AONB Designation – Some Progress

A commentary by CMS trustee David Bateman on the report
Pathfinder – Testing the Appropriateness of Designation (PDF – 4Mb)
commissioned by CCW and produced by Europarc Consulting

A 2009 report for the Countryside Council for Wales lends very strong support to our views on the benefits of AONB designation. It also casts doubt on the alternative proposal currently being pursued by local authorities, the so-called Cambrian Mountains Rural Development Project. The consultants suggest, precisely as we have done, that AONB designation should be seen as either a superior or at any rate a complementary strategy. The report’s title, Pathfinder – Testing the Appropriateness of Designation – is exactly what we might have asked for ourselves if we had been commissioning it, and many of its conclusions and recommendations also mirror our own.

On the downside, it has to be said that the report, prepared by Europarc Consulting earlier this year, represents the views of the consultants, not necessarily those of CCW. Furthermore, the consultants were asked to focus on the Clwydian Range AONB where an extension has been under discussion for several years. Nevertheless, as the consultants note, ‘it is intended that this should also serve as a “pathfinder” to help shape CCW’s approach in other parts of Wales’.

The following summary of the most relevant sections gives a flavour of the report – single quotation marks and italics are used to indicate direct quotation from the report.

1. The core objectives identified for the Clwydian AONB are similar to the ones we have identified for the Cambrian Mountains:

bullet to win resources – AONB designation ‘gives a clear competitive advantage’, say the consultants;
bullet to avoid damage – AONB ‘clearly offers superior protection’
bullet and to change behaviour – the consultants report that they ‘can say with confidence that a designated AONB has three advantages:

bullet help in establishing its brand image by being nationally recognised as one of “our finest landscapes”;
bullet a better chance of securing long-term funding for a dedicated unit promoting its special qualities;
bullet a statutory duty on public bodies to have regard to its purpose.’

In addition, ‘the requirement to adopt and review an AONB management plan following full public consultation, if handled well, is a key advantage of designation’.

2. ‘We commend the process which has been followed in the study area: independent assessment of the area’s outstanding natural beauty; establishing a broad consensus on the special features and qualities of the area, the forces for change and agreed action. This is the way to secure value for money.’
3. Some of the comments on AONBs in general (not just in the Clwydian) are as follows:

bullet ‘AONB designation is likely to improve the conservation and enhancement of the natural beauty of an area.’
bullet ‘AONB designation is able to contribute positively to the social and economic development of an area. The engagement of AONB partnerships in a broad range of actions supporting sustainable development is at the heart of their work, not an outlier. Well-run AONB partnerships enjoy the enthusiastic support of local communities and the business sector.’
bullet ‘No alternative to AONB designation will be as effective. With suffi cient political commitment, alternatives to designation can achieve some of the same benefits. However, designation is clearly advantageous now, and when the uncertainties of the next 50 years are taken into account, the foundation of a national statutory designation is clearly superior.’
4. On the alternative proposal for the Cambrian Mountains (the Cambrian Mountains Rural Development Project), the report concludes:

bullet ‘We see some weaknesses in the proposal. It seems overly optimistic in its assertion that “Substantially increased tourism revenue could be achieved by increasing visitor spend and lengthening the tourism season rather than by significantly increasing visitor numbers”. We cannot see the hard business analysis which supports this optimism.’
bullet ‘It understates the difficulties associated with paying farmers and landowners for providing ecosystem services such as carbon storage, water purification and flood control. State aids approval for such an extensive “pilot” – nearly 2,000 sq km – would be very unusual and its ability to deliver a long-term solution for the area would depend on radical changes to the Common Agricultural Policy.’
bullet ‘… The prospectus speaks of the project “demonstrating the value of integrated thinking, with the delivery of these outcomes being mutually reinforcing …”. We do not consider the current deficiency to be a lack of integrated thinking. Much thinking has been done about the benefits of integrated action in the uplands (and many other areas of the country). The struggle has been to achieve integrated delivery.’
bullet ‘The past twenty years have seen a parade of initiatives aimed at more integrated delivery of public services, the most recent in England being Multi-Area Agreements. All attempts at “soft” co-ordination of delivery have been more or less failures. Integrated delivery requires trade-offs to be made between different interests. Not every action will be mutually reinforcing. Trading off interests can only be done satisfactorily within a single decision-making framework. It requires a range of sovereign organisations to cede or pool power – something they have been singularly reluctant to do. To take an example …. we do not think that potential conflicts between landscape protection and wind energy development can be resolved to everyone’s satisfaction through soft co-ordination.’
bullet On the positive side, the report acknowledges that ‘a new mechanism for integrated decision-making has been provided by Part 8 of the NERC Act 2006. This ……opens up the possibility in a special area such as the Cambrian Mountains for the creation of a Statutory body composed of local authorities and NDPBs which could deliver planning, tourism, economic development, community well-being, countryside management (from local authorities), agri-environment funding (National Assembly of Wales), wildlife regulation (Countryside Council for Wales) and water resource management (from Environment Agency). This could provide the truly integrated decisions about delivery which the proposal says are essential.’
bullet ‘Finally, we point out that an integrated rural development initiative of this type is not an “alternative” to designating the area as being of outstanding natural beauty any more than it is an “alternative” to designation of parts of the area as Special Protection Area (SPA), Special Area of Conservation (SAC) or Ancient Monument. ……Whether or not the Cambrian Mountains meet the statutory criterion for AONB designation is independent of the decision about whether they should benefit from an integrated rural development project.’
5. Responsibilities
The report makes some interesting comments on the designation process. It expresses strongly the view that AONB designation is a matter for CCW alone, not for CCW in consultation with the Welsh Assembly Government. Although WAG has the power to confirm the designation (or not), the only basis on which it can refuse to confirm is that the area does not have outstanding natural beauty

Conclusion

Up to now, the onus has been on us, the Cambrian Mountains Society, to make the case for an AONB. We now believe the position is reversed. Let our opponents make the case against designation! As the consultants themselves recommend, ‘CCW should publish a statement on the future of the AONB designation as a whole, indicating whether all areas meeting the statutory criterion of “outstanding natural beauty” have been designated and, if not, broadly where the missing areas are.’