The clearest way into the Universe is through a forest wilderness.
– John of the Mountains: The Unpublished Journals of John Muir, (1938), page 313.
In Spring 2019, I was recommended a book by a fellow commuter on the Grindleford-Sheffield train, as we talked about our shared love of plants – particularly orchids. This fellow amateur botanist (and local farmer) recommended “The Orchid Hunter” by Leif Bersweden. It was a lovely read – both a gentle`coming of age` story and a thrilling description of a young man’s attempt to see all 52 known British orchid species in a single year. I couldn’t put it down.
I have always loved orchids, particularly since moving to the Peak District, where the arrival of the Early Purple Orchids signals the start of spring proper. But growing up in the boulder clay areas of north Bolton meant we rarely saw any on the afternoon walks with my mum, who would try to name every flower spotted and encouraged us to learn them `off by heart`. A degree in Botany at Durham University meant focusing on how plants worked, more than field study – but I do remember one astonishing field trip to the Italian Dolomites where we were lucky enough to see Lady’s Slipper Orchid.
Early Purple Orchids, Tansley Dale Southern Marsh Orchid, Old Moor
More recently, a keen interest in bird watching has taken us to many different places, so I’ve also noted Bee Orchids on Maltby Common, near Rotherham, and Southern Marsh Orchids at the Dearne Valley Old Moor RSPB reserve near Barnsley. I got even more excited by a chance discovery of Bird’s Nest Orchids in woodland near Ashford in Derbyshire – made even more memorable because I could share that find with my mum, who happened to be visiting at the time.
Bird’s Nest Orchids, Great Shacklow Woods, Derbyshire
But reading Leif Bersweden’s book made me seriously wonder if I could do the same – not all of them in one year perhaps (that would be beyond my other half’s patience I think) – but see all of them at some point. A holiday to Italy that same year included the Gargano Peninsula – where we saw many orchids and other wild flowers – it is a stunning area. So I will include some of our photos of that trip and others overseas. But my main aim is to see all of the British orchids in Britain. So I have created a page in this blog to record my endeavours.
This blog article is based on my paper produced for the journal – People, Place and Policy. The full article can be read here. The article was written following work with the Countryside Management Association, many of whose members struggle with these issues on a daily basis, and continue to rise to the challenges posed by the government’s austerity measures.
Two significant reports from the Heritage Lottery Fund (HLF) in 2014 and 2016 describe the growing deficit between the rising use of public parks and the declining resources that are available to manage them. Their findings show that while parks are highly valued by the public and usage is increasing, park maintenance budgets and staffing levels are being cut. Their research calls for collaborative action to deliver new ways of funding and managing public parks to avert a crisis. The HLF conclude that “Without urgent action the continuing downward trend in the condition of many of our most treasured parks and green spaces is set to continue” (HLF, 2016). Alongside these concerns, other researchers have established the very wide range of public benefits which parks and urban green spaces provide to society, including health and well-being impacts, as well as many environmental benefits such as carbon sequestration, air pollution mitigation, and biodiversity improvements.
In the face of very public concerns about these growing challenges, the UK Parliamentary Communities and Local Government (CLG) Select Committee undertook an inquiry in 2016 into public parks to examine the impact of reduced local authority budgets on these open spaces. As a result of that inquiry, the CLG Committee recommended the creation of a new Parks Action Group, whose role would be to provide leadership and share good practice within the parks sector. The Parks Action Group was created in September 2017, with members from the Association of Public Sector Excellence (APSE), Fields in Trust, the Local Government Association, the Parks Alliance, Natural England, National Federation of Parks and Green Spaces, Heritage Lottery Fund, Groundwork, National Trust, and Keep Britain Tidy. Their work is ongoing.
Concerns continue to be expressed about the direction of advice and policy from all these organisations. Current central government policy calls for innovative and entrepreneurial approaches to resolving these challenges. This can bring real benefits and creative approaches to parks management, not least in terms of community engagement and the recognition of the wider public services provided by parks. Various welcome funding schemes have been created by lottery bodies and others, to explore new ways of funding and managing parks and share good practice.
Sheffield Hallam’s Centre for Regional, Economic and Social Research (CRESR) is currently evaluating the Parks for People Programme . The Parks for People programme aimed to regenerate public parks of national, regional or local heritage value for the enjoyment and recreation of local people. The programme began in 2006 and was funded by the Heritage Lottery Fund and the Big Lottery Fund. Since 2006, £254 million has been awarded to 135 projects across the UK. Evaluation is an important element of the programme and several reports have been published assessing the impacts of the programme. These show that overall Parks for People is making a positive contribution across all outcomes. The current evaluation being undertaken by CRESR focuses on some specific case studies, in an attempt to obtain more detailed, qualitative information about the programme and its benefits for public parks management and use.
Despite these welcome and much-needed programmes of funding, tensions can still develop as new ways of supporting public park management are sought by hard pressed local authorities. There can be issues of increasing dependency on volunteers and third sector organisations, and the commodification of spaces and the commercialisation of services, even privatisation. Such conflicts may potentially undermine democratic accountability and a sense of community ownership, and potentially threaten the effective management of parks generally. It seems to many practitioners and researchers alike that current UK government policy is moving away from a social welfare model of public parks provision, and that we need to fully understand the impacts of these changes in order to avoid inadvertently reinforcing this approach to public service provision.
Full article (with additional references) published in People, Place and Policy online, Volume 12, Issue 2, December 2018.
Few users of Twitter or Facebook can be unaware of the furore this week surrounding the `banning` of Iceland Foods’ advert for their Christmas promotion, featuring the baby orangutan `Rang-Tan`. When I last looked, a petition to attempt to persuade the body responsible for clearing adverts for broadcast (Clearcast) to reverse their decision and authorise its broadcasting, had been signed by nearly 700,000 people. The animation itself has been viewed on YouTube nearly 4 million times.
The animation is an excellent example of a major food company promoting their own pro-environmental behaviour by advertising their intention to remove all palm oil from Iceland Foods’ own brand products by the end of this year. It is also a clever piece of environmental campaigning – emotionally engaging, identifying both an adorable `victim` and the big, bad `enemy`, and with clear messages about how our consumer behaviour can impact upon biodiversity. It concludes with an excellent, upbeat message to convince us that we can take action, change our behaviour, and make a real difference to our future. It meets all the guidelines on how to undertake a successful campaign (read Chris Rose’s Campaign Strategy web site for an excellent overview).
The use of unsustainable palm oil in so many food stuffs and beauty products is an environmental catastrophe around the world. Greenpeace’s palm oil campaign explains the devastation wrought in countries such as Indonesia and Malaysia. To feed our growing demand for everything from chocolate to cosmetics, tropical rainforests and peatlands are destroyed and re-planted with oil palm plantations. Greenpeace claim that “an area the size of a football pitch is torn down in Indonesia’s rainforest every 25 seconds, with palm oil driving the destruction“. Borneo’s orangutan numbers more than halved between 1999 and 2015 with the loss of approximately 150,000 individuals – “we lose 25 orangutans every day“. These areas are not only vital for biodiversity, they are also essential for regulating the Earth’s climate.
There are many difficulties if you are an ordinary consumer trying to avoid palm oil. It is difficult to identify in lists of ingredients (often given a different chemical name) and it has become almost ubiquitous in many of these products. But palm oil does not need to be obtained in such a damaging way. Greenpeace are targeting some of the biggest brand names and users of palm oil (such as Mars, Unilever and Nestle) in an attempt to persuade them to source their palm oil from sustainable sources. They believe that only by customers – us – voicing our concerns and taking our purchasing power elsewhere will these major users of palm oil change their current practices. They have therefore aimed their campaign at these major brands and food companies such as Iceland Foods.
A complete boycott of palm oil is not necessarily the way forward. The International Union for the Conservation of Nature have just produced a report on the issue, and they conclude that boycotting palm oil completely would mean that other types of vegetable oil would be used to meet global demand – and that could actually make matters worse. The IUCN state that palm oil crops yield four to ten times more oil per unit of land, and require far less pesticide and fertiliser, than some of these other sources. In fact, palm oil makes up 35% of all vegetable oils, grown on just 10% of the land allocated to oil crops. So, if other crops such as soybean replaced a shortfall in palm oil, this would not only shift more production to the Amazon (a major soy-producing region), it would require more land and lead to more deforestation. As with many of these issues – the problem is far more complex than we might think.
Certification – a system which ensures consumers know they are paying for more responsibly sourced products – is one way to help safeguard rainforests, and the wildlife which lives in them. Palm oil certification is spearheaded by the Roundtable on Sustainable Palm Oil (RSPO), who are leading the market toward environmentally and socially responsible palm oil that doesn’t contribute to deforestation. Many organisations, including Greenpeace, support this approach (and Iceland Foods have confirmed they also support this campaign).
The public have responded massively to the Iceland Foods’ advert in the last few days. There is outrage that these efforts to save nature in some of our most threatened habitats have been deemed `too political` to broadcast. The advert has been compared to the more traditional Christmas adverts – largely aimed at getting us all to spend-spend-spend, and the latter have been found wanting (and – you might argue – even more `political`, as such adverts clearly reinforce a capitalist view of our society). Can we not have a Christmas message which actually reinforces the need to care for the planet and take responsibility for our actions?
However, the reasons for the apparent `ban` are not so clear cut. Writing on Clearcast’s own blog site, their Managing Director, Chris Mundy, has defended their decision. He explains that the decision was not based on the topic of unsustainable palm oil use and the impact of deforestation on biodiversity, but on the fact that the animation was originally made by an environmental campaigning organisation, Greenpeace, and used by them this summer to front their own campaign against unsustainable palm oil use. Mundy explains that this contravenes broadcasting rules set out in the UK Code of Broadcast Advertising (BCAP), because they have judged it is “an advertisement which is inserted by or on behalf of a body whose objective are wholly or mainly in the political arena” (Section 7 of the BCAP).
Mundy also adds that it is not the role of Clearcast to `ban` adverts. That is the job of the Adverting Standards Authority and, in the case of political ads, Ofcom. Clearcast just work with advertisers and broadcasters to ensure the BCAP rules are followed.
I have to admit here that I am not a media lawyer, and when it comes to broadcasting regulations, I am just an ordinary member of the public. But we have all seen other TV advertising by environmental campaigners, such as the WWF, and charities such as Shelter and Oxfam (I appreciate the BCAP explicitly excludes party political broadcasts and government public service adverts from this ruling). The media web site Campaign highlights the “bold” WWF advert just released for this Christmas, which “issues a rallying cry to fight for our planet in light of new research revealing a dramatic drop in wildlife population“. All credit to the WWF, but this seems to be a very similar approach to the Greenpeace animation, and in this case it is quite explicitly in support of a similar organisation.
There is also no mention of Greenpeace in the Iceland Foods version of the Rang-tan animation. I imagine most of the 4 million people who have viewed the advert had no idea this had originally been produced for them. When Greenpeace used the animation in the summer, it concluded with a direct `call to action` to sign a Greenpeace petition. But the Iceland Foods’ version concludes with the company’s own decision to remove palm oil from their own brand products (until they can source it sustainably). The animation is clearly linked to an Iceland Foods’ business decision and not to any other organisation’s name. It does beg the question as to whether companies are allowed to use other well-known images if they wish to align themselves to particular environmental actions. Images such as polar bears on melting icebergs, sea turtles eating plastic waste, or even the `blue marble` image of the planet Earth (captured 45 years ago by Apollo 17), have become ubiquitous images used by many environmental campaigns. Maybe these images are also `too political`?
So – while I can see that the board of Clearcast have had to draw a fine line somewhere – I still do not understand why they chose not to authorise this particular advert for broadcasting. Even more alarmingly, it is also difficult to see who we should complain to if we don’t agree with a particular decision by Clearcast.
Iceland Foods are to be applauded for leading the way in their attempts to remove palm oil from their own brand products. I imagine they are also very pleased with the results of this particular campaign. The level of engagement by the public with the advert on social media is extensive, and they can now include campaigning messages highlighting their environmental credentials in much less contentious adverts (which I presume Clearcast will authorise for broadcast). I hope that other major companies will see this public support and advertising success, and increasingly appreciate that there is a real market out there for environmentally responsible products. Rang-tan certainly won’t be forgotten quickly (cuddly toy for Christmas anyone?).
On 30 November, 2017, I attended a Westminster Briefing Workshop, with colleagues from the Countryside Management Association. This is a brief summary of that event, with some personal reflections .
This workshop was aimed at parks and urban greenspace practitioners and promised to explore good practice in funding and management, as well as an update on recent government initiatives in the sector.
Ian Leete (Local Government Association) provided a good overview in his opening address. He emphasised the decline in green space funding, confirming that local authorities faced a funding gap of £5.8 billion by 2020 due to government austerity measures (a loss of 75p in every £1 of core funding). But Ian also emphasised the growing recognition of the importance of parks and green spaces across a wide range of public benefits. The CLG Committee’s The Future of Public Parks Report1 lists many of these, including health and well-being, community cohesion and identity, local economy and active travel, biodiversity and access to nature, as well as increasing climate and flood resilience. Their consultation on parks attracted many thousands of responses. They can have been left in no doubt as to the importance of these places to a very wide range of people.
The CLG Committee’s report concluded with 16 recommendations, many of which covered well-trodden ground. But the recommendations also included a wide range of actions encouraging local authorities to look beyond public funding to initiatives such as independent trusts, private sector investment models, and funds from the health sector. They also recommended the creation of a new Parks Action Group, whose role would be to provide leadership and share good practice within the parks sector. The Parks Action Group has now been created, with members from the Association of Public Sector Excellence (APSE), Fields in Trust, the LGA, the Parks Alliance, Natural England (our own Dave Solly), National Federation of Parks and Green Spaces, Heritage Lottery Fund, Groundwork, National Trust, and Keep Britain Tidy – but we are yet to hear any specific news about their work.
Some of the most interesting information provided by Ian Leete was on a Natural Capital valuation study2 undertaken in London. This has established that for every £1 spent on green spaces, Londoners benefit by £27; that Londoners avoid £950 million per year in health costs because of parks; and that the value of parks’ recreational activities is estimated at £926m per year. However, how these types of valuations can be then turned to increasing private investment in the basic infrastructure and associated services was not so easily answered.
Dave Morris (Chair, National Federation of Parks and Green Spaces) provided his usual inspiring talk about the benefits of involving local communities and Friends groups. But he also had a warning – such groups need support – to build confidence and capacity – they are not a panacea for funding crises.
Helen Griffiths (Fields in Trust) talked about the work of this long established body (established in 1925 as the National Playing Fields Association). 2732 parks and green spaces across the UK are now specially protected through their `Deed of Dedication`. Helen also reinforced the wide range of public benefits arising from these green spaces. Helen mentioned another useful report from APSE3 which paints a bleak picture for publicly funded services. Of the parks professionals who responded, 95% either “agree” or “agree strongly” that the lack of investment in parks and green spaces will have health and social impacts. Their report also highlights a growing trend in the use of parks as festival and event spaces. This is one indication of the attempt to grow income generation from urban green spaces, and can of course have both community benefits, but also real challenges.
Fields in Trust are publishing their own research report shortly, “Revaluing Parks and Green Spaces: Establishing the Economic and Wellbeing Value“, which will attempt a robust economic valuation of parks and green spaces. Figure 1 includes some of the headline findings from this report. But, as Helen herself concluded, the collection of evidence alone is not sufficient unless it is used to inform long-term strategic decisions to recognise the full value, and invest now in securing our parks and green spaces in perpetuity.
Figure 1 – Headline Values of Parks and Green Spaces (Fit for the Future, 2018)
Alan Carter (The Land Trust) explained their model of managing and investing in parks in perpetuity. The Trust is an independent charity, governed by a board of trustees (with a remarkably similar membership to the new Parks Action Group) managing over 60 green spaces around the country. Alan also emphasised the wide range of benefits arising from well managed green space (is there a pattern developing here?), as well as the importance of partnership working, community engagement, and long term investment. The range of funding streams mentioned was helpful, and included: service charges from residential or commercial properties; endowments; section 106/Community Infrastructure Levy; operational income; commercial use of sites, e.g. private events; onsite charges, e.g. car parking, concessions; rental income, e.g. grazing licences; and third party grants, e.g. English Woodland Grant scheme, Landfill Communities funding.
Alan felt the Land Trust model particularly benefitted communities – particularly those considering taking on legal ownership of parks themselves, as this could often be too burdensome. He also provided some interesting examples of working with the private sector – at the Port Sunlight River Park, Wirral, working with Biffa Waste; and Beaulieu Park, in Chelmsford, working in partnership with Countrywide Properties, where long term investment in the green infrastructure has been secured through a service charge model.
Figure 2: Beaulieu Park, Chelmsford (The Land Trust)
All the points from the Land Trust and Fit for the Future were well made, and of course there are many other trusts and social enterprises who are achieving great things in parks and green space management. But over lunch time, many of us, from both local authorities and NGOs, were left wondering if the latter are really able to cover the funding gap in core public sector funding. Will we not all be trying to do the same thing and competing for the same, limited resources?
Paul Todd (Green Flag Award) provided an excellent overview of the Green Flag awards and their significance in establishing and celebrating excellence in green space management. Finally Paul Rabbitts (Head of Parks, Open Spaces & Projects, Watford Borough Council) completed the formal sessions with his sometimes humorous, sometimes bleak – but always inspiring, discussion around the role of the park manager. Paul demonstrated how he had lived through all the various reincarnations of the role – from horticultural supervisor to multi-tasking manager and innovator. He warned about the loss of many traditional skills, but was also encouraging about the new role. He had some headline take away messages – we need to keep reminding people that we are `parks` people, and we need better careers pathways. But the sector also needs champions – particularly within government. He also suggested a new professional body might be needed (perhaps something for CMA to reflect upon?). He concluded by emphasising the importance of a strategic vision, exploring all options to maximise investment, and ensuring a future for all our parks and green spaces – something we could all agree upon.
- Communities & Local Government Committee (2017), The Future of Public Parks, https://www.parliament.uk/business/committees/committees-a-z/commons-select/communities-and-local-government-committee/inquiries/parliament-2015/public-parks-16-17/
- Greater London Authority, National Trust & Heritage Lottery Fund (2017) Natural Capital Accounts for Green Space in London, access on line at https://www.london.gov.uk/what-we-do/environment/parks-green-spaces-and-biodiversity/green-infrastructure/natural-capital?source=vanityurl .
- APSE (2018) Local Authority Parks and Green Spaces Services, http://apse.org.uk/apse/index.cfm/members-area/briefings/2018/18-11-state-of-the-market-2018-local-authority-parks-and-green-spaces-services/ .
Here is a copy of our Department of the Natural and Built Environment’s Annual Research Review for 2016-17 – DNBE Research Review 16-17 – final merged–
One of our main aims in the Department of the Natural and Built Environment is to work with local groups to enhance landscapes and biodiversity, and improve people’s enjoyment of these places. One of the ways we do this is through our research and consultancy work.
Recently, Professor Ian Rotherham and myself joined colleagues in SHU’s Outdoor Recreation Research Group to support the work of an exciting, new landscape project in Sheffield. The Sheffield Lakeland Landscape Partnership (SLLP) is funded by the Heritage Lottery Fund as part of its national landscape partnerships programme, and is hosted by the Sheffield and Rotherham Wildlife Trust. The project offers a unique opportunity to manage the area’s natural and built heritage as one, with a common vision – on a landscape scale and for more people to enjoy.
This area of North West Sheffield is an outstanding example of a living landscape – rich in history, abundant in wildlife, vibrant communities and strong traditions. It is dominated by fast flowing rivers which rise off the Peak District moors and tumble through steep sided valleys to meet up at the city of Sheffield. These rivers powered the early years of the industrial revolution, and the reservoirs they feed now provide drinking water for the city’s growing population and much-loved places for recreation.
Sheffield Lakeland Landscape Partnership area
The name of the project comes from a programme of tours, developed in the 1950s, by a Sheffield bus company, drawing inspiration from the numerous reservoirs which define the area. Sheffield’s Lakeland Tour
The partnership is hoping to create a more natural and resilient landscape for everyone to value, understand and enjoy. To do this, it needs to balance the needs of wildlife, agriculture, forestry and recreation, and support a landscape which provides clean water and air, helps to reduce flooding, and benefits the health and wellbeing of communities within the Lakeland area and in the city.
In 2017, SHU’s Outdoor Recreation Research Group was commissioned by the SLLP to undertake an Access and Gateways study; to provide visitor information for the project, and develop priorities for enhancing recreation and people’s enjoyment of its rich cultural and natural heritage.
Working with colleagues in the Faculty of Health and Well-being, our study involved the gathering of primary and secondary data for the SLLP project, as follows:
- An assessment of nationally available data from Natural England and the Ordnance Survey to apply to the local area, identifying visitor trends and potential growth areas.
- Over 1000 people in the area were surveyed through on-site surveys, a local residents’ questionnaire, and an on-line survey, to explore current interests and the potential for new uses.
- Community groups and other stakeholders were interviewed, to gain an understanding of the detailed knowledge local people already have about the area, particularly its cultural and biodiversity value.
- Community workshops were held in Sheffield and in local villages, to discuss ideas for further development.
Our conclusions identified some emerging priorities for the SLLP:
- People already visit and enjoy the reservoirs, hills and river valleys of this part of Sheffield. But people also wanted more information about where to go and what to do, and to better understand the natural and cultural heritage of the area.
- Many individuals and local groups have already undertaken much recording and sharing of the history and stories associated with the local landscape.
- The SLLP project can build on this existing knowledge, to form a basis for increased interpretation and enjoyment by local people and visitors to enable a broader range of people to enjoy this sense of place and its connection to the wider city of Sheffield.
- Our specific recommendations include: a community based project to capture and utilise existing knowledge about local heritage; increased information and interpretation provision; and access improvements associated with visitor hubs and community gateways.
Our full report can be read on the SLLP web site, and our recommendations have been incorporated into a bid to the Heritage Lottery Fund, to unlock a further £2.8m for natural and cultural heritage improvements in this part of Sheffield. We hope to hear in the autumn 2018 if the bid has been successful and if further work can develop to support landscape, cultural and biodiversity improvements in this part of Sheffield. We are also hoping that further research work – by both staff and our students – will provide more support for this exciting project.
National Parks include some of our most beautiful and inspiring landscapes. Covering nearly 10% of England, they make a huge contribution to the economy – tourism in English National Parks contributes £4bn a year – as well as playing a vital role in protecting and enhancing natural and cultural heritage. These areas have the highest level of planning protection, yet this does not always prevent damaging major development from taking place in, or close to, National Parks.
Stanage Edge, Peak District National Park (photo – Howard Crowe)
The Department of the Natural and Built Environment, Sheffield Hallam University, were asked to undertake this research project, funded by the Campaign for National Parks, the Campaign to Protect Rural England (CPRE), and the National Trust, over the summer of 2016. We were asked to investigate the interpretation and application of the so-called ‘major development test’ (the test) in National Parks in England and Wales. My fellow lead researcher, Dr Cate Hammond and I have a long-standing interest in the protection of our National Parks, and we were ably supported throughout the project by one of our postgraduate students, Nikky Wilson.
We were asked to respond to concerns that despite the test being an integral part of the 2012 National Planning Policy Framework (NPPF), this does not always prevent damaging major development from taking place in or close to our National Parks. Our clients wanted us to investigate the effectiveness of the planning protection given to National Parks in England and Wales in relation to these major schemes.
The full report of our main findings can be read on line at http://www.cnp.org.uk/SHU-planning-research.
This is the current wording of the relevant paragraph in the NPPF (the test is slightly different in Wales):
“116. Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest. Consideration of such applications should include an assessment of:
- the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
- the cost of, and scope for, developing elsewhere outside the designated area, or meetinthe need for it in some other way; and
- any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.”
The test has been amended several times since it was first introduced in 1949 (then known as the ‘Silkin test’). Perhaps the most significant changes were actually made by William Waldegrave in 1987, when National Park Authorities (NPAs) were first required to consider the impact of approving or refusing a scheme on the ‘local economy’. Our research has shown that reference to the ‘local economy’ is a significant factor in the approval of major development applications.
We evaluated major development policies in the Local Plans of all NPAs in England and Wales. This demonstrated that there was significant variation in both the definition of major development and NPAs’ interpretation of existing policy. The definition of major development perhaps seems a fine legal point, but it can have significant impacts on the implementation of the test. A legal opinion provided by James Maurici of Landmark Chambers in 2014, emphasises that the definition of major development in relation to the test is a matter of planning judgment to be decided by the individual NPA. Importantly, national significance or absolute scale is not mentioned, but the severity of the impact on a National Parks’ special qualities is paramount.
We investigated the implementation of the test by searching NPAs’ planning portals to examine over 70 individual cases, and then a more detailed examination of fifteen selected case studies. We also undertook interviews with senior NPA planning officers and received comments from National Park Societies, National Trust planning advisers and CPRE local groups.
We are extremely grateful to all those NPA planning officers who gave up their time and local group members – often working as volunteers – who provided us with a rich background to many of the individual planning cases. We came to fully appreciate the size and complexity of these cases. Many local group members commented on their admiration of National Park officers dealing with such time consuming schemes. The research also identified many examples of good practice which we hope will be promoted widely amongst all the NPAs.
Our main findings suggest that the existing test is generally well supported by NPAs. It is not the actual wording of the test which causes any significant issues. As one local group member commented to us “the policy would have been sufficient to turn down xxx application, had they wanted to”. However, there is strong support for more guidance on the interpretation of some of the terms in the test, such as ‘public interest’ and ‘exceptional circumstances’.
Although the current wording of the test in the NPPF is weaker than the original Silkin test, the most recent changes do not appear to have had any significant impact on decisions. Local and national decisions continue to reflect central government’s agenda at any particular time, and also the continuing challenge of supporting National Park purposes whilst allowing local economic development. Enabling the sustainable development of local communities whilst ensuring National Parks’ primary purposes to protect and enhance these special landscapes for everyone to enjoy, remains the challenge at the heart of these complex cases.
As a result of our main findings, the CNP, CPRE and the National Trust have published a series of recommendations aimed at both National Park Authorities and the English and Welsh Governments. These include:
- Government should reconfirm its commitment to National Parks in the forthcoming 25 Year Plan for the Environment by clearly stating how they will ensure their long-term protection and enhancement.
- National Park Authorities should ensure their local plans are clear about how the major development test should be applied in relation to the special qualities of the National Park in order to help reinforce and support local decision-making.
- The Government should make it clear that the duty to ‘have regard’ to National Park purposes applies to developments in the setting of National Parks. Ministers should also emphasise that this duty applies to all public bodies, including neighbouring planning authorities, the Planning Inspectorate and bodies such as Local Enterprise Partnerships and Combined Authorities. This should be addressed by a Ministerial Statement.
- The Government should ensure that developers are aware of the additional planning protection afforded to National Parks and encourage them to engage with local planning authorities at an early stage when considering any development in, and just outside, National Parks. This should also be addressed by a Ministerial Statement.
- Natural England should take a more active role in ensuring that National Parks are effectively protected from major development. This should include producing an annual update setting out how the major development test is being implemented and providing guidance or training for NPAs to address any issues identified. Government should support Natural England to fulfil its statutory responsibilities for designated landscapes.
- To ensure that the many sensitive and important areas for biodiversity and wildlife in National Parks can be safeguarded, it is essential that protections for nature are maintained after the UK leaves the European Union.
We hope our research has helped our clients’ work to provide the highest levels of protection for these designated landscapes.