Written evidence submitted to the Environmental Audit Committee’s Parliamentary Inquiry on Local Nature Partnerships by Lowland Derbyshire and Nottinghamshire LNP. Submitted by – Tony Walker, Chair, Lowland Derbyshire and Nottinghamshire LNP About us - Lowland Derbyshire and Nottinghamshire LNP was formed in 2012. We cover all of Nottinghamshire and the area of Derbyshire outside the Peak Park. Chair of our board is Tony Walker from Toyota Manufacturing UK. Also represented on the board are Derbyshire and Nottinghamshire County Councils, the Health and Wellbeing Board, relevant private sector companies and local environmental organisations. Executive Summary The Lowland Derbyshire and Nottinghamshire LNP consists of a group of committed and motivated members who seek to define the role of the partnership and ensure it is successful and adds value. We recognise that LNPs are relatively new organisations and there are several key problems that the Government and LNPs need to resolve together to ensure that they are sustainable and will add value. We have listed below the key issues that the Committee and Government must note and address. Governance, Composition and Funding of the LNP The LNP relies on the good will and participation of Board members. This is a positive contribution and a key driver for a successful LNP. The LNP is concerned that the level of non-monetary resource and commitment from the Defra family (Natural England, Environment Agency and Forestry Commission) that is required to support the LNP is not defined and authorised. A lack of secure long-term funding for our LNP staff represents a real risk that the LNP cannot be a sustainable and effective organisation. To ensure an effective LNP the Government must identify the minimum funding requirements to discharge statutory obligations and implement national policy objectives delivered through an LNP. Impact on NIAs, habitats more generally and on the planning system To support the LNP we have established a Natural Capital Working Group to establish the natural capital baseline for 8 capital assets and 65 components with the aim to identify priority problems for the LNP Board to focus on and develop its strategy. Natural capital is a new approach and requires Government support to develop a cost effective and efficient method for the LNP to collate natural capital data which is nationally consistent and has local relevance. To ensure that the LNP Board delivers a consistent approach to strategic planning and local planning we produced a planning policy framework, rules and procedure for the Board to handle planning issues (see appendix 2). As a matter of urgency the Government needs to clarify the LNP role and task(s) to meet the requirement of the Localism Act 2011 duty to co-operate in relation to strategic plans and sustainable development, and ensure that our current holding position is not jeopardising a planning authority’s statutory duty. There is a knowledge and skill gap for LNP to undertake the task to evaluate and advise planning authorities in relation to sustainable development. This needs to be addressed by Government and LNPs as a matter of urgency. Government needs to articulate a single, clear, measurable remit for LNPs. For example “to measure, maintain and improve natural capital in the local areas” and support LNPs set key performance indicators to measure success and value. The LNP has no statutory or non-statutory mechanism through which the protection and/or improvement of all natural capital is incorporated into strategic plans. The most appropriate mechanisms to achieve this must be investigated by Government to ensure national consistency. Links and co-ordination with other LEPs, environmental and planning organisations A diverse LNP Board with top and senior management representation from organisations has helped with developing links and co-ordination. Strong private sector representation on our board helps us to engage with the LEP and this is a real asset in our LNP. The Government should review boundaries between the LNP, the LEP and other organisations to establish if we have the most efficient organisation for planning and partnership working. The Government must review the most efficient way, including the role of the County Councils in working with LNPs, to evaluate strategic plans with the aim to minimise burden and workload which results from 16 strategic development planning authorities in our area. To ensure long term and effective partnership working, the Government should consider recognising and formalising the working arrangements between key Government organisations. LNP partners tend to focus on green nature (i.e. species and ecological communities). Links with other organisations concerning other natural capital assets such as sub-soil assets, minerals, and air quality, and their economic and social value, are less well represented. In particular, links and co-ordination around air quality is difficult. The Government must promote stronger links and more integrated approach for these natural capital assets, particularly for air quality. 1. Governance, Composition and funding of the LNP 1.1. Our LNP Board is led by a chair from the private sector: Tony Walker, Deputy Managing Director, Toyota Motor Manufacturing UK. There is a broad representation from the private and agricultural sectors, the public sector including the Health and Wellbeing Board, and the third sector comprising non-governmental environmental organisations [see Appendix 1 for full board details]. 1.2. Governance structure is limited to a part-time co-ordinator acting as secretariat to the LNP Board. This position is funded by four of the Board organisations for a period of three years. There is no guaranteed funding after that time. The part-time nature of the role restricts the LNP’s capacity, and a lack of secure long-term funding represents a real risk that the LNP cannot be a sustainable and effective organisation. 1.3. Several Board organisations are supporting the LNP Board to drive its strategy and activity. Support is temporary with no long term commitment. It includes: o provision of a technical manager from Toyota Motor Manufacturing to support strategy and natural capital baseline development; o provision of technical support managers from Derbyshire and Nottinghamshire County Councils; o provision of a data hub and GIS resource from Derbyshire County Council to support natural capital baseline development; and o provision of natural capital data through staff resource from British Geological Survey, Environment Agency, Forestry Commission, Natural England, Derbyshire County Council and Nottinghamshire County Council. The LNP relies on the good will and participation of the Board members. This is a positive contribution and a key driver for a successful LNP. 1.4. It is imperative for a successful LNP to have the practical support of the Defra family to enable it to discharge its functions. The LNP is concerned that the level of non-monetary resource and commitment from the Defra family (Natural England, Environment Agency and Forestry Commission) that is required to support the LNP is not defined and authorised. This is limiting our capability to achieve our aims and objectives. Further, Defra family participation at a Board level is minimal which can reduce the effectiveness of the LNP. 1.5. Although funding may be available through the Local Enterprise Partnership, Heritage Lottery Fund and EU it is unlikely to be available to support human resource for an LNP secretariat or operational organisation. Further, making application for this funding is timeconsuming and we don’t have staff resource to make applications. A lack of secure longterm funding for our LNP staff represents a real risk that the LNP cannot be a sustainable and effective organisation. 1.6. LNPs need a level of funding so that they can discharge, at least, the functions that the Government expect them to fulfil. In particular the requirement under the Localism Act to support and ensure that Planning Authorities’ strategic plans achieve sustainable development. The work content for this task is not insignificant and in our area there are 16 local planning authorities alone producing strategic plans. To ensure an effective LNP the Government must identify the minimum funding requirements to discharge statutory obligations and implement national policy objectives delivered through an LNP. 2. Impact on NIAs, habitats more generally and on the planning system 2.1. We have focused on establishing the natural capital baseline in the first instance before embarking on nature improvement areas and habitats in general. A key problem is that the Board members do not understand natural capital and its condition in their area, the condition of key ecosystem services, and the state of natural capital goods and benefits. There is also an initial narrow view of nature as being ecological communities and species. To support the LNP we have established a Natural Capital Working Group to establish the natural capital baseline for 8 capital assets and 65 components with the aim to identify priority problems for the LNP Board to focus on and develop its strategy. Natural capital is a new approach and requires Government support to develop a cost effective and efficient method for the LNP to collate natural capital data which is nationally consistent and has local relevance. 2.2. We have selected two landscape scale areas (Trent Valley and Sherwood) to focus on strategic natural capital improvements to support economic growth and health and wellbeing. A team of public, private and third sector is being put together to undertake sensitivity mapping and understand the critical issues for the Trent Valley. In the case of Sherwood Forest we are investigating the opportunity of a regional park to facilitate natural capital and economic improvements. 2.3. Handling of planning issues is a sensitive subject with a board comprising of private, public and non-governmental environmental organisations. We aim to ensure that the LNP delivers real improvement in the area of planning and sustainable development through constructive co-operation and team work with all partners and stakeholders. To ensure that the LNP Board delivers a consistent approach to strategic planning and local planning we produced a planning policy framework and rules and procedure for the Board to handle planning issues [see Appendix 2]. 2.4. With our limited resource and the current lack of available natural capital baseline information we cannot fully discharge the requirement to review strategic plans under the duty to co-operate placed on planning authorities. This could jeopardise the Local Planning Authority’s duty and result in its plan being called in by the planning inspector. As a consequence our LNP, working with County Council Planning Departments, has published a planning holding letter to respond to each request to co-operate [see Appendix 3]. This is not an ideal situation. As a matter of urgency the Government needs to clarify the LNP task(s) to meet the requirement of the Localism Act 2011 duty to co-operate in relation to strategic plans and sustainable development, and ensure that our current position is not jeopardising a statutory duty. 2.5. We have not received any education or training in relation to requirements set by statute. Further we have no standards or processes to evaluate that strategic development plans are sustainable. There is a knowledge and skill gap for LNP to undertake the task to evaluate and advise planning authorities on strategic plans in relation to sustainable development that needs to be addressed by Government and LNPs as a matter of urgency. 2.6. Going forward it is unclear how the LNP will influence strategic plans in relation to sustainable development. Natural capital assets are not always incorporated into strategic plans in a spatial and quantifiable way. Exceptions include minerals and the statutory obligations on mineral planning authorities. Influencing strategic planning can be an effective way for LNPs to improve the stock of natural capital in their area. The LNP has no statutory or non-statutory mechanism through which the protection and/or improvement of all natural capital is incorporated into strategic plans. The most appropriate mechanisms to achieve this must be investigated by Government to ensure national consistency. 2.7. An important issue in relation to the impact of our LNP has been to establish a single, clear, measurable objective. In contrast, the LEPs’ objective can be neatly summed up as ‘Supporting economic growth by bringing private and public sector together’ and LEPs can measure their success in numbers of jobs created. The LNPs have neither a similar, clear objective, nor any indicators with which to measure success. We are developing our strategy and are beginning to formulate a single measurable objective “To measure, maintain and improve natural capital in our local area”. Government needs to articulate a single, clear, measurable remit for LNPs. For example “to measure, maintain and improve natural capital in the local areas” and support LNPs to set key performance indicators to measure success and value. 3. Links and co-ordination with other LEPs, environmental and planning organisations 3.1. Lowland Derbyshire and Nottinghamshire LNP aims to develop productive relationships with the local LEP, the Local Authorities, relevant private sector companies and environmental organisations as well as the Health and Wellbeing Board and Defra family. A diverse LNP Board with top and senior management representation from organisations has helped with developing links and co-ordination. 3.2. We have private sector representation from key sectors relevant to our area which includes: manufacturing (Toyota); construction (David Wilson Homes); mining and aggregates (Lafarge) and tourism (Centre Parcs) Strong private sector representation on our board helps us to engage with the LEP and this is a real asset in our LNP. 3.3. Organisation boundaries don’t coincide with those of the local LEP (which covers Nottinghamshire and all of Derbyshire including the Peak Park) making communication with the LEP more complex than it would be if our borders coincided. Similar border inconsistencies exist for other environmental and planning organisations. The Government should review boundaries between the LNP, the LEP and other organisations to establish if we have the most efficient organisation for planning and partnership working. 3.4. With the removal of regional spatial and strategic plans we must liaise with 16 planning authorities in our area and review 16 strategic local plans in addition to other strategic plans. We do not have resource to liaise with 16 planning authorities on matters of strategic planning or the statutory review of strategic plans. It would be more effective and efficient to carry out all strategic planning at county level as minerals and mining planning is currently done. The Government must review the most efficient way and the role of the County Councils in working with LNPs to evaluate strategic plans with the aim to minimise burden and workload which results from 16 strategic development planning authorities in our area. 3.5. We have worked hard to communicate and promote team working with key Government organisations (i.e. Environmental Agency, Forestry Commission, Natural England, British Geological Survey, Derbyshire and Nottinghamshire County Councils). To ensure long term and effective partnership working the Government must recognise and formalise the working arrangements between key national Government organisations. 3.6. Initially the LNP had strong links and networks with partners concerned with ecological communities and species. More recently we have extended links and networks with organisations with an interest in other natural capital assets (minerals, sub-soil assets, air quality). This has promoted wider engagement and a stronger and more integrated approach to sustainable development. LNP partners tend to focus on green nature (i.e. species and ecological communities). Links with other organisations concerning other natural capital assets such as sub-soil assets, minerals, and air quality, and their economic and social value, are less well represented. In particular links and coordination around air quality is difficult. The Government must promote stronger links and more integrated approach for these natural capital assets, particularly for air quality. Submitted by: Tony Walker, Chair Lowland Derbyshire and Nottinghamshire LNP board Appendix 1 – Lowland Derbyshire and Nottinghamshire LNP Board Appendix 2 Lowland Derbyshire and Nottinghamshire LNP Planning Framework and Rules Appendix 3 Lowland Derbyshire and Nottinghamshire LNP Planning Consultation Holding Letter