The Government is seeking the public’s views on their response to the Glover Landscapes Review which was published on 15^th January 2022. Friends of the Lake District are producing a detailed response for the consultation and we would encourage others that live in, work in or visit protected landscapes to do the same.

There are several questions in the consultation focusing on specific aspects of the Government’s response:

• The proposed changes to the statutory purposes for protected landscapes
• The development of the new environmental land management scheme
• The management of visitor pressure and potential enforcement powers
• The use of unsealed roads by recreational vehicles
• The role of AONB teams in planning
• The role of public bodies and strengthening their statutory duties

There is also a final section asking if respondents have any further comments about other aspects of the Government’s proposals.

The consultation closes at 11:45pm on 9 April 2022.

The Government’s proposals, along with a link to the consultation, is available at https://www.gov.uk/government/publications/landscapes-review-national-parks-and-aonbs-government-response/landscapes-review-national-parks-and-aonbs-government-response

We will publish a detailed response on our website soon, but in the meantime you may like to use the summary below to inform your own response. This highlights the aspects that we believe are most important for the protected landscapes in Cumbria. 

Summary of key points

The proposed changes to the statutory purposes for protected landscapes

Friends of the Lake District strongly supports the proposal to strengthen the first purpose to ensure we actively recover nature in protected landscapes and recognise their role in tackling climate change. We also believe that conserving and enhancing landscape as a holistic entity should be reflected in a strengthened first purpose. It is the landscape that provides us with all the benefits that the Government want to deliver through their proposals. It is the relationship between nature and culture, and encompasses biodiversity, geodiversity, cultural and natural heritage, along with all the health and wellbeing benefits of being immersed in the landscape. We strongly urge the Government to also make specific reference to cultural heritage in a strengthened first purpose. Our protected landscapes are the result of the interaction between nature and culture, creating the landscape character that is treasured by so many. It is therefore vital that any nature recovery is carried out in such a way that conserves and enhances our shared cultural heritage and identity.

Friends of the Lake District agree that the benefits provided by protected landscapes should be available to all parts of society and that nobody should feel excluded from enjoying their special qualities. We agree that this should be reflected in a strengthened second purpose. However, we are concerned that “enjoyment of the landscape” can be interpreted in many ways, encouraging a wide variety of activities, some of which are not always compatible with the first purpose and in fact can have a damaging effect on the special qualities. Improving opportunities and supporting access has to be balanced with addressing visitor pressure and ensuring that the special qualities we want people to enjoy are not damaged as a result. A strengthened second purpose should therefore make specific reference to quiet enjoyment with people enjoying the special qualities in a responsible manner in order to protect them, with greater emphasis on what this might include.

Friends of the Lake District agree that AONBs should have the same set of agreed purposes as National Parks. However, AONBs have smaller teams and a much smaller budget than National Parks. If they are to have the same set of purposes they should be sufficiently resourced and on a more level playing field in order to deliver both purposes.

We very much welcome the Government’s decision to clearly reject the Review’s proposal to create a third purpose for National Parks. We did not support a third purpose focused on economic activity as it could lead to increased pressure for inappropriate economic development in protected landscapes. A third purpose would undermine the very reason for designation and further weaken the other 2 purposes.

Sandford Principle

Alongside the strengthened purposes we also urge Government to strengthen the Sandford Principle that states that if there is a conflict between the purposes, then greater weight must be given to the first. We would suggest seeking to strengthen this further by providing policy guidance as to where and when the principle should apply. Government should also take the opportunity to raise awareness of the principle and reconfirm its importance.

If AONBs are given a second purpose, then the Sandford Principle should also apply to them.

The development of the new environmental land management scheme

We support all the options proposed for developing the new environmental land management schemes. We would also urge Government to create a multi-objective scheme that provides multiple ecosystem services and public benefits, including landscape, access and cultural heritage, rather than the current siloed and insular schemes that have a narrow focus on nature and water.

The management of visitor pressure and potential enforcement powers

We believe that protected landscapes should be provided with the authority and enforcement powers to manage visitor pressure when required. However, greater enforcement powers should be accompanied by projects and campaigns that prevent the antisocial behaviour in the first instance. For example, improvements in public transport and educational campaigns that provide visitors with the information they need in order to visit the landscape in a responsible manner. 

NPAs will need additional resources to use greater enforcement powers in order to investigate infringements. Resources will also be needed to undertake educational campaigns to influence behaviour.

The use of unsealed roads by recreational vehicles

Friends of the Lake District opposes the use of unsealed unclassified roads by recreational motor vehicles on the grounds of disturbance of peace and tranquillity and damage to biodiversity and the fabric of the roads themselves. Tranquillity is one of the Special Qualities of the Lake District, with opportunities for people to quietly enjoy the landscape and cultural heritage away from traffic. We consider that green lane use by recreational vehicles is contrary to the first statutory purpose, as it is damaging to the natural beauty, wildlife and cultural heritage, whilst also negatively affecting people’s enjoyment of the landscape.

We believe that protected landscapes should not be blighted by heavy traffic, which harms their special qualities, and that some areas should be largely free from traffic and we welcome the Government’s support of a sustainable transport pilot in the Lake District that could act as blueprint for other protected landscapes. Recreational driving on unsealed roads is contrary to the proposal to encourage greater use of sustainable transport and greatly hinders efforts to reduce carbon emissions and air pollution.

We therefore agree that Government should legislate to restrict the use of motor vehicles on all unsealed unclassified roads for recreational use in protected landscapes.

The role of AONB teams in planning

Friends of the Lake District supported the Glover Review’s recommendation for AONBs to follow the Arnside and Silverdale AONB example of producing a dedicated local plan document or Neighbourhood Plan. We continue to support this along with the option for dedicated design guides, SPDs or other documents as appropriate. In any event, AONB teams should be statutory consultees for on all local plan documents where relevant. We also support AONB teams automatically being notified of all planning applications so that they are aware and can choose to comment on those they wish to.

A clearer role for public bodies

We strongly agree with the proposals set out in ‘A clearer role for public bodies’. It is vital that the statutory duty on public bodies carries legal weight and it will be essential that there is a clear process for enforcing the new guidelines and that public bodies are held to account if they do not comply. 

National Landscapes Partnership

Friends of the Lake District largely welcome the proposal to create a new National Landscapes Partnership. However, it will be important that this new partnership delivers more than the current status quo. The partnership should have the independence and authority to provide strong leadership and hold those bodies managing protected landscapes to account, ensuring strong management plans and effective implementation in how the statutory purposes and the Sandford Principle are applied to ensure consistency across the country. The partnership will need sufficient resources, with a dedicated team of staff, to ensure they have the capacity and funding to deliver efficiently.

New designations and extensions

We are extremely disappointed that the proposal for a southern boundary extension to the Lake District National Park has not been considered for designation this time. We firmly believe that this is a strong, well-evidenced and thought out case for an extension to the National Park. We therefore strongly urge Government to ensure that when a strong case such as this is made, the proposal should be considered on its own merits, and unless there is clear justification for not proceeding, the designation process should be progressed.

Lake District Sustainable Transport Pilot

We welcome the support for the Lake District National Park Authority and Cumbria County Council developing new sustainable ways to access the National Park that may transform public transport in the area. This is a huge opportunity that should be delivered as soon as possible not only to create better transport for local people, but to meet our climate change targets, deliver the levelling up agenda, help the area recover from Covid and ensure the impacts of tourism do not damage the landscape that it relies upon. Disappointingly, there is no firm clarification of what is meant by ‘support’ and without financial support and guidance it will be difficult to implement. We would urge the Government to commit to financial support to ensure the pilot is a beacon of best practice that can be replicated elsewhere.

Funding

We are extremely disappointed that there has not been a commitment to the multi-year funding agreements suggested by the Glover Review despite the Government’s recognition that the core grant will not be sufficient for the work that needs to be done. Whilst we acknowledge that there is a role for private finance, sponsorship or commercial opportunities we have some serious concerns about the proposed new funding model. This proposed funding model will not provide protected landscapes with the certainty they need to plan ahead, which is so vital for planning for nature recovery, ensuring resilient landscapes and implementing long-term engagement programmes.

Affordable housing

We are disappointed that the Government have not provided any real solutions to the issue of affordable housing and second homes in protected landscapes. Whilst we acknowledge that this is not an issue exclusive to protected landscapes, it is an issue that is particularly acute in protected landscapes and needs a unique approach, especially as the landscape sensitivity of protected landscapes means that simply building more is even less appropriate in these areas than it is elsewhere.  In some protected landscapes it is unlikely that demand for housing could never be met no matter how many new houses were built due to the number of people who want second homes or holiday lets who can then outcompete residents.  Regulation is the only way to ensure people who live and work in protected landscapes are able to afford to live in them.  We strongly recommend the Government looks again at this issue and brings together experts and professionals in the field to develop practical, long-term solutions.

People and Place

We agree with the Government’s proposals that our protected landscapes should be available to all and that nobody should feel excluded. Whilst this needs balancing with managing visitor pressure, we are extremely supportive of ensuring our protected landscapes are accessible to all and urge Government to emphasise this within the levelling up agenda.

We welcome the proposal to seek ways to support capacity building in schools to engage with nature. Our original response to the Glover Review recommended introducing designated landscapes into the national curriculum and providing opportunities for all children to visit a designated landscape and we urge Government to take forward the Review’s proposal to introduce a night under the stars for every child in a protected landscape.