The Landscapes Review
It is just over seventy years since the National Parks and Access to the Countryside Act established the framework for National Parks and Areas of Outstanding Natural Beauty in England and Wales. This initiated a novel role for government. As expressed by Sheail (2002, p.10) “A third force, alongside agriculture and forestry, emerged in the management of the countryside, namely the conscious stewardship of rural landscapes and the coastline for their amenity and wildlife, and the opportunities they afforded for outdoor recreation”. Since then these protected areas have come to cover about a quarter of the country’s land area, representing our best landscapes, but also including many areas of high conservation value and becoming a key focus for recreation and tourism in rural areas.
In 2018 Michael Gove, then Secretary of State for Environment, Food and Rural Affairs, commissioned Julian Glover to undertake a review of National Parks (NPs) and Areas of Outstanding Natural Beauty (AoNBs). Glover was given an extensive brief to review the areas’ statutory purposes and their alignment with the government’s 25 Year Environment Plan, to consider the case for new area designations, how to improve their governance and finance, how to enhance environmental standards and how to connect with all sections of society and improve health and wellbeing. Glover, supported by a panel comprising Ewen Cameron, Sarah Mukherjee, Jim Dixon, Fiona Reynolds and Jake Fiennes, visited all of the NPs and AoNBs in England and received 2500 submissions. The panel reported back in October 2019. Their report is currently under consideration by government.
Glover sees NPs and AoNBs together as a single family of ‘National Landscapes’ (NLs). He identifies various deficiencies, particularly the continued decline in natural beauty and in species and habitats, and the lack of diversity both amongst both visitors to the areas and amongst those involved in their governance. Glover has produced a substantial report, addressing a broad range of issues and making 27 separate proposals. The key elements and proposals are set out below. However, the report fails to identify the means by which these objectives can be achieved on the ground. The primary focus in this response to the report is on the potential for better conservation and environmental governance, the formal and informal arrangements for the stewardship of the land and landscapes.
The key elements and proposals in the Glover Report
The Glover report is set out under five headings:
- Landscapes alive for nature and beauty: Natural beauty is being lost and the system of landscape protection has too little influence. NLs are not delivering on their duty in relation to nature. Glover proposes a renewed mission to recover and enhance nature, delivered through strengthened management plans “backed up by stronger status in law” (p. 43). He sees NLs to be the backbone of Nature Recovery Networks as proposed in the 25 Year Environment Plan. NLs should take a central role in the delivery of the government’s new Environment Land Management system. AoNBs should become statutory consultees in the planning system.
- Landscape for everyone: There is a lack of diversity in governance and users of NLs. Very limited active initiatives currently being undertaken within NLs to support health and wellbeing. Glover proposes that NLs should have a stronger mission to connect all people with landscapes, long term programmes to increase ethnic diversity and ‘a night under the stars’ for every child. NLs should be more proactive in developing schemes to cater for and improve the nation’s health and wellbeing. This work would be led and implemented by a National Ranger Service. Surprisingly in this context, there is no discussion of the role of country parks which may be seen as a stepping stone for groups less familiar with and able to get access to the wider countryside and which have been facing severe financial challenges.
- Living in landscapes: The communities within NLs face particular challenges with regard to transport and housing. Glover proposes a new third purpose to foster social and economic wellbeing in order to promote more vibrant communities. There should be a National Landscapes Housing Association and a new approach to co-ordinated public transport.
- More special places: Glover was impressed by arguments for giving new protection to areas and suggests that there could be new designated landscapes and a new national forest. The report identifies potential new national parks in the Chilterns, the Cotswolds and in Dorset and a national forest in Sherwood. More generally, there should be a better designation process.
- New ways of working: Glover argues that there is a lack of coherence, limited ambition, too little collective working or challenge across NLs. In response, he proposes stronger purposes for both NPs and AoNBs together overseen by a new National Landscapes Service. This should be entrepreneurial, leading fundraising, entering commercial partnerships, promoting efficiencies. The governance of NPs should be simplified with smaller boards whose members bring passion, skills, experience and diversity. There should be a new financial model, and at least secure funding for NPs for 5 years but increased budgets for AoNBs.
Analysis of the environmental problem
There is little specific assessment available on the status of NL environments, but we can reasonably assume that they are subject to much the same pressures as those outside the NLs. For instance, data on the declining proportion of Sites of Special Scientific Interest (SSSIs) in favourable or unfavourable recovering condition show a very similar pattern of recent decline in NLs as in England as a whole. However, the reliability of even this evidence may be questioned if, as claimed, the level of monitoring of SSSIs has been substantially reduced following cuts to the Natural England budget.
In Glover’s report, this environmental decline is associated with changes in the pattern of human land use. “Every acre of our landscape has been modified by human activity” (p.27). “If the curlews are gone, the hay meadow has been turned to silage and species lost, the streams dug out, the soil degraded and the walls broken, replaced with tangled wire; if the trees are ageing and dying from disease, if the farmers are leaving their land, the visitors are marginalised, then natural beauty is lost” (p.27). The damage to the environment is seen to be a result of poor management and past mistakes, particularly encouraged by government: “Some places have been farmed badly, over or undergrazed, and not only because the subsidy system has encouraged it” (p.57). “Well-managed moors can achieve that and overcome past mistakes such as the draining of uplands, mostly encouraged not by grouse management but by government” (p.57-8).
The implication appears to be that ‘good’ farmers who are not misdirected by the government will provide the high environmental standard that society wants. But in reality things are more complex. Judgements of what is good or bad management become much easier with the benefit of hindsight. Farmers have responded over time to changes in prices and technology and to the pressures to achieve adequate incomes alongside government policies. Decision to make silage rather than hay or to ‘improve’ upland pastures by increased fertilisation are rational decisions taken by perfectly ‘good’ farmers. And some may argue, together with Fisher and Carver (2018), that we don’t need farmers at all and that we should provide more space for rewilding. In order to deliver the high environmental standards that have become the key goal for policy, there will need to be regulation alongside positive incentives to change land uses and farm practices, often away from what ‘good’ farmers might choose on their own behalf.
The changes proposed
Glover’s proposals to address the problems set out a coherent structure. The introduction of stronger purposes for NLs establishes a clearer commitment to landscape recovery and enhancement, beyond conservation. NL purposes would be amended to include a duty to “Recover, conserve and enhance natural beauty, biodiversity and natural capital, and cultural heritage” (p. 135). Systematic assessment of natural capital within the designated areas should be undertaken in order to identify the status of natural capital and from this to determine priorities for interventions. This would link with the proposals in the 25 Year Environment Plan for Nature Recovery Networks. The inclusion of natural capital, i.e. the elements of nature that provide value to people, such as soils, species, forests, water and landscapes, here extends the remit of the NLs across a much broader canvas and would require the development of NL staff capability or be outsourced to external consultants. This would be formalised through stronger ‘statutory’ management plans developed in NLs, with clear priorities for targeted actions for nature recovery including, but not limited to, wilder areas and the response to climate change, particularly for tree planting and peatland restoration. The implementation of the plans must be backed up by their stronger status in law and supported by the government’s Environmental Land Management Scheme (ELMS). Glover argues that “It is essential that farmers and land managers are meaningfully involved in the process of shaping ELMS and this should be done through engagement in the Management Plan” (p. 59) and the management plans “should set the framework for all ELMS payments within their landscapes”.
The governance of national landscapes
National landscapes have never played a primary role in nature conservation. While the ‘great divide’ created by the 1949 National Parks and Access to the Countryside Act has been addressed in England through the merging of government bodies to create Natural England, it has remained in the separate systems of designation for landscapes and nature conservation. Glover’s proposals could in principle offer an essential framework for its closure on the ground, at least in the NLs. However, as they stand, the proposals leave major gaps in terms of both governance and finance.
National Landscapes lack authority for the management of the environment other than that gained through the operation of the planning system in National Parks. Nature conservation designations are managed by Natural England. Responsibility for water pollution, water allocation and flood protection rests with the Environment Agency. Administration of forestry regulations lies with the Forestry Commission. Responsibility for farming policy lies with Defra. National Parks, let alone AoNBs, own very little land over which they can directly control land management. In practice they operate primarily through seeking to influence decisions of others, securing funding from other sources and working in partnership with other public and private bodies.
An assessment of the status of natural capital must be the first stage in its effective management. It can identify its condition and its strengths and weaknesses within a local area. But this cannot per se simply translate into clear priorities for action. Resources for interventions in the landscape are inevitably limited and they have costs and opportunity costs. Should the priority be to make good the areas of the environment that are most damaged or should it be to secure and enhance the areas of the highest quality? These are essentially political judgements. We might look to National Park Authorities to make such value judgements through their appointed members, but AoNBs have no equivalent structures. The implementation of the Glover proposals would require some sort of democratically accountable body to take decisions about local environmental values and to set priorities for action. A parallel here is with the development of local authority plans; the difference is that the ambition here for NLs covers a far broader range of natural capital resources.
The potential relationship between NLs and ELMS is also unclear. As Glover notes, “No role has yet been carved out for them in Environmental Land Management Scheme development or in the Nature Recovery Networks” (p.132). The current proposals for ELMS (Defra, 2020) do not provide any apparent role for NLs, or indeed for farmers within NLs, in the design and administration of the scheme. The third tier under the proposed ELM structure for landscape-scale land use change projects comes closest to a potential role for NLs. It is possible to envisage local schemes developed within NLs submitted by local landholders in partnerships with other local stakeholders supported by, or perhaps even led by NL administrations. Consistency with an NL management plan could be taken as support of an application. But as things stand there is no obvious role for NLs in designing schemes or in determining the allocation of funding.
Finance for NL governance
Perhaps the most obvious gap in the Glover proposals is the limited discussion of finance. There is a proposal for ‘a new financial model’, although the implications of this are not spelled out, and a recommendation for increased funding for AoNBs. But there is a clear reluctance to propose any substantial increase in public funding for National Parks, even though there is an expectation that they should become more active and deliver greater social value. No information is provided on the historic level of public funding for National Parks and it is not clear whether or where else this information is available. There was considerable concern expressed in 2015 by the Campaign for National Parks about the major cuts that were being introduced at that time (park funding was reduced by 35-40% between 2010/11-2015/16 for most parks) and the extent to which this has subsequently been resolved is not clear. A further question remains too about what, if anything, will replace EU funding, especially from Interreg, LIFE or LEADER, that has been used in the past to benefit National Parks and other landscapes. These are not obviously substituted by ELM or by the Shared Prosperity Fund. Rather Glover’s presumption is that the NL administrations should save funds from efficiencies and draw to a larger extent on other connected public and private funding streams, moving from core grants towards “more diverse, larger and more sustainable flows of funds” (p. 142). The extent to which further efficiencies are possible on top of those that have already been made in response to past reductions in funding is not clear. Glover does recommend some reductions is costs by reducing the size of boards, although any savings could be offset by the introduction of partnership groups and planning-subcommittees.
Reliance is placed on the development of a more diverse range of funding sources. This sees a growth in philanthropic giving, in trading activities and in largescale externally funded projects. The potential extent of such new funding streams is not elaborated. However, this will be seen as both a threat and an opportunity. The renewed focus sought by Glover on attracting and engaging with more ethnically and socially diverse communities seems inconsistent with the adoption of a more commercial approach towards landscape management. Generally Glover has been sympathetic to the views and concerns expressed to him by those engaged in the management of the landscapes. However, in this particular context he seems to dismiss their concerns about the dangers of becoming excessively reliant on commercial activities, partnerships or philanthropy. He comments that “During the course of this review we heard repeatedly of tensions over proposals for a national charity to support National Parks, and of difficulties in developing commercial links” (p. 143). This, he states, represents “a failure of coordination, ambition and expertise” (p.143). There must be a concern that increased commercialization or reliance on philanthropy in NLs could further deter the use of these areas by those sections of society with whom Glover seeks closer engagement, and divert priorities away from those agreed by the authorities responsible for the governance of the areas.
Governing and overseeing National Landscapes
Glover sets the purposes and structure for NLs to play a wider and more active role in local environmental governance. But he fails to deliver the means by which such a role may be implemented. There needs to be an organisation with the authority and capacity to determine appropriate priorities for innovations and interventions in land management, and to have direct influence over land uses and management practices.
A management plan, statutory or otherwise, sets out the policies and indicates priorities. Beyond setting constraints over actions set through general regulations, it cannot determine the specific interventions that will be undertaken in particular places. In a system such as the governance of the rural environment, which is largely driven by voluntary actions, those making the plan cannot know what options in what locations can potentially be available. Specific actions taken will ultimately be determined by landholders’ and other stakeholders’ willingness to implement change. Thus there needs to be a public body that determines priorities for interventions. This needs to have authority and accountability. We have argued elsewhere that National Parks, with a combination of public representation and professional staff, offer a potential model of a Local Environmental Governance Organisation (LEGO) that could direct environmental interventions at a local level. This would also require locally directed funding. We have also argued that a proportion of ELMS funds should be devolved to be allocated at a local scale. This could achieve the degree of involvement for NLs in ELMS sought by Glover that is unlikely to be achieved in the absence of direct control over funding at a local scale.
National Parks could potentially develop their own ELM schemes in their areas, or they could take on the role of implementing a scheme designed at a national level. But the best option for extending governance across the full range of elements of natural capital would be through the development of landscape scale land use change projects. This could potentially cover and integrate flood protection, carbon sequestration, biodiversity and public access. Such projects will require considerable input from intermediaries in leading the development of the necessary science and information, identifying and brokering amongst stakeholders with the potential to engage and contribute to the projects, and in building the necessary level of trust amongst them. A National Park Authority, strengthened by the capability to determine the allocation of funding, would be needed in order to envision potential projects and to bring them to fruition. If extended to AoNBs, this would considerably expand their role. They would need to develop their capacity to assess the state of natural capital in their areas, determine local priorities for conservation actions, work with local stakeholders to develop environmental projects and land management schemes, allocate funding to support these activities, and monitor and enforce land management agreements.
There are also other elements currently in the policy process that could complement the developing role of NLs. NLs offer obvious potential sites for biodiversity gain under the Net Gain requirements being introduced into the planning process under the Environment Bill. This could provide additional funding for nature recovery. One of the concerns in the management of the rural environment relates to the capacity to secure changes in land management in the long term. This has become increasingly critical in the context of payments for carbon sequestration and flood protection. It could be possible to use ELM funding to support land acquisition by conservation organisations or by NLs themselves. But long term security for changes in land management could be extended over a larger area with a given level of funding through the use of the conservation covenants also being introduced under the Environment Bill.
Prospects for action
The Glover report identifies important issues and sets out key objectives for our national landscapes. But as it stands, it fails to establish the means by which these desired outcomes could be delivered. National Parks, and potentially administrations in AoNBs, should be given greater authority to direct environmental interventions in their areas and be provided with the means to promote them, particularly through devolved ELM funding. Further support could be delivered by joining up other current policy innovations, especially Biodiversity Net Gain and conservation covenants in order to develop more integrated and effective rural environmental governance. The experience in NLs can then act as a potential model for systematic and integrated actions across the wider countryside more generally.
Can this happen in the current context? The Corvid 19 lockdown has drawn attention to the importance of our open spaces and nature, and also to the role of government in supporting social priorities. But government capacity to think and plan and implement new approaches to land and conservation policy were already severely strained under the pressures of Brexit and austerity. The response to Corvid 19 will stretch this capacity even further for some time to come. A new approach to national landscapes would require a major push from government. In its absence, it must be feared that this will be another missed opportunity to properly integrate our rural land conservation policies.
 Sheail, J. (2002) An Environmental History of Twentieth-Century Britain. Palgrave, London.
 HM Government (2018) A Green Future: Our 25 Year Plan to Improve the Environment. https://assets.publishing.service.gov.uk/government/uploads/system/
 Glover, J. (2019) Landscapes Review.
 See: https://unearthed.greenpeace.org/2018/09/07/half-england-sssi-sites-not-monitored (last accessed 14 April 2020)
 Fisher, M. and Carver, S. (2018) Reviewing England’s National Parks: and opportunity for rewilding? ECOS 39 (3).
 Defra (2020) Environmental Land Management. Policy discussion document.
 Sheail, J. (1988) The great divide: an historical perspective. Landscape Research 13 (1) 2-5.
 Campaign for National Parks (2015) Impact of grant cuts on English National Park Authorities. https://www.cnp.org.uk/sites/default/files/uploadsfiles/
(Last accessed 8 April 2020)
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