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Consultation on the English National Parks and the Broads: Draft Circular - revised version combining Circular 12/96 and Circular 125/77 (Defra)

05 February 2010

Dear Ms Blandford

Consultation on the English National Parks and the Broads: Draft Circular – revised version combining Circular 12/96 and Circular 125/77.
Vision for National Parks: Government priorities

A response from the Association of Local Government Archaeological Officers:England (ALGAO:England)

The Association of Local Government Archaeological Officers:England (ALGAO:England) is part of the over-arching ALGAO:UK. ALGAO:England is the national body representing local government historic environment services on behalf of County, District, Unitary and National Park authorities in England. ALGAO:England co-ordinates the views of English local authority members (94 in total) and presents them to government and to other national organisations. It also acts as an advisor to the Local Government Association on historic environment matters.

The Association would make the following responses to the above consultation document (any reference to National Park authorities includes the Broads Authority):

General comments:

  1. ALGAO welcomes the draft Circular and the emphasis it gives to the importance of the cultural heritage as a critical component of National Park landscapes, in particular Paragraphs 31 and 70.
  2. ALGAO acknowledges that the focus of the Circular is on National Park authorities but considers that greater emphasis should be placed on the contributions that others make towards achieving National Park purposes. For example, while the apparent ambition for National Park authorities with regard, in particular, to their socio-economic duties, goes beyond legislative requirement, the obligations towards others with regard to National Park purposes and duty appears to be restricted to minimal compliance with legislation. Thus imbalance should be rectified.
  3. While the relative brevity, readability and strategic direction of the draft Circular is welcomed, there are some anomalies in the use of language in this draft when compared with that used in statute and policy documents that need to be rectified.
  4. Similarly, there are welcome references throughout the consultation document to the key special qualities of National Parks – their landscape biodiversity and cultural heritage – and their importance. On occasions, this drops to two and it is often cultural heritage that is omitted (for example, Paragraph 71 –see further comments below). ALGAO strongly recommends that reference should always be to the three component parts, because they are indivisible, inter-related and mutually supportive; to omit one diminishes the remainder.
  5. ALGAO is concerned about the apparent watering-down of the Sandford Principle (see further comments in relation to Paragraph 39 below). This is such an important principle that it should pervade the entire document, applying to all agencies and organisations active in National Parks, as well as National Park authorities themselves. There should therefore be an unequivocal statement of support for the principle and its application in this Circular.

Specific comments

(relating to sections and paragraphs in the consultation document):

2.2 Sustainable Development Paragraph 17: ALGAO welcomes the reference to the role of National Parks as exemplars in achieving sustainable development and creating thriving communities. Sustainable, thriving communities are an essential pre-requisite for the positive management of the cultural heritage of National Parks, for generating and maintaining sense (and pride) of place and local distinctiveness, building community capacity and generating inward investment to benefit the local economy.

Paragraph 18: ALGAO also welcomes the reference to the success of the Sustainable Development Fund. ALGAO looks forward to the continuation of that funding stream even in these straitened economic times, because of the initiatives that have been and still can be developed, to enable National Park authorities to continue to be 'real and visible models' (Para 21) and continue to contribute to local and regional economies (Para 22), of which the cultural heritage forms part and to which it makes a significant contribution.

Paragraph 19: ALGAO particularly welcomes this paragraph, putting as it does, National Park purposes at the heart of sustainable development/economy in National Parks – including the cultural heritage - and the distinction between sustainable development in National Parks and the wider countryside is very helpful and welcome.

4.2 Conserving and enhancing natural beauty, wildlife and cultural heritage of the National Parks
Paragraph 31: ALGAO welcomes the recognition of the wide-ranging role of cultural heritage in the past and its continued contribution in the present and in and for the future.

Paragraphs 32 & 34: ALGAO also welcomes the comments in these paragraphs, as they affirm National Park authorities' policies and practices for conserving landscapes and sites, their settings and their character, as well as endorsing the close work and co-operation that already occurs with partners and stakeholders.

4.3 Promoting opportunities for the understanding and enjoyment of the special qualities of the Parks by the public
Paragraphs 35 – 38: ALGAO welcomes the recognition that no two National Parks are the same and that National Park authorities need to play to their individual strengths. The emphasis on education and recreation is welcomed and ALGAO would underline the importance of the cultural heritage of National Parks in these contexts and the important role it has in promoting understanding and enjoyment. It is unfortunate that the three key special qualities – landscape, biodiversity and cultural heritage – are not referred to specifically and ALGAO would recommend that such a reference is made at the end of the penultimate sentence of Paragraph 35, to underline the contribution – often inter-related – that these special qualities make.

Paragraph 39: ALGAO is very concerned that this paragraph appears to undermine the importance of the Sandford Principle. One of the reasons that there has been very little irreconcilable conflict between conservation and recreation is because of the very presence of that Principle. Many negotiations have been successfully concluded because of the presence, in the background, of the Principle and the knowledge that if differences cannot be reconciled, then conservation will prevail. It is an ultimate bargaining chip. As drafted, this paragraph does not endorse the Sandford Principle, nor does it suggest that it remains in place. In ALGAO’s opinion, this seriously weakens the position of National Park authorities in delivering National Park purposes and duty. If this was the intent, ALGAO strongly recommends that this decision should be reconsidered. If it was not, then ALGAO recommends just as strongly that the wording should be re-visited so that there is a much more robust affirmation of and support for the Sandford Principle and its application where conflict between recreation and conservation cannot otherwise be resolved.

5.2: Duty on all public authorities
Paragraph 52: ALGAO welcomes the re-statement of this responsibility but considers that the wording could be made stronger, given the premier UK landscape designation that National Parks enjoy.

5.3 Economic and social well-being
Paragraphs 53 - 56: ALGAO welcomes the reference to the role of communities and their activities in shaping National Parks. ALGAO recommends that there should be a more-explicit reference to the ways in which cultural heritage, biodiversity and landscape have played and continue to play a major role in that place-shaping, and the concomitant enhancing of the social and economic well-being of communities.

6.5 Conservation of Biodiversity
Paragraphs 68 – 69: While ALGAO recognises that this is a particular reference to Sec. 40 of the 2006 Act, it believes that the title of the section is misleading. It should be altered to 'Conservation of Biodiversity, Cultural Heritage and Landscape', the better to reflect the content of these two paragraphs, particularly the welcome expectation of equal weight being given to objectives for conserving and enhancing the cultural heritage and the landscape, as stated in Paragraph 69.

7 Government priorities for the Parks
Paragraph 70: ALGAO supports the expectation of focus on delivery of the Vision and securing increased value-for-money. ALGAO also supports the short-term focus recommended by Government, and particularly welcomes the recommendation that authorities should increase their contribution to enhancing cultural heritage and combating and adapting to climate change.

7.1 Helping people and nature to adapt to climate change
Paragraph 71: While acknowledging that this paragraph relates to biodiversity in the main, much of the ‘natural’ beauty of the landscape and many habitats are the product of past and present human activity and as such are also a cultural heritage component, while relying on continued human intervention (or non-intervention) for their existence. Field patterns in the Dales or the White Peak of the Peak District are seen by many as natural landscape but are anthropogenic – created and maintained by humans. Field boundaries act as wildlife corridors or habitats and industrial waste heaps are refuges for specific plants such as metallophytes on lead and fluorspar dumps. The penultimate sentence, referring as it does to two of the three key special of National Parks, should also refer to cultural heritage.

Paragraph 72: ALGAO considers that there is a missed opportunity to include cultural heritage in the definition of environment contained within this paragraph. There are things we can learn from the past, for example about land management (particularly in reducing flood risk) and building design and location, that can and should contribute to mitigating and adapting to climate change and should be included in consideration of ecosystem services. A brief reference is required here to reflect this - the cultural heritage can provide help and guidance to enable people and nature to adapt to climate change.

7.2 Mitigating climate change: leading the way
Paragraph 74: ALGAO considers that National Parks can provide leadership in more than renewable energy generation. There is a significant part to be played by National Parks and their authorities as test beds and exemplars for mitigating the impacts of climate change on cultural heritage assets – buildings, monuments and landscapes – that will have a significant effect on the social, economic and environmental development of National Parks and the wider UK and international community. Some work has already been done or is underway, such as the ridgeblade wind turbine development in the North York Moors National Park, and ground-, water- and air-source heat pumps throughout all the Parks. Much of this work has been funded through the Sustainable Development Fund (SDF) but much more could be done, both to maintain National Park landscapes and their component parts, as well as providing examples of ways forward for elsewhere across the country. However, encouragement and incentivisation are needed, both financially through the maintenance of the SDF and through this Circular.

7.3 Increasing biodiversity
Paragraph 75: In line with the comments made regarding Paragraph 71 above, ALGAO would re-state its belief that many, if not most, habitats are the product of past and present human activity. Conservation of the cultural heritage through land management practices therefore has a major impact on biodiversity conservation, particularly maintenance of landscape character (e.g. woodlands that impede flood water flow and/or absorb additional water) and maintenance and restoration of traditional farm boundaries and buildings, for example. ALGAO urges strongly that this relationship between biodiversity and cultural heritage should be recognised in this section and that cultural heritage should be listed as an aspect that should be addressed as part of the process of increasing biodiversity in Management Plans and other such documents.

7.5 Landscape, heritage and improving quality of place
Paragraph 81: ALGAO welcomes this paragraph and the recognition of the role of cultural heritage and landscape (and biodiversity) to achieving the Government’s ambition. The reference to the developing PPS15 and the European Landscape Convention are also welcome , as are, particularly, the bullet–points identifying Government expectations for these issues in National Park Management Plans.

7.7 Promoting and delivering agri-environment schemes
Paragraph 84: Having been heavily involved in the development of the current Environmental Stewardship Scheme, and more-recently in the development of the Upland Entry Level Scheme (UELS), ALGAO welcomes this recognition of the contribution that agri-environment schemes make to cultural heritage conservation, including through the delivery of ecosystem services.

7.16 Health and well-being
Paragraphs 105 – 106: While these paragraphs are welcomed, ALGAO recommends that the contribution of cultural heritage, landscape and biodiversity to enjoyment and understanding should be specifically recognised in this section. National Parks aren’t just scenery; every view (whether inspirational or not) has a story to tell that can enhance people's quality of life and bring them back time and again, to the benefit of their mental and physical health and well-being. It is vitally important that people are encouraged to make healthier long-term lifestyle choices by engaging with the special qualities of National Parks in ways that encourage return and repeat visits, rather than short-term ‘outdoor gym’ measures that can be achieved or accommodated elsewhere.

7.17 Making tourism sustainable
Paragraph 107: While ALGAO welcomes the positive references to sustainable tourism, it strongly recommends that the final sentence should refer to ‘..the conservation and enhancement of the special qualities..’. This would better reflect the aims of sustainable development set out in Paragraph 19.

I hope that you find the above comments of use and that they will inform the development of the final draft of this important Circular. If you have any need for further comment or explanation, please do not hesitate to contact me.

Yours sincerely

Ken Smith
Convenor
ALGAO Countryside Committee