Coed Cadw (the Woodland Trust) Response to the Welsh Assembly Government's Consultation on the Convergence Programmes
October 2006
Introduction
Coed Cadw (the Woodland Trust) welcomes the opportunity to respond to this consultation. The comments that follow are delivered on behalf Wales’ leading woodland conservation charity. We achieve our purposes through a combination of acquiring woodland and sites for planting and through wider advocacy of the importance of protecting ancient woodland, enhancing its biodiversity, expanding woodland cover and increasing public enjoyment. We own over 100 sites across Wales, covering around 1,580 hectares. We have 250,000 members and supporters across the UK.
Coed Cadw’s vision is for a sustainable well-wooded countryside, which has diversity of landscape and biodiversity at its heart. As a charity committed to the conservation of our native woodland heritage, and the awareness and enjoyment of it by the public, Coed Cadw is very much aware that the quality of the environment is the basis on which much of our economy rests, as well as being central to our quality of life.
Coed Cadw has been involved in three Objective 1 projects over the past five years: the Trust’s own Ancient Woodland Restoration Project, the Forestry Commission’s Reclaiming our Forgotten Inheritance and the Meirionnydd Oakwood Habitat Management Project. As well as offering various economic, social and environment benefits, these projects have drawn significant amounts of additional funding into West Wales and the Valleys. We believe that these projects have offered significant benefits and we hope that there may be potential for further such initiatives as part of the Convergence Programmes.
We have not attempted to provide answers to all the questions in the consultation document, confining ourselves to those areas where we feel we have some particular insight, experience or expertise to offer.
Summary of key points
• The Convergence Programmes offer huge potential for economic development, employment growth and also for environmental enhancement. It is important, however, that we find ways of delivering the first two of these without detracting from the third.
• As is recognised throughout the consultation document, Coed Cadw believes that the current Objective 1 funds are working for Wales. Gross Domestic Product per head has risen, while the funds have also made a very significant contribution towards improving the state of our natural environment in Wales, which the consultation document recognises as being the basis on which much of our economy rests. There have been a number of successful partnerships involving the voluntary sector, and in particular the Environmental NGOs, which have enabled the funds to be deployed in new and innovative ways. Moreover, careful planning appears to have largely avoided funding going into projects which would in themselves cause significant damage to our natural environment. Coed Cadw believes that if the present Convergence Programmes are ultimately as effective as the present Objective 1 funding in these respects, they will have been successful.
• In one important respect, the proposed Convergence Programmes do not seem to be well integrated of the Assembly Government’s overall policy agenda. Outcome 21 of the Environment Strategy aims at getting 95% of international sites into favourable condition by 2010. During the last round of European funding, investment in European designated Natura 2000 sites was provided for under EAGDF. This was doubly sensible, as European funding could have been put at risk if Wales was seen to fail to bring its Natura 2000 sites into favourable condition. For 2007-2013, however, funding for Natura 2000 sites was not provided for in the Rural Development Plan, nor is there provision for it under the Convergence programmes, other than as a lucky spin-off of economic development projects. Bearing in mind the recent reaffirmation by the EU that “adequate funding should be provided to Natura 2000 implementation through Community (CAP, Rural Development, Structural funds and LIFE +) and Member state co-financing.” , this is a worrying omission. We strongly urge the Assembly to reconsider this point, and to make provision for drawing down EU funding for getting Natura 2000 sites into favourable condition, either through the Convergence Programmes, or the Rural Development Plan.
• Coed Cadw recognises the emphasis that is being put on job creation, transport and economic infrastructure, in line with the Lisbon Agenda. If the programmes are to be compatible with the Gothenburg agenda, however, and even more so with the Assembly’s own Environmental Strategy and Sustainable Development Scheme, it is vital that the funds are not deployed in ways which actually undermine or damage the natural environment. Coed Cadw notes that the Policy Gateway summary at the end of the consultation document awards the plan its lowest score for “Action in our built and natural environment”.
• Coed Cadw understands the desire of the WAG to see fewer projects supported by the Convergence Programmes than have benefited from Objective 1. There is clearly a risk, however, that reducing the number of projects supported will make it much more difficult for the voluntary sector to play a part in developing and delivering projects, and that this could lead to a loss in creative, new ideas, and initiatives that are rooted in local communities. We would therefore suggest that WEFO be asked either to reconsider the desire for less projects or consider how to increase the capacity of voluntary organisations to act as lead partners for strategic or consortia projects and to participate in the delivery of strategic initiatives in partnership with the public and private sectors.
• Coed Cadw understands very well the emphasis that needs to be put on driving down the costs of projects funded by Objective 1 at present. However, bearing in mind that under EU rules no contingency funding can be allowed for, we feel this approach can sometimes to counterproductive, as it can force projects to be over-cautious and to avoid taking risks as they simply cannot afford to fail.
Consultation questions
Analysis
1. To you agree with the overall vision for West Wales and the Valleys?
The Assembly Government is to be congratulated for trying to learn lessons from the Objective 1 programme, and make the Convergence Programmes even more effective than Objective 1. Coed Cadw strongly supports the aim of making the environmental sustainability a cross-cutting these within the programmes.
We note, however, that there is a potential conflict between promoting environmental sustainability, and the promotion of certain kinds of economic development, for example the expansion of air travel between north and south Wales. (The service is touched on in section 3.18 of the supporting document.)
Hence, if the commitment to environmental sustainability is to have a real impact, then there needs to be a system to ensure that development proposals that are not environmentally sustainable will not be supported through it. Does the WEFO or WAG have such a system in place?
Coed Cadw recognises the importance of following the Lisbon Agenda in the planning of the Convergence Programmes. We note however the conclusions of the European Council on 22 and 23 March 2005 that “…the Lisbon Strategy is to be seen in the wider context of the sustainable development requirement that present needs be met without compromising the ability of future generations to meet their own needs”. The Programmes therefore need to be consistent with the Gothenburg Agenda for sustainable development and by implication with the UK Sustainable Development Strategy and the Welsh Assembly Government’s Sustainable Development Scheme.
For this reason it is vital to ensure that, in a rush to promote jobs and development, the Convergence Programmes in no way has the effect of undermining the Assembly’s Sustainable Development Strategy, or indeed its Environment Strategy.
The Environment Strategy for Wales notes that biodiversity is still declining, partly due to inappropriate development. If this programme fails effectively to protect and enhance the natural environment, it will undermine any employment and quality of life benefits that it brings. We believe it is vital to recognise the public benefits of investing in the natural environment in Wales, in terms of the sustainable economic and social benefits that derive from a high quality environment.
The most striking example of this is bringing European designated Natural 2000 sites into favourable condition. As noted above, during the last round of European funding, investment in European designated Natura 2000 sites was provided for under EAGDF. For 2007-2013, however, funding for Natura 2000 sites was not provided for in the Rural Development Fund, nor is there provision for it under the Convergence programmes, other than as a lucky spin-off of other economic development projects. Coed Cadw believes this is both a mistake and a missed opportunity to use European money in furtherance of its own policy agenda. We therefore strongly urge the Assembly to reconsider this point, and to make provision for drawing down EU funding for getting Natura 2000 sites into favourable condition, either through the Convergence Programmes, or the Rural Development Plan.
2. Do you agree with the Analysis of strengths and weaknesses, opportunities and threats facing the Region?
Coed Cadw notes the recognition in paragraph 1.2 of Chapter 1 that the economy in West Wales and the Valleys has performed well in recent years and has seen growing output and rising average earnings.
We welcome the recognition in paragraph 1.49 that the environment can be an important driver of economic and social well being, as well as being a public good in its own right.
We would support the SWOT analysis in general terms, and in particular we welcome the inclusion of the first two Strengths listed, relating to the quality of the natural environment, the good quality of life.
3. Do you agree with the Strategy?
While Coed Cadw supports the objectives of the Strategy, as outlined in paragraph 2.20 we are concerned the delivering of these objectives could have the effect of undermining the Assembly’s Sustainable Development Strategy, and indeed its Environmental strategy, unless processes are put in place to ensure that this does not happen. Coed Cadw notes that the Policy Gateway summary at the end of the consultation document awards the plan its lowest score for “Action in our built and natural environment”. In our view, the Assembly needs to find some way to ensure that only projects that are compatible with sustainable development receive support through the programme.
We welcome, however, the specific reference to environmentally friendly products and processes and renewable energy in paragraph 2.22.
We welcome the emphasis on sustainable energy and the environmental related sector, in paragraph 2.26.
We particularly support the emphasis on decoupling economic growth from increasing demands on the environment, as outlined in paragraph 2.56. At time of steeply rising energy prices, this approach makes very good economic as well as environmental sense.
4. Do you agree with the aims and objectives for the programmes?
All of our comments in response to the question above, No 3, are equally valid in response to this question.
5. Do you agree with the monitoring and evaluation strategy?
We welcome the inclusion of the Sustainable Development indicators from Wales: a vibrant economy, specifically the quantity of industrial and commercial waste produced per annum, carbon emissions as a percentage of Gross Value Added and renewable and waste energy consumption as a percentage of total energy consumption.
Bearing in mind the narrative regarding the importance of the environment for the economic development, however, we believe that the document incomplete without indicators linked specifically to the quality of the environment, such as the percentage of Natura 2000 sites in favourable condition.
7. Do you agree with the focus of the priorities?
ERDF Priority 1
Coed Cadw is happy to support the priorities outlined in paragraph 3.1, so long a firm mechanism exists to ensure that they are achieved in ways which are consistent with the programmes crossing-cutting themes, and which do not undermine the Assembly’s Sustainable Development Scheme and Environmental Strategy.
ERDF Priority 2
Likewise, Coed Cadw is happy to support the priorities in paragraph 3.9 so long a firm mechanism exists to ensure that they are achieved in ways which are consistent with the programmes crossing-cutting themes, and which do not undermine the Assembly’s Sustainable Development Scheme and Environmental Strategy.
An example of this is the emphasis on improving transport links, as outlined in section 3.1. While transport solutions may create “larger, more competitive markets”, the implication is that goods will be traded over a wider area, increasing fuel use and “food miles”, and thus undermining the aim of decoupling economic growth from increasing demands on the environment.
More specifically, Coed Cadw strongly opposes the use of Convergence Programme funding to develop a scheduled air service between north and south Wales. (The service is touched on in section 3.18 of the supporting document.) Air travel is a highly polluting form of travel in terms of C02 emissions, compared to road, rail, bus and indeed most other transport modes. Yet it is already heavily subsided relative to other transport modes, due to lack of excise duty of aviation fuel. To use Convergence funding to further subsidise air travel would be utterly perverse, in our view, and would certainly be contrary to the cross-cutting theme of environmental sustainability, which supposedly runs through the document.
With regard to the Theme 1, sustainable transport, Coed Cadw is also concerned that supporting key road developments is likely to lead to an increase in the number of vehicle miles travelled, which would in turn lead to an increase in CO2 emissions and thus reinforce the link between economic growth and increased demands on the environment, and undermining the cross-cutting theme of environmental sustainability.
8. Do you agree with the proposed priority level indicators?
In themselves, the indicators appear to reflect the narrative that immediately proceeds them.
It is important to recognise that the indicators relating to the cross-cutting themes, in particular environmental sustainability, such as reductions in commercial waste landfilled, reduction in greenhouse gas emissions and number of products or processes developed to improve resources efficiency (p68), are every bit as important as the indicators for the number of km of new roads constructed.
10. Do you agree with the proposed objectives and approach to mainstreaming Environmental Sustainability within the programmes?
Coed Cadw welcomes the attempt made to mainstream Environmental Opportunity, and we strongly support the rationale quoted in support of this in paragraph 4.57. We also welcome the recognition that this cross-cutting theme needs to be integrated into projects at an early stage of development (paragraph 4.85).
If this attempt is to be ultimately successful, however, this cross-cutting theme needs to genuinely impact on the way the overall objects of the programmes are met. We strongly support the Environmental Sustainability Objectives for the Programmes quote in paragraph 4.89, but fear that, if they do not have specific, published, indicators attached to them, then they could end up being nothing more than boxes which are ticked on application forms.
We would therefore call for more specific monitoring of the extent to which these Environmental Sustainability objectives are delivered.
11. Do you agree with the proposals for the broad allocation of resources?
Bearing in mind the requirement to follow the Lisbon Agenda, Coed Cadw is happy with the proposed allocation of resources, so long as the cross-cutting themes really are mainstreamed, and the resources are deployed in ways which really do promote environmental sustainability.
12. Do you agree with the proposals for strengthening strategic implementation?
Coed Cadw understands the desire of the WAG to see fewer projects supported by the Convergence Programmes than have benefited from Objective 1. There is clearly a risk, however, that reducing the number of projects supported will make it much more difficult for the voluntary sector to play a part in developing projects, and that this could lead to a loss in creative, new ideas, and initiatives that are rooted in local communities. We would therefore suggest that WEFO be asked to consider how to increase the capacity of voluntary organisations to act as lead partners for strategic or consortia projects and to participate in the delivery of strategic initiatives in partnership with the public and private sectors. Technical assistance funds could be used to promote the involvement of voluntary and community organisations in the local delivery of national strategic projects.
13. Do you agree with the proposals for Technical Assistance?
Coed Cadw agrees with the points covered in this section but would add a few additional ones. We would like WEFO to:
a. Develop a transparent application process with clear guidance on application criteria.
b. Recognise the cost of submitting EU applications, particularly the pressure this exerts on NGOs, and to make the application materials concise and straight forward. We do however understand WEFO’s need for sufficient information to enable them to make informed decisions.
c. Provide comprehensive pre-application advice and early guidance if a project is unlikely to be funded by WEFO to avoid unnecessary cost to potential applicants.
d. Ensure that whilst claiming and monitoring procedures need to be robust and transparent, they do not become excessively onerous or alter during the programme period.
14. Do you agree with the proposals for the Programme Monitoring Committee (PMC)?
We agree that it makes sense to have one PMC for both the Convergence and the Competitiveness programmes. As well as streamlining the administration, this should make it easier for find representation from both the private and voluntary sectors.
Coed Cadw (the Woodland Trust), Yr Hen Orsaf, Llanidloes, Powys SY18 6EB
www.coed-cadw.org.uk
www.woodland-trust.org.uk/campaigns
www.epolitix.com/forum/woodland-trust
For further information please contact:
Rory Francis on 01766 832563, email: roryfrancis@woodland-trust.org.uk
Jerry Langford on 01570 471568, email: jerrylangford@woodland-trust.org.uk
