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.
- 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.
- 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.
- 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.
- 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.
- 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.
-
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