Recreation
Breadcrumbs
DETR rights of way proposal (NCAF 2/4)
Purpose
1. The Forum is invited to comment to the Countryside Agency on the Government's proposals for improving rights of way in England and Wales.
Background
2. In July 1999 DETR published a consultation paper Improving Rights of Way in England and Wales (copy enclosed). This invites comments, by 15 October 1999, on 20 specific legislative proposals and a number of related issues.
3. The Government's proposals were informed by a series of recommendations from the Countryside Commission, published in March 1999 under the title Rights of Way in the 21st Century: Conclusions and recommendations (CCP 550).
4. A paper on the Government's proposals will be considered by the Countryside Agency Board at its meeting on 16 September. The advice of the Forum will be reported orally to the Board at that meeting.
Invitation to comment
5. The Forum is invited to comment to the Agency on the contents of - and any omissions from - the Government's consultation paper. In order to facilitate discussion, Annex A to this paper provides a summary table comparing the Countryside Commission's recommendations with the Government's proposals.
ANNEX A
Government's response to the recommendations made by the Countryside Commission in Rights of Way in the 21st Century; Conclusions and recommendations (CCP 550)
| Countryside Commission's reccommendations | DETR's assessment and proposals as set out in Improving ROWs in England and Wales |
| FUNDING | |
| Recommendation 1: The Government should require each HA to prepare, and roll forward annually, a rights of way business plan setting out how it will use its budget to best effect to make progress towards the National Target, and identifying the resources needed to achieve each element of the Target in full by a specified date. | Agrees on the importance of rigorous financial planning by LAs to ensure vfm in the delivery of services as well as estimating expenditure requirements. The development of ROW business plans by all HAs would assist them in determining their needs and priorities. But whatever planning measures LAs choose to adopt should be in line with the best value measures in the Local Government Bill currently before Parliament. (Para 3.6) |
| Recommendation 2: Government should ask the CA (in consultation with the LGA and CSS) to: a. evaluate English HAs ROW business plans and advise Government on the additional funding which needs to be allocated to ROW work in those authority areas; and b. provide Government with:- i) more accurate estimates of the cost of meeting the National Target over a specified time scale; ii) estimates of the annual cost of sustaining the National Target, including an element for improving the network. | Not specifically addressed |
| Government should include rights of way expenditure, as estimated, as a new item within the Standard Spending Assessment (SSA) process, separated out from highway (ie road) maintenance. | Under the Revenue Support Grant system it is for individual LAs to decide how much they spend on services, including ROWs, within the framework of their statutory obligations. The Government has no power to require LAs to increase (or decrease) expenditure on particular items. The CC's proposal would therefore not affect the responsibility of each HA to determine how much it will spend on rights of way. A review of the Revenue Grant Distribution System was announced In the White Paper Modern Local Government In Touch with the People and will be subject to consultation. The method of calculating SSA is unlikely to be changed while the review is taking place. (Paras. 3.4-3.5) |
| Recommendation 3: Government should direct additional funding of £30 million per year to ROWs over each of the next 5 years to enable all HAs to deal with their current backlogs of recording, maintenance and enforcement. This must be genuinely additional to highway authorities' existing rights of way expenditure. | Government is committed to assessing the financial and other implications of its policies. A detailed economic appraisal of its proposals is being made, including assessments of LAs' current expenditure on ROWs and the cost of meeting their duties in full. But it is for authorities to determine their own priorities within the total revenue support grant available. Proposals for regulations will also be subject to a Regulatory Impact Assessment which will weigh the estimated cost of complying with regulations for all those involved against the expected benefits. (Paras. 2.54-2.55) |
HIGHWAY AUTHORITIES' APPROACH TO THEIR DUTIES
| Countryside Commission's reccommendations | DETR's assessment and proposals as set out in Improving ROWs in England and Wales |
| FUNDING | |
| Recommendation 4:
Government should equip the Secretary of State with
powers: a. to direct highway authorities to carry out their statutory duties, in specific instances and within a specific timescale, and with provision for significant penalties in the event of non-compliance; and b. to intervene, as a matter of last resort, in the case of persistently under performing highway authorities by transferring the responsibility for rights of way management, and sufficient resources, to another body. It is to be expected that the resources transferred away from highway authorities in these cases would be significantly greater than those they were employing for this purpose before the transfer. | The Local Government Bill currently before Parliament proposes a duty of best value on all LAs to secure continuous improvement in the discharge of their duties, including duties towards ROWs. The Bill's provisions include a requirement on LAs to consult with local taxpayers, service users, etc.; powers for the Secretary of State to specify compulsory performance standards and performance indicators; and a requirement on each LA to review the competitiveness of its performance in comparison with other authorities. It also provides for reserve powers of intervention by the Secretary of State very much as the Commission recommended. The Government are keen to encourage the development of consistent ROW performance indicators within the best value framework and would welcome comments on how this might be achieved. Shall also discuss this further with the Countryside Agency and the CCW. (Paras 3.7-3.8) |
| Recommendation 5: Government should propose legislation to extend the provisions of section 56 of the Highways Act 1980 (which enables members of the public to serve notice on highway authorities in respect of rights of way which are out of repair) to cover rights of way which are obstructed. | Accepts in principle that provision should be made to enable a member of the public to stimulate action by a HA to secure the removal of obstructions. It would apply to all highways, including roads. (Para 2.37 and proposal 12). |
| Recommendation 6: The Secretary of State should appoint a rights of way regulator, or ombudsman, with the duty to assess complaints by individuals or organisations against highway authorities and the power to award compensation payments against an authority in extreme cases. | Not addressed |
| Recommendation 7: Government should make a commitment to reviewing the effectiveness of rights of way administration five years after these changes come into operation. | Not addressed |
IMPROVING THE LEGISLATIVE FRAMEWORK AND ADMINISTRATIVE PRACTICE
| Countryside Commission's reccommendations | DETR's assessment and proposals as set out in Improving ROWs in England and Wales |
| FUNDING | |
| Recommendation 8: Government should ask the CA: a. to establish, in consultation with the relevant interests, consistent arrangements for the recognition of highway authorities meeting the National Target; and b. to produce, in consultation with the Local Government Association and CSS, guidance for highway authorities on the preparation of costed strategies for sustaining the National Target once they have met it. | Not addressed |
| Recommendation 9: Government should propose legislation to give highway authorities a duty to review the adequacy of the rights of way network in their area periodically - say every ten years. Such reviews should be undertaken as part of authorities' work on recreation strategies and sustainable transport plans. They should be carried out through a process of public consultation, and based on guidance approved by the Secretary of State. Highway authorities should be required to prepare and implement programmes of new creations to address needs established through the review. | Accepts that HAs should be under a duty to carry out a periodic review as recommended, including a requirement to identify priorities for creation and, if necessary, diversion and closure of ROWs. The review should be in consultation with the Local Access Forum and the results published. But it would not be appropriate to place a specific duty on HAs to implement the review's findings within a specific timescale (Para 2.5 and Proposal 1) |
| Recommendation 10: Government should ask the CA to draft guidance for highway authorities on the criteria and priorities for such reviews. | Not specifically addressed |
| Recommendation 11: Government should act to establish a reasonable scale for the compensation costs of creating new permanent rights of way by order, taking into account the established use of the land. | Not immediately persuaded of the advantages of establishing a national scale for compensation but invites views on whether the Commission's proposals would assist those concerned with negotiations on compensation for the creation of rights of way (para. 2.6) |
| Recommendation 12: Government should: | |
| a) ask the CA to advise it on the scale and cost of the task of researching and recording currently unrecorded rights of way and to prepare an operational plan for implementing the task, in order that Government can set completion dates for this task taking account of the amount of work to be done in each highway authority area; | Not addressed |
| b) state that it intends to take powers to enable the eventual closure of individual definitive maps to further amendments based on historical documentary evidence, but that these powers will be conditional upon the historic network having been researched and recorded to a high standard, against criteria set and monitored by a competent body at arm's length from Government; and | Understands reasoning behind the recommendation but doubts whether agreement would ever be reached that sufficient research had been undertaken to meet the criteria. Is theoretical possibility that further evidence of ROWs might be discovered at any point in the future. No certainty about how long the process might take. Agree that it would be difficult to set a deadline by which authorities would be required to clear all cases. (Para. 2.14) |
| c) make additional and adequate resources available to highway authorities and relevant voluntary bodies for the task of completing the necessary research. | Not addressed. |
| Would welcome comments on a more practical third option; of setting a date in primary legislation (perhaps 10 years) by which all claims for the existence of ROWs made solely on the basis of historic documentary evidence must be made. But no statutory time limit for surveying authorities to reach decisions on claims, other than those built into procedural arrangements. The Department would also exhort LAs to check their own records as fully as possible (Para 2.15 and Proposal 3). | |
| Would welcome views on how this should apply in relation to proposals initiated by authorities where no application made by a member of the public. One option would be to allow such cases to proceed after the deadline provided the initial evidence had been discovered before it. (Para. 2.16) | |
| Would also welcome views on definition of 'historic documentation'. One option would be to apply it to documents produced before the National Parks and Access to the Countryside Act 1949 came into force. (Para. 2.17) | |
| Proposes that applications for adding rights of way to definitive maps on the basis of 20 years use must use be made within (say) 5 years of the right of use being brought into question. For a transitional period of (say) 10 years claims might continue to be made on the current basis. (Para. 2.18 and Proposal 4) | |
| Recommendation 13: The Government should propose legislation to put in place a statutory code of practice for definitive map modifications. It should ask the Countryside Agency, in consultation with the Rights of Way Review Committee and the CSS, to draft such a code, and prepare guidance on sources of documentary evidence. | Note the Commission's recommendation for a statutory code of practice but consider the detailed measures required for both definitive map and public path orders would need to be set out in the legislation and/or in regulations. (Para. 2.21) |
| Recommendation 14: Government should propose legislation to give highway authorities the duty of determining applications for definitive map modifications, and any objections to them, within a specified time limit and in accordance with the code of practice described above. The legislation should provide for a right of appeal - by the applicant or an objector - to the Secretary of State or his nominee, such a right to be limited to the grounds specified in the code of practice. | Propose that, as suggested by the Commission, LAs be given responsibility to take decisions on disputed definitive map and public path orders. will need to consider whether this approach would be appropriate for every kind of public path order, but see it as a natural extension of the Government's proposal to require LAs to work with local communities in reviewing the adequacy of ROWs and as reflecting the theme of the White Paper, Modern Local Government: In Touch with the People. (Para 2.20 and proposal 5). |
| Department is giving further consideration to additional safeguards including the Countryside Commission's proposal for a right of appeal against local authority decisions. (Para. 2.20) | |
| Recommendation 15: Government should propose legislation to give highway authorities a statutory duty to determine - within a specified time limit, and subject to a right of appeal against non-determination - properly made applications for public path orders (ie. creations, diversions and extinguishments). | Agrees that shortcomings (about inability of landowners to apply for PPOs) should be put right. Minded to introduce procedures for applications for certain public path orders. Not appropriate to extend to creation orders (but Proposal 1 would provides for suggestions for creations to be made). (Para .2.22 and Proposal 6) |
| Recommendation 16: Government should propose legislation to put in place a statutory code of practice for public path orders. It should ask the Countryside Agency, in consultation with the Rights of Way Review Committee and the CSS, to draft such a code. | As for recommendation 13 above |
| Recommendation 17: Government should take the necessary powers to enable it to test - or to ask the Countryside Agency to test - the effectiveness of using a mediation service to help resolve disputes in respect of public path orders, and to implement such arrangements more widely if the test proves successful. | Supports principle of resolving disagreement at early stage. Legislation not necessary for this to be done through mediation. Welcome views on feasibility and demand for a mediation service, including the point at which mediation should be offered, whether every case would be suitable or how suitable cases would be identified, and the form of mediation. (Para. 2.24). |
| Recommendation 18: Government should propose legislation to give highway authorities the duty of determining applications for public path orders, and any objections to them, in accordance with the code of practice described above. The legislation should provide for a right of appeal - by the applicant or an objector - to the Secretary of State or his nominee, such a right to be limited to the grounds specified in the code of practice. | As for recommendations 14 and 16 above. |
| Recommendation 19:
Government should ensure that any organisation which acts on behalf
of the Secretary of State in determining disputed rights of way
orders or appeals is required and resourced, as part of its
contractual arrangements with Government, to: a) ensure that its staff are adequately trained in rights of way law and supported, where necessary, by expert assessors; b) prepare, and make publicly available, guidance to its staff on carrying out their duties; c) put in place a system of quality control, to ensure that decisions are as accurate and consistent as possible, and report publicly on the results; and d) review the administrative arrangements for public inquiries or other hearings, to ensure that they are as convenient as possible for members of the public wishing to participate in them. | Government broadly agrees with these
recommendations, and believes they should apply equally to local
authorities. Specifically: Professional training is already a Government priorities. Shall seek further opportunities to enhance skills and knowledge, to ensure that ROW functions are carried out effectively. Have begun a programme of publishing guidance to Inspectors on evidence, case law, etc. Are also updating guidance to the staff of Government Offices and will make this publicly available when completed. ROW decisions made on behalf of the Secretary of State are already subject to quality control procedures. It is clear, however, that we need to explore the question of consistency. Would welcome advice on how accuracy and consistency may be assured, given the need for independent decisions to be reached on the basis of complex and variable factors. Agree that where there is a genuine need for a public inquiry to be held out of office hours appropriate arrangements should be made. But would expect such sessions to be the exception. (Paras 3.9-3.14) |
| Recommendation 20: Government should propose legislation to add designated cycle tracks to the definitive map as a new category of rights of way. | Recognises that including cycle tracks would provide a more comprehensive legal record of ROWs but HAs would face an additional burden unless this could be achieved without the need for individual orders. Would also be necessary to define cycle tracks more precisely. Understands that the vast majority of existing cycle tracks carry a right of way for pedestrians but would welcome views on whether it is practicable to endow all cycle tracks with such rights. |
| The Government notes that there was a broad measure of agreement for this proposal when suggested in Rights of Way in the 21st Century and are willing to consider it further. However, would welcome views on (a) the practical aspects, (b) whether this would be the most effective way of providing better information to the public and (c) whether it could be undertaken without a significant increase in work for highway authorities. (Paras 2.51-2.52) | |
| Recommendation 21: Government should ask the CA and the Ordnance Survey to work together to develop and evaluate proposals to create a national rights of way database, along the lines set out in the Ordnance Survey's initial report to the Countryside Commission. | The definitive map and statement retained by the HA would remain the legally authoritative record of ROWs and any limitations' and conditions. But Government agrees on the value of complementing LA maps with a national database and will discuss this further with the Countryside Agency, CCW and OS. (Para 3.15-3.17) |
| Recommendation 22: Government should propose legislation to enable public path orders and the consequential definitive map modification orders to be combined, in those cases where both orders are made by the same authority, into a single composite order. | Agrees HAs should be able to make joint public path and definitive map modification orders (Proposal 7). |
| Recommendation 23: Government should propose legislation that introduces arrangements to deal more effectively with obstructions, along the lines set out in this report. | Agrees on the need for effective
sanctions against those who intentionally obstruct rights of way.
Asks for views on whether the current problems arise primarily from
an unwillingness to use existing measures or from shortcomings in
the legislation. Is willing to consider increasing the level of penalties if there is evidence that the maximum fine is insufficient for the courts' use. Is also sympathetic to the proposal that magistrates should have powers to require that obstructions be removed, particularly where the offence persists. Believe that continuing (daily) fines may introduce a number of complex problems when the courts are considering what sentencing level may be appropriate and may be at odds with the principle that the penalty should match the seriousness of the offence. Are willing to consider views, but consider that a power for magistrates to order the removal of an obstruction might be more appropriate in dealing with persistent offenders. Is not immediately persuaded of the value of fixed penalty notices for offences relating to obstruction of rights of way but are prepared to consider views on the proposal, particularly from those who have direct experience of enforcing the current legislation. (Para. 2.41) |
| Recommendation 24: Government should encourage the use of local transport plans (LTPs) to manage and promote rights of way and minor roads as an integrated network. | Guidance to LAs already makes it clear that LTPs must include policies to promote walking and cycling and we recognise the value of LAs reviewing the contribution which ROWs might make to their wider strategies. (Para. 3.19) |
| Recommendation 25: Government should encourage local planning authorities to consider and maximise the potential of the rights of way network in sustainable transport planning, through guidance on local transport plans and an amendment to PPG13 (Transport) at its next revision. | LAs are already free to include
proposals in LTPs where they are satisfied this will help deliver
the plan's objectives. Would welcome comments on what further guidance might be needed on the role of ROWs when authorities' provisional LTPs have been received. (Para. 3.19) |
| Recommendation 26:
Government should invite the CA to convene a time limited working
group of representatives of the main organisations with an interest
in vehicular use of rights of way, with the objective of
identifying and agreeing specific proposals to improve both the
management and the recording of byways. Such a working group might
best operate under the auspices of the National Access
Forum. Recommendation 27: In the event that a negotiated agreement on the way forward on vehicular use of rights of way cannot be secured, Government should make a clear choice between the three options specified (ie whether motorised recreational use of byways should be accommodated and managed, restricted to a limited category of byways, or banned altogether). The Agency will, at that time, give advice about which option it believes Government should take. | Recommendations 26 and 27 not
specifically addressed. But Government believes there to be a strong case for reclassifying RUPPs by means of primary legislation, although as bridleways rather than as BOATs (as had been suggested by the Commission in its original discussion paper). This will relieve authorities from the duty to research and reclassify RUPPs individually, while remaining open for anyone who has evidence of a different status to make an application for the definitive map to be amended. (Para 2.9 and proposal 2) The Government is not disposed to pursue the inclusion of unclassified roads (UCR) on the definitive map. Doubt whether it would be possible to achieve a sufficiently robust and clear definition to allow them to be recorded without allowing for proposals to be advertised and open to challenge. Status of each route would also have to be considered case-by-case. But are willing to consider views on the proposition and suggestions for solutions to the problems involved. (Para 2.11). |
| Recommendation 28: Government should propose legislation to introduce revised arrangements for regulating the use of byways. These should include provision to regulate their use throughout the countryside on environmental grounds. However, the exercise of these powers by highway authorities should be firmly constrained, within the legislation and through supplementary Government guidance and monitoring, to prevent their misuse as a substitute for reasonable maintenance. | Existing legislation enables HAs to make traffic regulation orders to conserve natural beauty and to promote recreation and nature study in certain areas. Government is minded to extend these provisions to the whole of England and Wales and to include conservation of nature. (Paras 2.28-29 and proposal 8). |
| Recommendation 29: The CA should undertake research to improve the general understanding of the use of, and demand for, rights of way. | Not addressed |
| Recommendation 30:
Government should propose legislation to give highway authorities a
duty - together with the necessary financial provision - to
promote, through the implementation of their rights of way duties
and powers (including any support they offer to landowners) the
principle of "least restrictive option" for all crossing points
(i.e. places where rights of way cross obstacles such as fences,
hedges, walls, watercourses or roads). The same duty should be
applied to the Highways Agency in respect of major roads which are
crossed by rights of way. The principle of "least restrictive option" should encompass the issue of safety, as well as convenience, but it should allow for exceptions to meet legitimate land management requirements, such as the need to stockproof certain fields. | Accepts the Commission's recommendation. Proposes that there should be a duty on HAs, acting in accordance with guidance by the CA and CCW, to promote the principle of easing passage for disabled people at places where rights of way cross fences, walls, watercourses or roads, with the Highways Agency under a similar duty in respect of trunk roads crossings. Exceptions may be necessary to allow for land management requirements such as stock proofing. (Paras 2.47 - 2.48 and proposals 18). |
| Recommendation 31: Government should ask the Countryside Agency, in consultation with relevant interests, to draft guidance on how the principle of "least restrictive option" should be interpreted for each category of rights of way. | Accepted. (Proposal 18). |
| Recommendation 32: The Countryside Agency should promote an initiative to identify, both in published information about rights of way and through distinctive waymarking on the ground, those paths which are free of obstacles such as stiles. | Not addressed |
| Recommendation 33: Government should propose legislation to give highway authorities a duty to make regular reports on the work they have done to improve the accessibility of their rights of way network to disabled and less agile people. | Accepts the Commission's recommendations. Proposes that HAs should be under a duty to publish such reports, say every two years. (Paras 2.47 - 2.48 and Proposal 19). |
OTHER ISSUES
| Countryside Commission's reccommendations | DETR's assessment and proposals as set out in Improving ROWs in England and Wales |
| FUNDING | |
| Recommendation 34: Government should undertake research, in consultation with the Local Government Association, the CSS and others, to identify and address the specific problems of recording and managing rights of way in urban areas and on housing estates. | Not addressed |
| Recommendation 35: Government should consult on how best to improve the conveyancing system to provide greater protection to purchasers against the future discovery of rights of way over the land they are buying. | The Government published for
consultation in December 1998 a package of proposals for improving
home buying and selling (The key to easier home buying and
selling). One proposal, that the seller should put together am
information pack , could provide an opportunity for prospective
purchasers to be informed about any ROWs that affect the property
and any undecided claims for paths to be added to the definitive
map. The LGA has established a working party to review search enquiries. It will look at the range of information which should be provided to buyers, including information on ROWs (Paras 3.21-3.22) |
ADDITIONAL ISSUES NOT COVERED IN THE COUNTRYSIDE COMMISSION'S RECOMMENDATIONS
| Countryside Commission's reccommendations | DETR's assessment and proposals as set out in Improving ROWs in England and Wales |
| Requirements of the EC Habitats and Birds Directives | The Government believes it is necessary to make provision for ROW in respect of two EC Directives that have been transposed into UK law. It is therefore proposed that in creating, diverting, closing, maintaining and managing rights of way, local authorities be required to comply with procedures laid down in the EC Habitats Directive for considering plans or projects likely to have a significant effect on sites designated under that Directive or under the EC Birds Directive. (Paras 2.30-31 and proposal 9) |
| Diversion or closure of rights of way | The Government believes there is a case for introducing similar powers to safeguard all SSSIs, as sites of national importance, including those which do not qualify under the Habitats and Birds Directives. The more radical step of providing powers to divert and close ROWs on the grounds for which TROs may be made (ie for the conservation of natural beauty, recreation and nature study) is considered to be too wide. The Government is not convinced that there is enough of a problem outside SSSIs to justify new powers to divert or close ROWs to protect nature generally, but would be interested in views. (Para 2.33 and proposal 10). |
| Creation of rights of way | The Government believes there to be a case for placing local authorities 'under a general duty to consider the needs of nature conservation when creating rights of way under sections 25 and 26 of the 1980 Act, just as they are presently required to have regard to the needs of agriculture and forestry. (Para 2.34 and proposal 11). |
Measures to assist in crime prevention and to rationalise some diversion and closure powers
| Countryside Commission's reccommendations | DETR's assessment and proposals as set out in Improving ROWs in England and Wales |
| Crime prevention | Government has sympathy
with: (i) the recommendation of the DEE Working Group on School Security that LAs should consider changing any ROWs identified by schools as a significant security risk, (ii) the wider concerns of LA associations and the police about the use of footpaths and back-alleys by criminals to gain access to property or as escape routes, principally in urban areas. Are prepared to legislate, in principle, to facilitate preventative action against crime provided there are strict safeguards to prevent powers from being abused. Would welcome views on both the principle and possible safeguards (Paras 2.42 - 2.43) Proposes that HAs should be able to make TROs: (i) to prohibit the use of a highway at certain times and to erect gates, where on police advice it is necessary to prevent persistent criminal activity; (ii) denying pedestrian access to premises by other than by owners, leaseholders, etc. Also propose that HAs be empowered to divert or close highways where, on police advice, it is necessary to protect the safety of the public. (Paras 2.42-2.43 and proposals 13, 14, 15.) |
| Closure or diversion of rights of way carrying vehicular rights | Proposes that HAs existing powers to
divert or close footpaths and bridleways be extended to include
ROWs recorded on definitive maps which carry vehicular rights. The
Secretary of State/NA for Wales to have reserve powers. Magistrates
current parallel powers relating to footpaths and bridleways, and
powers in respect of Byways Open to All Traffic be withdrawn. (Para
2.44 and proposal 16). The Road Traffic Act 1988 should be amended to ensure that the prohibition on driving motor vehicles on footpaths, bridleways and land away from roads, applies to all motor vehicles. The special provisions currently available for invalid carriages would still apply. (Para. 2.46 and proposal 17). |
| Temporary diversion of ROWs for land management purposes | Government is aware of suggestions that provision should be made to allow the temporary diversion of ROWs for land management purposes. Accept that public interest would need to be properly safeguard but would welcome views on need for such provision. (Para. 2.26) |
| Other issues | It is proposed to remove the anomaly that exists under existing legislation and which prevents HAs from amalgamating parts of any definitive maps that have been inherited from predecessor authorities following local government reorganisation into the existing definitive map for the HAs area. This will allow an authority to produce a single, consolidated map for its area and reflecting its current administrative boundaries. (Para 2.53 and Proposal 21) |
