Response to consultation on the Marches LEP Draft Strategic Economic Plan : Accelerating Growth through Opportunity 28 Feb 2014

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1 Working together to conserve and sustain the landscape Shropshire Hills AONB Partnership The Old Post Office, Shrewsbury Road, CRAVEN ARMS, SY7 9NZ T: F: E: Response to consultation on the Marches LEP Draft Strategic Economic Plan : Accelerating Growth through Opportunity 28 Feb 2014 The Shropshire Hills AONB Partnership welcomes the opportunity to comment through this consultation. The AONB Partnership is the Joint Advisory Committee established to advise Shropshire Council and Telford & Wrekin Council regarding management of the Shropshire Hills AONB, which comprises 14.2% of the Marches LEP area. The statutory purpose of AONB designation is to conserve and enhance natural beauty, and AONBs are judged in government policy to have equal landscape value and protection to National Parks. AONBs have secondary purposes to take into account the needs of local communities and rural industries and to promote sustainable forms of economic development which in themselves conserve and enhance natural beauty. The AONB Partnership is also the LEADER Local Action Group (LAG) for the Shropshire Hills, covering an area centred on the AONB but extending to 25.8% of the Marches LEP area and located right in its centre. We are currently starting to develop the Shropshire Hills Local Development Strategy for the next round of LEADER, which with its economic focus, will need to have strong links to the Strategic Economic Plan. The AONB Partnership is also a lead partner in the Shropshire Hills and Ludlow Destination Development Partnership, This is the co-ordinating body for tourism, which covers the same area as LEADER in the Shropshire Hills. We make our comments below from these perspectives, responding to the questions posed in the consultation, along with some other points. 1. Are the five strategic priorities clearly explained? We welcome the reference to recognising our environment as an economic asset but feel that this theme is under-developed in the Plan. It is listed under Low carbon economy, but the environment has dimensions well beyond low carbon, and should be linked to all the strategic priorities: Supporting Business a key factor in why the Marches is attractive as a business investment location is the high quality of environment and resultant high quality of life (including natural, historic, aesthetic, etc). Businesses should also be supported to improve environmental standards as a part of sound business management and to improve their competitiveness. Physical Infrastructure development of infrastructure projects need to recognise that the environment is an economic asset, and avoid harm to it through insensitive development, which would result in economic costs or disbenefits. The Shropshire Hills AONB Partnership is hosted by Shropshire Council and funded also by Defra, Telford & Wrekin Council and project funders.

2 Skills investment & social inclusion the environment provides a valuable asset both for skills training, and for engaging people actively, improving their wellbeing and therefore productivity. The strategic priorities should be underpinned by a cross-cutting theme of sustainable development, referencing established international definitions. This is in line with the overriding prominence given to sustainable development in the government s National Planning Policy Framework, which explains the concept as follows: Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs. The UK Sustainable Development Strategy Securing the Future set out five guiding principles of sustainable development: living within the planet s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly. Wording from the NPPF also is helpful in defining the breadth of scope of the environment in relation to development, in addition to low carbon aspects: contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy. In line with this, we also recommend the priority titled Low Carbon Economy be retitled Environmentally Sustainable Economy, with the accompanying text amended to: We will drive the transition to a high value, low carbon economy, maximising the opportunity in new technologies, reducing costs to business through sound environmental management, and utilising and respecting our environment as an economic asset. The Plan should avoid terminology which characterises the environment as a barrier to growth, but rather foster an attitude of sound environmental management making good economic sense, just like maintaining a home to avoid its deterioration and resulting large future capital expenses. In section 3.2, suggest adding the following to the list of Key Principles of the Investment Fund Resource protection Maximise opportunities offered by the high quality landscape In section 4 the main headings under the Marches Growth Strategy are the same as the Strategic Priorities in section 2.1 but in a different order, with Physical Infrastructure brought first. The Supporting Business section 4.2 states that support products will be the same across the whole of the Marches geography. Research and experience in our area has shown that the needs of different-sized businesses in varying sectors, such as those found in deep rural areas, are different, and advice mechanisms should be sufficiently adaptable to reflect this. In the visitor economy section, we welcome the prominence given to landscapes and in particular the Shropshire Hills AONB, which is backed up by the LEP s research which showed that within the LEP area the Shropshire Hills are as significant a draw to visitors as Shrewsbury, Ironbridge and Hereford. The following sentence should make clear that LEP area also includes parts of the Malvern Hills AONB as well as the Wye Valley AONB (these could also be labelled on the map on p22). The description of Offa s Dyke Path National Trail should be corrected to this wording. 2

3 The sentence later which refers to destinations and businesses need to act collaboratively should make reference to Destination Partnerships which have been established for this purpose and are already looking at the opportunities which may exist from LEP funding. The Shropshire Hills & Ludlow DDP has agreed a Sustainable Tourism Strategy for the area, which provides many actions and potential projects which will help to implement the Strategic Economic Plan. We support the development of recreational walking and cycling routes. Investment in cultural/heritage assets should include projects based in our market towns, and also include natural assets. Section 4.4 on Low Carbon Economy is very short and sketchy compared to the other headings. In line with the recommendation above to broaden the title of this section, we recommend the Local Nature Partnerships are approached to add content and case studies to bring this section up to the standard of those preceding it. The Environment as a key economic asset bullet point should be significantly expanded, including reference to landscape, biodiversity, heritage, soils, minerals, and pollinators. A section should also be added on climate change adaptation, which has many dimensions from changes or improvements to physical infrastructure including buildings, bridges etc, through to adaptations in farming practices and technology. The environment still provides basic resources for urban and rural populations alike. There is a wide range of benefits from the land, its rocks and soil, and from good quality habitats and ecological networks - including landscape, wildlife, carbon storage and water regulation. Ecosystem services or functions such as clean air, water and food production sustain life and are vital for health, and effective catchment management to maintain water quality and help prevent flooding in major settlements has huge economic benefits. Water supply is a critical issue for development - the described new 70,000 homes will need of the order of 9 million cubic metres of clean drinking water every year. This topic needs much more detailed consideration in the Plan. Water supply management and flood alleviation would be better wording than flood defences here. The recent debates nationally about flooding have highlighted the importance of sound catchment management in addition to flood defences to help alleviate the costly consequences of extreme flooding. The difficulty of relating these water topics to the Low Carbon title illustrates the inadequacy of this title to cover all environmental aspects. The consequences for other parts of the economy of inadequate management of water quality in certain catchments within the LEP area are rightly highlighted in the SWOT analysis. However these are not issues which can be solved at the level of advice or support to single businesses, since the economic cost of poor standards (e.g. inability to progress housing developments) does not generally fall to the businesses responsible for the pollution, which may include farms, sewage treatment works or even individual households i.e. they are externalities. Though the current political trend is to seek to reduce regulation in order to facilitate economic growth, this is a clear example of where regulation to maintain good environmental standards is an essential underpinning of economic prosperity. In the case of water quality and diffuse pollution, there is also a need for incentive schemes and support to raise environmental standards, since the significant problems which exist with real economic costs often result from legal levels of discharge which cannot be tackled by regulatory means. In the water environment it is well established that prevention measures are far more cost effective than cleaning up water for use. Section 4.5 on social inclusion should include those excluded through isolation in rural areas (access to services IMD). 3

4 2. Will the Strategic Priorities deliver the vision? The Vision makes reference to the Marches having an exceptional... environment. Without more prominence to the environment and sustainability across the Strategic Priorities, there is a risk that the LEP s vision to have an exceptional environment may be compromised by damaging forms of economic development. Making this change would also bring the Plan more in line with the Structural and Investment Funds Strategy, which has Supporting the Environment as a Strategic Activity (in addition to Low Carbon). We understand that an evidence base has been established to support the Plan, but there are few references to this in the document. Average levels of occupancy and economic activity would suggest that 40,000 new jobs would not be sufficient to support 72,000 new homes, and the thinking behind these figures could be made more explicit. 3. Are there further opportunities that could promote accelerated business growth and sustainable job creation? We would like to see better development of measures to support sustainable development of small businesses in the most rural areas, drawing on the high quality environment but without damaging it. There could also be potential to develop social enterprises to a greater degree. 4. Further comments We welcome the recognition of the rich and diverse landscape of the Marches in section 1. In section 2.0, the high quality environment is a key part of the context for economic growth, especially in rural areas. This is in terms of the economic opportunities it delivers (tourism, food and drink, other land-based, local supply chains and as an attractive place to live and work) and in terms of resource protection. The western part of the Marches area is the only sparsely populated area in the West Midlands and is different from the urban parts of the LEP area. There is no mention of our border with Wales or that the Marches include significant service areas for people living in east Wales, along with important transport routes. Figure 1- the logic chain should include care for the natural assets of the area which underpin economic activity. In section 2.1 (p9 para 1) we feel the description of the LEP area focuses on mainly on the major towns and the wording and some very rural places.. does not accurately portray the very rural nature of the Marches, which is among the most rural of all LEP areas in England. The particular economic issues of sparsely populated rural (especially upland) areas, should be referred to. These will be a key theme of our new LEADER Local Development Strategy for the Shropshire Hills. This section could also mention the three AONBs as recognition of the exceptional quality of the landscape. In section 3.4 Transport Infrastructure for Growth, we welcome the reference to protecting the natural and built environment, and suggest the improved wording which makes the Marches a special place to live, work and play and underpins economic prosperity. We also welcome the references to walking, cycling and public transport in the transport section. 4

5 The designation of Opportunity Towns is unclear these are unlabelled on the map on page 22, and the town highlighted between Ludlow and Shrewsbury is in the location of Church Stretton. Later in the document however there is a reference to Craven Arms as an Opportunity Town. The Opportunity Towns should be clearly listed in the document, annotated on the map, and the meaning and implications of the designation outlined. The meaning and designation of Enterprise Areas should also be made clearer. In section 5, we would recommend some representation of environment interests in the governance structure, perhaps through a sub-group or maybe more effectively, through representation on a variety of other groups. The section on Collaboration should mention with how the LEP is required and intends to collaborate with LEADER Local Action Groups and with Local Nature Partnerships (LNPs). There could also be reference to how the LEP will co-operate with other LEPs and with Wales. 5