Planning Consultation Response

Natural Living Assets

Submission on Draft Planning Policy Statement 23

Enabling Development

05/05/2011

                                              

 1          Background

 Local Angling Associations and clubs have worked extremely hard for many years to conserve, protect, and enhance not only the fishery on rivers but the entire river environment, for the benefit of local people and increasingly, visitors.  Countless (voluntary) man-hours and hundreds of thousands of pounds have been spent to improve rivers and associated fisheries: these Associations and clubs continue to provide a self-financing and voluntary community-based effort to look after the rivers. Many voluntary officers within angling clubs have contributed time, knowledge and commitment to support the development of river basin management plans now approved by the Northern Ireland Environment Agency as part of the river basin management process.   

The Pricewaterhouse Coopers Report of July 2007 for DCAL on the social and economic value of angling in NI, states that all forms of angling in NI support some 780 full time equivalent jobs, and are worth some £40m p.a. to the NI economy, mostly from game angling. If this jobs/economic benefit is to maintained and enhanced, the conservation of good water and catchment habitat is vital.

This DCAL study highlighted the impressive record of angling in promoting a healthy, outdoor activity with an almost unmatched record in eliminating sectarian influences. Angling Associations are now responsible for selling large numbers of day tickets to visiting anglers and are generating considerable interest in NI among anglers from outside the area. It is therefore important that any proposal which may jeopardise this community activity should be subject to reasonable assessment.

Natural Living Assets is very concerned about the potential effects of these proposals on rivers and lakes as a number of planning applications have proved to be detrimental to the environment generally and to waterways and fisheries in particular.

It is critically important that the natural integrity of rivers is protected to allow continuation of the natural ecology of the stream, and to allow existing fish populations to prosper regardless of which planning system is used.  

Therefore “enabling planning”, if adopted as a way forward needs to fully consider socio economic and ecological economic value as a measure of economic success.

( Above paragraphs taken and modified from UAF response)

Any planning approvals need to assess the ecological consequences and the holistic socio economic value of any particular project.

It is not clear how ecological economic measures are factored into enabling the planning process nor how the greater community good is to be assessed.

There is a need to recognise ecological impacts, no less than any previous planning system.

To be successful it is essential to fully consider the value of any environmental services provided by local river habitats including the value of fish stocks to the local community and the full added value provided by holistic community assessment. These include the following.   

*           Biodiversity

*           Amenity

*           Flora and Fauna

*           Clean waterways

*           Angling

*           Salmonoid  ranching 

*           Educations programmes

*           Research operations

*           Community development projects. 

PPS23 requires a Strategic Environmental Assessment due to its great potential impact on the environment.

Finally, we would like to know what restrictions (if any) will be placed on the kinds of enabling development that would be permitted, and how far the developments are allowed to deviate from any current plans.

Brendan Kerr

 

Natural Living Assets

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