Written evidence submitted by the National Trust
Summary of main points
1.1 The National Trust is Europe’s largest conservation charity with over four million members and an annual turnover of more than £450 million. We currently manage over 250,000 hectares of countryside, several hundred historic houses, gardens and parks and more than 740 miles of coastline across England, Wales and Northern Ireland. The National Trust exists to look after special places for ever, for everyone.
1.2 The work of the National Trust has an increasing focus on the condition of the natural environment. The health of the natural environment is compromised by decades of misuse and under pressure from climate change. Sixty-per cent of our wild species have declined over the past 50 years and in the UK 30% of the natural processes that people benefit from (“ecosystem services”) are assessed as declining and many others are in a degraded state[1]. The health and beauty of the places the National Trust looks after are in danger if the wider condition of the natural environment continues to deteriorate.
1.3 This response from the National Trust attempts to respond to all three areas set out by the Committee:
Our response is based on issues that remain of concern for the National Trust, following our involvement in the early stages of developing the concept of LNPs, and engagement with a number of LNPs since.
2.1 We supported the original proposals for LNPs in our response to the Efra inquiry on the Natural Environment White Paper in June 2011. We called for them to have a broad definition, take a holistic approach to land and be resourced adequately: we felt the £1 million seed funding was likely to be insufficient. We also felt that it was vital that LNPs operated in parity with LEPs and suggested that access to further public funding by either LNPs or LEPs should be contingent upon their joint agreement and that there be a degree of overlapping of membership or ‘observer’ status for representatives required at each other’s meetings.
2.2 In further evidence submitted to the Efra Committee in September 2011, we set out that LNPs should have the following characteristics:
2.3 We felt that LNPs should facilitate the duty to co-operate, and therefore suggested either DCLG should be their sponsoring Department, or there should be joint sponsorship by Defra and DCLG.
2.4 With a wide range of proposals being developed, we felt there was a risk that existing fora (such as LBAPs/Biodiversity Forums) simply became LNPs without sufficiently extending their membership or function to reflect the Natural Environment White Paper (NEWP). We believed there was a need for an institutional framework to bring partners together. While the capacity-building fund from Defra would help, we suggested that county councils might also play a role in facilitating LNP formation.
2.5 We highlighted the advantages of having private sector involvement from key actors (e.g. water companies, agricultural producers, retailers) in the LNPs to help facilitate more initiatives like the ‘Moors for the Future Partnership’ which had brought resources and mutual ecosystem/cost benefit as a result.
2.6 We believed LNPs could be a really useful tool in respect of the ambitions of the NEWP but felt they did need guidance, resources and strategic connection to LEPs if these were going to have impact on the ground. We were concerned that the concept of LNPs was being rushed for no particular reason and that they needed to be fit for purpose.
2.7 In a similar vein, whilst we welcomed the proposals for Nature Improvement Areas as part of the delivery mechanism for the NEWP, we not only expressed our concern that more than 12 such areas would be required to restore nature on any significant scale but that these were also being rushed through and should have come later and have been a focus for the LNPs.
2.8 In evidence submitted to the CLG Committee on the National Planning Policy Framework, also in September 2011, we drew attention to there being no mention of the new LNPs. The National Trust fought hard for LNPs to be established as a fundamental part of the new planning system. This was because we recognised the need for further bodies to support the duty to cooperate in relation to strategic planning. We felt the NPPF should make clear the relationship between it, LNPs and LEPs. This would have helped overcome some of the uncertainty around how strategic planning and delivery would work in terms of both economic and environmental outcomes.
2.9 We were a signatory to a joint Wildlife and Countryside Link paper, Local Nature Partnerships: Delivering for Nature, published in December 2011. This set out our collective NGO views on what we believed the role of LNPs should be, and the systems they required around them, to ensure they were influential in achieving restoration and recovery of the natural environment. The aim was that this document would be used by Defra in producing further guidance and support for LNPs ahead of the application process in 2012.
2.10 In our response to another EAC inquiry on biodiversity offsetting in 2014, when considering which model of delivery would be appropriate, we felt it would be important that any scheme adopted should have the ambition and capacity to fund the landscape scale work that is needed to deliver the ambitions of the NEWP. One suggestion was that LNPs, which operate at this larger-than-local level, should be given responsibility for distributing the funds, or a proportion of them, based against a nationally agreed set of criteria. In this scenario, many LNPs would need to ‘raise their game’ and ensure they have sufficient capacity and draw on appropriate expertise. LEPs should be required to work with them.
2.11 Many of these views and recommendations remain valid. Additional information in respect of the three areas being examined by this inquiry is set out below. Together, this forms the basis of our summary points above.
3 Governance, composition and funding
3.1 Given the reservations about how much LNPs were meeting the recommendations outlined above, the National Trust has taken a conscious decision to base our involvement in LNPs on a case-by-case basis, prioritising those where there is a clear cross-over in objectives and where they are responsible for delivering something tangible, e.g. where delivering an NIA and where we were already involved in a previous partnership network. In addition, LNPs are still in their early stages of development, with many only having had inception meetings last year, so we have been playing a watching brief.
3.2 Our observations indicate that some LNPs are struggling to be effective, for which we believe there to be a number of governance, strategic and financial reasons:
3.3 However, further observations suggest that LNPs with a non-environmental Chair can result in positive benefits; this is due to the different backgrounds, skills and experience that such individuals can bring to the table, such as new perspectives and opportunities for collaboration with other sectors, including LEPs.
3.4 In addition, LNPs that already had good partnerships and funding in place have, unsurprisingly, had more success in taking projects forward, especially where funding can support the time of a project officer. Experience from other environmental project or focus groups would support this, and that even a small amount of funding can help drive forward initiatives and bring in larger amounts of external funding, providing both the kick-start and confidence to move forward.
3.5 LNP meetings still have a very senior level of representation, which signifies good buy-in and commitment from those organisations involved. However, this can create difficulties with implementation on-the-ground and at practitioner level, usually requiring delegation to practitioner-level workgroups to take forward projects.
3.6 LNPs offer a useful gathering and networking opportunity for many of those in the environmental sector who may be lacking other opportunities to get together; the informal networking and discussions arising as tangents to formal meetings can sometimes be of greater benefit than the meetings themselves and complement them well.
3.7 LNPs where projects have not progressed well seem to have a lack of funding as well as steer; besides the need for funding a national “steer” would be of benefit to LNPs in helping set direction and pace.
4.1 Whenever we have been involved with LNPs, including where we attended various workshops at the beginning to explore their priorities, we have tried to encourage a broader approach, e.g. looking at landscapes and access as well as habitats. It feels like this is hard for the LNPs to do and therefore their positioning is dependent on people valuing nature rather than them making wider connections to wellbeing, children, natural capital agenda, etc.
4.2 We think this is missing a trick as it is politically hard to prioritise nature at the moment unless there are other social or economic benefits. Where they do enter this arena, it tends to be linked to green infrastructure and this, for example, has been the most effective way of getting nature and the environment into planning. Some green infrastructure networks have linked effectively with the LNP and this seems to be quite useful in an urban context, e.g. green infrastructure is “politically acceptable” in a way that nature is not.
4.3 There has been talk of LNPs being a statutory consultee for planning but this has tended to cause LNPs to panic because they were not resourced to be able to do this effectively. As far as we can tell, they do not engage volunteers in the way that an organisation like CPRE would do to influence planning.
5.1 Most seem to have a tenuous relationship with LEPs which clearly hold all the resources and are often strongly focused on big industry, infrastructure and growth. LNPs are their poorer sister and have limited ability to influence unless it is on the ‘sustainability’ agenda linked to EU funding (e.g. water, energy, etc) but this agenda seems out of sync with LNPs’ skills.
5.2 It is also worth highlighting the issues of overlap at the local level with Catchment Partnerships which are also being promoted by Defra. This illustrates the lack of integration across Defra policy areas resulting in confusion and overload for stretched organisations at the local level. Because LNPs and CPs vary so much, organisations will back one or the other depending on their interests and the perceived focus of the LNP or CP. To add to the confusion, we also have the 12 NIAs and NGO-led landscape scale partnerships (Futurescapes, Living Landscapes, etc) to engage with. As a resource-constrained local Wildlife Trust or even a business looking to support some good work, where do you focus your effort?
5.3 There is perhaps an assumption amongst some that CPs “do water” (specifically the Water Framework Directive) and LNPs “do nature” and that these are different. However, in practice some CPs are taking a whole-catchment approach to land management, payments for ecosystem services, habitat creation, etc., i.e. they recognise that they need to deal with the overall system (as was originally expected of LNPs). Some clarity from Government on how these initiatives should work together would be useful. We also think a more explicit encouragement for both CPs and LNPs to work at a system level and think about multiple benefits is needed.
5.4 More generally, we think it would be worth mentioning the need for LNPs and Government support of them to be more aligned with the ambitions of NEWP and also that LNPs might have a role in implementing the 25 year plan aspirations of the Natural Capital Committee.
5.5 The following is an excerpt from notes of a recent Biodiversity 2020 workshop which helps illustrate the overlap between water and biodiversity work through local initiatives: “The potential for good alignment on wetland biodiversity between NIA agendas (albeit covering a small proportion of England) and the England wide CaBA [Catchment Based Approach] partnerships was demonstrated through the case studies presented; CaBA can & does operate more widely than WFD, whilst some NIAs are helping WFD as well as biodiversity. Defra presented strong evidence on the ambitions of catchment partnerships as extending beyond a narrow WFD/water quality focus to include freshwater and terrestrial biodiversity. The ecosystem services focus for these groups was noted and County Wildlife Trusts were noted as a constant member of catchment partnerships. However, it was also noted that not all actions which had apparent biodiversity aims were actually delivering against specific Biodiversity 2020 outcomes, and some actions could act counter to biodiversity objectives, underlining the need for clearer guidance on Biodiversity 2020 outcomes. Interestingly, better landowner representation was a gap that many Catchment Partnerships had indicated they would like to address. There is more potential to build on current catchment group best examples.”
5.6 We also have concern that reliance is often placed on the same people from different organisations to engage and drive forward these partnerships (often around the edges of their day job). As well as diluting the impact, without investment it is hard for the LNPs in particular to get beyond the strategy/work-planning stage as no-one has the resource to take forward the actions. Both initiatives could co-exist but only with proper investment and by addressing those issues set out above.
6.1 Given the concerns outlined above, the time is right for the next Government to review the role and remit of Local Nature Partnerships. The experience of the best LNPs shows that Local Nature Partnerships should not simply be discarded but should be reviewed to maximise their potential as part of the new sub-national arrangements being looked at by all the main parties, and what guidance and support can be given by central government.
6.2 This review should examine how the Government can show leadership and champion LNPs (in the same way as LEPs), determine the funding and resources necessary for LNPs to have any impact, and establish clear strategic asks of LNPs – including the potential to channel funding and projects through them, as with LEPs.
6.3 That review also needs to look at the role of LNPs in the wider context of:
6.4 In the meantime, we support ideas from the Northern Upland Chain LNP for environmental or ‘natural capital’ investment plans as a means to help parties galvanise around a set of collectively-agreed strategic priorities. Such an approach would provide a common national framework that could be tailored to local circumstances, responding to recommendations of the Natural Capital Committee’s Third State of Natural Capital Report whilst also linking to Biodiversity 2020 and WFD objectives.
25 February 2015
[1] State of Nature, RSPB, May 2013; UK National Ecosystem Assessment, 22 September 2011