Secure a Future for our Landscapes – respond by 30th September

_DSC long triple

Images: Mike Alexander 

Welsh Government is consulting NOW – please act swiftly to ensure that our National Parks and AONBs retain the protection they need.

Welsh Government has a live consultation on ‘Taking Forward Wales’s Sustainable Management of Natural Resources’*.  The consultation covers diverse environmental issues.  Some of the proposals are detailed whilst others are broad and general.  Many of the proposals are positive.

Chapter 3 focuses on designated landscapes – National Parks and Areas of Outstanding Natural Beauty.  Wales has three stunning National Parks – Snowdonia, Brecon Beacons, and Pembrokeshire Coast – and five wonderful AONBs  – Wye Valley, Gower, Llŷn Peninsula, Anglesey, Clwydian Range and Dee Valley.  We all know how unique and irreplaceable these landscapes are.  Keeping them that way doesn’t happen by magic.  It comes from decades of work, applying the available tools to their active care and protection.  That work must be continued regardless of the latest trends in policy.

The problem with the proposals in this section is that they draw directly on the ‘Future Landscapes Wales’ report.  This report is causing serious concern across the spectrum of landscape and nature conservation organisations.  Some of these concerns are detailed here: Alliance position paper on Future Landscapes report FINAL

Speak up for National Parks  – before 30th September

It is vital that Welsh Government receives a clear response to the Designated Landscapes section of this consultation*.   According to the International Union for the Conservation of Nature, the Future Landscapes report, if implemented, would threaten the international status of National Parks in Wales.

Welsh Government is more likely to listen if people like you speak up to represent the many – people, businesses, and organisations – who value and depend on our designated landscapes. The message to Welsh Government needs to be clear – that the first precaution of intelligent tinkering is to keep all the working parts.  In National Parks that means keeping the tools and mechanisms for protection which have proved their value. Those tools include the important Sandford Principle Appendix 2 Sandford commentary

We applaud Welsh Government’s ambition to lead the world on environmental legislation, but on the issue of designated landscapes there is a need to go back to basics.  Proposals for change need to be based on evidence and reasoning – both are lacking from the Future Landscapes report.  Otherwise there is a risk of condemning our designated landscapes to an insecure future, out of step with the rest of the world.

*You may also want to respond to other sections of the consultation eg Access (Chapter 4); we recommend Ramblers Cymru or British Mountaineering Council for info on that section.

How to have your say:

  • Download this template**

    Response to SMNR consultation chapters 1,2 and 3

  • Add in your name and email address.
  • Send it to naturalresourcemanagement@wales.gsi.gov.uk 
  • Include in the subject line of the email Response to consultation ‘Taking Forward Wales’s Sustainable Management of Natural Resources’

If you prefer, you can send by post to: Natural Resources Management Team, Welsh Government, Cathays Park, Pillar J08, East Core, CF10 3NQ

**The template  is based on work by the Alliance for Welsh Designated Landscapes which brings together organisations active in Designated Landscapes in Wales, and Wales Environment Link.

We don’t have much time; please act by 30th September

_DSC1054 s DSC_1262 s

 For background on concerns about the Future Landscapes process and report see also:

Alternatively you can use the following points in constructing your own response to Chapter 3 of ‘Taking Forward Wales’s Sustainable Management of Natural Resources’

Proposal 6 & Question 11 

Aligning the statutory purposes of designated landscapes solely with the sustainable management of natural resources (SMNR) is not the right way forward. Instead of a blanket alignment, a more rigorous analysis should be undertaken to inform where alignment would be helpful, and whether there would be any unhelpful or unintended consequences.

In 2014 the Minister for Natural Resources commissioned an independent panel to conduct a review of designated landscapes in Wales chaired by Professor Terry Marsden of Cardiff University with John Lloyd Jones and Dr Ruth Williams as members.  Professor Marsden’s report, published in October 2015, made 69 recommendations on purposes, principles, vision, governance models, planning and funding. These were the product of wide consultation, systematic evaluation and structured, logical reporting and were widely supported. The Marsden report offers a clear way forward on how the sustainable management of natural resources can be taken forward in designated landscapes.  Welsh Government should adopt this approach as a strong basis on which to move forward to deliver the sustainable management of natural resources across 25% of the land area of Wales.

The principles of SMNR as set out in section 4 of the Environment (Wales) Act[1] are general principles for management. They are not purposes of designation and nor could they be comfortably aligned as such. It is difficult to understand exactly what Welsh Government envisages by the proposed alignment, as the proposals in the ‘Future Landscapes Wales’ report are so vague, but the risks of moving away from a coherent framework to something so undefined are potentially very serious.

In designated landscapes the sustainable management of natural resources can and should be based on interlocking purposes as recommended by the Marsden report, along with a clear protective conservation principle and a strengthened duty on public authorities.

The UK Assessment Panel of the World Commission on Protected Areas consists of a number of leading UK experts in protected areas. It was set up in 2012 in order to determine which areas in the UK met the IUCN’s international standards for a protected area.  Significantly, the Panel has concluded that, if acted upon, the recommendations in the Future Landscapes Wales report “would make it impossible for the panel to continue to accord international recognition” to Wales’s National Parks and AONBs as protected areas. Such an outcome would undermine the statutory Wellbeing goal of a ‘globally responsible Wales’.

The most startling omission from the Future Landscapes Wales report is an ultimate safeguard for natural beauty and biodiversity, with a resultant risk that they may be diluted or eroded.  The Sandford Principle is a fundamental pillar of National Parks and provides legislative priority for the first National Park purpose in cases of irreconcilable conflict with the second purpose. It was endorsed by Welsh Government as recently as 2013 and was a significant factor in the IUCN’s decision to continue to recognise National Parks and AONBs as Category V protected areas.

The Marsden report recommended that the Sandford Principle should be applied across all designated landscapes and that any changes to purposes should uphold the Sandford Principle, giving priority to the first (conservation) purpose if there were irreconcilable conflicts. This priority, alongside the interlocking purposes, was called the ‘Sandford Plus’ approach.

No rationale has been given in the Future Landscapes Wales report as to why there is felt to be no place for a Sandford-style conservation principle in a set of principles for natural resource management.

 

Proposal 7 & Question 12

It is virtually impossible to understand what is meant by Proposal 7 and what form Welsh Government envisages the “clear formal relationship” between the special qualities and partnerships, powers and policies would take.  There is no basis for the suggestion on page 31 of the consultation document that a ‘contemporary interpretation’ of the special qualities is not explicit or widely understood. The qualities listed such as biodiversity and cultural heritage are already reflected in the statutory purposes and in many policy documents.

Welsh Government has recently taken welcome action to strengthen the duty on public authorities with respect to biodiversity. Welsh Government should now significantly strengthen the current duty to ‘have regard’ to the purposes of designated landscapes. A strengthened duty would strengthen the partnership approach which underpins the sustainable management of natural resources.

The Future Landscapes report confuses ‘special qualities’ with ‘natural resources’; in practice the two are very different.  Special qualities are characteristics which reflect or are unique to a designated landscape, for example the sweeping grandeur of the Brecon Beacons, the sandy, unspoilt beaches of the Gower and the wildlife-rich oakwoods of Meirionnydd in Snowdonia. Special qualities require special, targeted measures for their management and are in many cases the reasons why people visit these special landscapes.  Natural resources, as defined in the Environment (Wales) Act 2016 are more generic and include animals, plants, air, water, soil and minerals. The sustainable management of natural resources requires an approach framed by a set of general principles.

Conflating special qualities with natural resources would be a backwards step and must be avoided. It risks diluting the special management approaches needed to sustain the special qualities of designated landscapes.

One of the most effective ways to give greater weight to special qualities in decision making would be to issue a renewed commitment to the role of National Park Authorities as planning authorities. NPAs set the policy framework through a Local Development Plan and determine all planning applications.  The most recent independent evaluation of NPA planning services[2] found that the planning system works well in National Parks, with many examples of good practice and good performance in relation to national indicators for planning service delivery. The Marsden report found the case for removing planning powers from the NPAs unpersuasive and largely based upon perception and dated examples that did not reflect contemporary experience. These points are not acknowledged in the Future Landscapes Wales report or the consultation document.  Sustainable management of these special areas requires that NPAs have responsibility for both planning and management responsibilities.

 

Proposal 8 & Question 13 

Whilst the good governance principles listed on page 32 of the consultation document are worth supporting, there is no convincing case for the introduction of a wider range of local delivery models for designated landscapes.  After careful consideration, the Marsden concluded that “the overwhelming body of evidence cautions against tearing down the current structures”.

Future Landscapes Wales governance proposals are poorly written and fail to provide clear and unambiguous recommendations. The use of abstruse language means that much of the report is open to multiple interpretations, making it difficult to move forward with certainty.

There is no traceability to many of the recommendations of the Marsden report, despite the working group being explicitly tasked with considering these. The Marsden recommendations were the product of wide consultation, systematic evaluation and structured, logical reporting. They offer a clear way forward on the governance of designated landscapes.

In contrast, the Future Landscapes Wales report lacks clarity on governance, calling instead for the current models of governance within a designated landscape ‘to evolve, informed by core principles, to reflect changing needs and opportunities’ and include ‘a wide range of delivery and partnership models, encompassing shared or delegated responsibilities, linked to a common vision.’ It is difficult to comment usefully on such vague wording.

These proposals introduce an unhelpful degree of uncertainty as it potentially re-opens debate on issues which have been considered and dismissed by subsequent independent reviews of governance models.

There is cause to welcome the proposal in the consultation document to focus efforts on ensuring National Park Authorities are providing effective leadership rather than increasing the cost and complexity of administration through direct elections. However, this appears to contradict with proposal 8 that governance arrangements need to evolve. The Future Landscapes Wales report on one hand seems to accept the conclusion of all other recent reviews, including the Marsden report, that the governance of designated landscapes is operating effectively, whilst at the same time appearing to suggest that it is not content with governance arrangements, but without providing any evidence on this.

Welsh Government should use this consultation as an opportunity to draw a line under the years of speculation which National Parks in particular have faced on their future powers and governance, allowing them to move forward with renewed certainty.

A welcome proposal is that to remove National Park Authorities from the improvement regime of the Local Government (Wales) Measure 2009.  All public bodies must be transparent and accountable.  However, the current reporting burden on NPAs is disproportionate in terms of their size, staff complement and financial budgets.  A single unified reporting process based on the National Park Management Plan would be clear and cost-effective and would have the added benefit of not needing legislation to proceed.

 

Proposal 9 & Question 14

Recognition of other areas of Wales for their special qualities or the sustainable management of natural resources must complement the existing National Parks and AONBs and must not duplicate, undermine or divert resources away from them.

Welsh Government’s commitment to explore ways in which new areas might be recognised for their special qualities and their sustainable management has some merit.  However a number of issues would need to be addressed to take this proposal forward, demanding that Welsh Government revisits what it is seeking to achieve through this proposal. New legislation at this stage would be both unnecessary and premature.

Clarity is needed on how existing and proposed designations would relate to each other. New designations could prove a distraction from the challenge of delivering sustainable management of natural resources across the whole of Wales.  Care also needs to be taken to avoid confusing terminology – for example, the term ‘designation’ has statutory implications, whereas elsewhere in the consultation it seems that Welsh Government is seeking flexible local approaches that may not require a statutory basis.

 

 

 

 

Comments are closed.