9th April 2015
Alun Ffred Jones AM, Chair
c/o The Committee Clerk
Environment and Sustainability Committee
National Assembly for Wales
Cardiff Bay
CF99 1NA
Annual Scrutiny of Natural
Resources Wales
Thank you for this opportunity to comment. We do have
concerns, particularly regarding the operation of NRW in their role
as statutory consultee for Welsh planning applications.
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It seems clear that the central
purpose of NRW, not least as reflected in public statements by the
chairman, Peter Matthews, is the promotion of the exploitation of
Wales’s natural resources and creation of a ‘new
economic model’. In the pursuit of this
objective there is the danger that the fact that rural Wales is a
great deal more than a fund of resources to be tapped is
overlooked. For a great many of us rural Wales is our home, where
we have chosen to live, to work, to raise families, to take our
holidays and walk or ride the hills, and we love the landscapes
around us. For those of us involved in any form of tourism the
rural landscapes are also our bread and butter, critical to our
livelihoods. A body which exists to promote development has a clear
conflict of interest when it also responsible for safeguarding
landscape and biodiversity. The existing rural ‘economic
model’, containing many diverse and creative enterprises,
must not be jeopardised by insensitive development or an
overarching agenda for development at any cost. Those of us living
in rural areas may not even agree that we need a ‘new
economic model’ or that our interests should be sacrificed to
someone else’s ‘new economic model’. Exploitation
of natural resources which does not give full consideration to
needs of rural communities and existing businesses, including
protection of landscapes, will cause untold damage to rural life
and the rural economy.
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Linked to the above point is the
diminution of NRW’s role as statutory consultee for Welsh
planning applications in relation to landscape. Worse, there seems
to be a lack of clarity which is allowing councils to believe that
a lack of objection from NRW on landscape grounds to an application
is sufficient for the council to assume that landscape impacts are
acceptable. This confusion is not helped when NRW fail to state
clearly the limits of the advice given or the precise remit to
which they are working. NRW advice on Powys application P/2014/0860
exemplifies the potential for confusion.
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There are councils which do not have
a landscape officer to take over the role of statutory consultee on
landscape so this retreat from an active landscape role in the
planning system on NRW’s part is creating a democratic
deficit and a lack of attention to landscape issues. Clarity is
needed for councils to understand the way in which they must adapt
their own structures and practices to fill the gap NRW has created.
At the same time NRW could be more active in promoting the
consistent use of Landmap data, and application of Landmap
guidelines, to ensure consistency of decision making and evaluation
of landscape impacts across Wales.
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There is a further source of
confusion concerning NRW’s role as statutory consultee on
ecological matters. Where councils have their own well qualified
and experienced ecologists it is not necessarily helpful to
ecological interests to have two sources of potentially conflicting
advice. There needs to be far greater clarity as to where the
council’s responsibility ends and NRW’s begins. I have
only just now attended a planning committee meeting in Powys where
not only the planning committee but also all the officers appeared
to have no understanding of the respective responsibilities of NRW
and the council’s own ecologist.
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There is great concern in Powys about
the deterioration in the water quality of our rivers. To some
extent this can be laid at the door of NRW who have a policy of not
addressing cumulative issues when smaller scale intensive
agricultural units are applied for. These, particularly in the form
of chicken sheds, have been applied for in great number in Powys,
and so with considerable cumulative impact, and there is now a
serious problem with water contamination (soluble reactive
phosphates) both within Powys and downstream on the Wye. It is
disappointing that a government organisation which must have
inherited from its predecessor bodies a great deal of scientific
expertise and experience has allowed a situation such as this to
arise or to worsen under its watch. It may again be that a policy
of promoting development is at the root of this problem, and that
the impacts of development have been insufficiently assessed and
monitored.
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Finally, I am aware that the issue of
deterioration of river water quality was known as far back as 2012.
Radnorshire Wildlife Trust, and I doubt they were alone in raising
this concern, were even then advocating greater controls on
intensive agricultural developments. However, NRW, despite having
effectively been in operation for a couple of years, has failed to
respond to these concerns and react effectively to prevent the
worsening of the situation.
This is our personal response to the
consultation. We do not object to publication.
Yours sincerely
Margaret and Iain Aitken