFRA “PLANNING REFORM WORKING PAPER - DEVELOPMENT AND NATURE RECOVERY” (15.12.24)

https://assets.publishing.service.gov.uk/media/675db3f7cfbf84c3b2bcf9f3/Planning_Reform_Working_Paper_-_Development_and_Nature_Recovery.pdf

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ANNEX 5

SUMMARY OF SEPTEMBER 2024 RESPONSE FROM COLNE VALLEY REGIONAL PARK (CVRP) TO  GOVERNMENT consultatioN (JULY 2024) ON REVISED NPPF

ANNEX 6

Basic information about the Colne Valley Regional Park

As the first Green Belt area west of London the CVRP offers those living in urban areas access to the natural environment, with all its attendant benefits for health and well-being.  Its multi-functional roles support:

• green and blue corridors rich in biodiversity and ecological connectivity
• opportunities for nature recovery and re-wilding
• local food production
• combatting climate change
• active lifestyles, physical and mental well-being
• recreational pursuits
• flood management

We believe the CVRP is unique in having an organisation established specifically to protect and improve this area of ‘inner’ Green Belt on the edge of the capital, working in collaboration with local authorities and other partners. Funding is, however, minimal.

The Colne Valley Park Trust oversees the park and is a registered charity.  Day-to-day operations are managed and implemented through a contract with Groundwork South, a not-for-profit company operating in the environmental sector. 

Everything we do in the park is guided by its six objectives.  These are consistent with national planning policy for the Green Belt:

1. Landscape: To maintain and enhance the landscape, historic environment and waterscape of the park in terms of their scenic and conservation value, and their overall amenity.
2. Countryside: To safeguard the countryside of the Park from inappropriate development. Where development is permissible it will encourage the highest possible standards of design.
3. Biodiversity: To conserve and enhance biodiversity within the Park through the protection and management of its species, habitats and geological features. We are the home of many areas of nature importance.
4. Recreation: To provide opportunities for countryside recreation and ensure that facilities are accessible to all.
5. Rural Economy: To achieve a vibrant and sustainable rural economy, including farming and forestry, underpinning the value of the countryside.
6. Community Participation: To encourage community participation including volunteering and environmental education. To promote the health and social well-being benefits that access to high quality green space brings.