Covering note followed by report: 

We enclose key points and recommendations that we hope will be considered for inclusion in Stroud District Council's submission to the consultation on the Draft Regional Spatial Strategy (RSS). Many of the points are supported by the Strategic Sustainability Assessment (SSA), but have so far not been included in the RSS. We consider it is vital for Stroud District and the region that they are included in the Councils' submission.

Please note the points below are in addition to those already made at the Planning Strategy Advisory panel meetings. We have provided supporting background information in the discussion section below which may be of interest. Green District councillors will be making a more detailed submission separate to these comments that will include many of the other aspects of the Draft RSS.

Cllr John Marjoram
Cllr Philip Booth
8th August 2006

ADDITIONAL COMMENTS RE: SDC RESPONSE TO THE DRAFT REGIONAL SPATIAL STRATEGY

1. Summary of additional key points and recommendations

1.1 The RSS economic forecast is flawed: the RSS must consider and develop additional plans that take account of different economic forecasts like the predicted energy price rises. To not do this could have serious implications for Stroud District.

1.2 Adopt SSA's alternative approach to the regions development (8.24): this will bring the most economic and environmental long term benefits to Stroud District and the rest of the region.

1.3 While noting some significant steps the SSA concludes that the Draft RSS will fail to tackle climate change: the RSS needs to reconsider how it will reduce greenhouse gas emissions rather than let them continue to rise as the Draft RSS looks set to do. The SSA identifies transport and higher performance in energy efficiency across the domestic, industrial and commercial sectors as two key aspects that need work (7.11 SSA). We need to move with more urgency towards a low carbon economy if we are to build a stronger economic future for Stroud District and the region.

1.4 Airport development proposals must not go ahead: the SSA report concludes that if it does, "all other gains in CO2 emissions will be cancelled out by growth in air traffic alone". Stroud District should object to all airport expansions in the region as they will wipe out any environmental gains made by this District and impact negatively on the regions economy. Our local businesses should not be forced to reduce their emissions further to compensate purely for rises in aviation.

1.5 No to Casinos: agree with SSA that CA1 should be deleted from the Draft RSS. A Casino would be bad for Stroud District and bad for the region.

2. Discussion

2.1 The RSS economic forecast is flawed

2.1.1 Economics are unpredictable

The draft RSS is based on forecasts of relatively high-growth scenarios (8.1.4 Draft RSS). The report acknowledges there are uncertainties surrounding its economic forecasts. Similar comments have been made by members of the policy panel including Cllr Dennis Andrewartha who stated concerns around the reliability of economic forecasts. Clearly there are a huge number of factors including geopolitical turmoil, natural and human caused disasters and the growth of countries like China and India that cannot be fully predicted.


2.1.2 Peak oil: a factor that could significantly shape and change policies

The Draft RSS states that factors such as ‘the price of fuel...will be important shapers in the region’ and that in many cases these factors ‘will have largely unpredictable effects into the longer term’ (2.3.1. Draft RSS). This is welcomed but wholly inadequate.

Peak Oil is the point at which oil production rises to its highest point before declining. Almost all expert opinion already agrees that it is fast approaching, possibly within five years, almost certainly within 15. In 2003 major oil field discoveries fell to zero for the first time and the excess capacity held by Opec nations has dwindled, from an average of 30% to about 1% of global demand now. Figures show that world oil and gas production is declining at an average of 4%-6% a year, while demand is growing at 2%-3% a year. President of Exxon Mobil Exploration, John Thompson, said in 2003: "By 2015 we will need to find, develop and produce a volume of new oil and gas that is equal to eight out of every 10 barrels being produced today." Oil on that scale is just not available.

What are the options? The US is pursuing by force of arms the lion's share of what remains (1). Others are considering shifting to unconventional sources of oil like tar sands and gas to liquids processing. The vast environmental costs of these along with financial costs make this prohibitive (2). That leaves the only option - to move fast towards renewable sources of energy, like wind power, biomass, tidal power and solar - plus reducing energy demands. We applaud the draft RSS for recognising the need for expansion in renewables but the need is for a much greater and much faster switch to this option.

The significance of Peak Oil can hardly be over-stated. Oil is the fundamental underpinning of our civilization. When the oil runs out the economic and social dislocation will be unprecedented. We are very concerned that long-term global policymaking on this aspect, perhaps the biggest decision this century, is virtually non-existent. The Swedish government is an exception in that it has already launched a programme to end Sweden's oil dependence by 2020.

In the light of Peak Oil many aspects of the RSS will need greater consideration. We for example disagree that less land is likely to be used primarliy for food production (7.3.15 to 7.3.18 Draft RSS). If oil prices rise as predicted by some then this will make transporting food (including flying) over long distances more expensive. We can envisage in the longer term more food being grown locally. A report by Tim Lang and Jules Pretty “Farm Costs and Food Miles: An Assessment of the Full Cost of the UK Weekly Food Basket”, argued that food could only be called sustainable when it is grown and consumed within a 20 mile radius. Similarly moves towards more organic farming will be more necessary and desirable compared to energy intensive pesticide, herbicide and fertiliser farming (8). The South West already has the largest area in the country of organic agriculture: 900 farms (21% of the UKs total). This is something we should be building on.

2.1.3 Conclusions

We consider it a fundamental flaw in this plan not to have fully considered other economic scenarios and to have included the possibility of those within the RSS. There is currently little room to adjust the RSS if economic forecasts change.


2.2 Adopt SSA's alternative approach to the regions development

2.2.1 An alternative approach

The SSA recognises that the aim of the Draft RSS is to develop the economy within environmental limits, and the uncertainties (like those noted above) outside of the control and influence of the South West. To that end it urges that a reasonable alternative to the draft RSS be considered that examines in detail ‘an approach to development and activity in the region that is less dependent upon it’s national and international links, and footloose investment’. They go on to note: ‘This could help reduce its exposure to external factors, making it more resilient to outside shocks, and at the same time reduces its ecological footprint’ (8.24. SSA).

2.2.2 An example of challenges ahead: 'Bra wars'

The challenges facing us on textiles last year illustrate some of our concerns. The so-called 'bra wars' with China are just the tip of the iceberg. Those who believe that Chinese competition presents no threat to Europe, since we can give up what’s left of our older manufacturing base and concentrate instead on knowledge-intensive industries, are in denial. China and indeed India are fast developing their own low-cost but highly-skilled expertise in these areas too: 20 per cent of China’s exports are already 'high-tech', and with two million graduates a year there’s every reason to believe that this percentage will grow.

The Draft RSS's response is to suggest we need to “raise productivity”, but we cannot compete. Chinese costs are artificially low because of its appalling record on the environment and it's failure to protect workers from exploitative pay, long hours and industrial accidents: some 100,000 deaths in industrial accidents every year, and over 100 million Chinese living on less than a dollar a day.

It is not the place for this submission to argue about the national and international laws needed to build a trading system based on high social and environmental standards. However it is right to raise concerns about the impact our current economic model will have on the region and to consider alternative models of development, particularly the one noted by the SSA.

2.2.3 Consumption versus happiness

We welcome the discussion and recommendations in section 4.33 of the SSA regarding the relationship between happiness and consumption. As noted in the SSA: “There is no evidence that the UK pattern of economic development is making people happier or giving them a better quality of life.” It is vital that indicators for measuring happiness are developed and implemented as part of policy.

2.2.4 Conclusions

We consider that it will be in the best interests of Stroud District for the RSS to adopt the alternative approach to development suggested by the SSA.


2.3 RSS fails to tackle climate change

2.3.1 Can policies be delivered?

We applaud the steps that have been made to improve sustainability, in particular we agree with the SSA that “Policies SD1 to SD4 are a very sound basis for putting the South West on a more sustainable path” (7.11 SSA). However SSA also notes in the same section: “The main issue will be delivery. The policies set down some tough challenges, which will be difficult to achieve given the scale of development proposed over the plan period, and the stubborn unsustainable trends, particularly with respect to resource consumption which have led to the region’s ecological footprint being unsustainable on current trends. For example, policy SD2 recognises the importance of climate change as the greatest threat facing life in the South West, but evidence suggests that the region will be unlikely to achieve the targets set in the policy, without in particular a major shift in transport behaviour and much higher performance in energy efficiency across the domestic, industrial and commercial sectors.”

Other groups have raised similar concerns. South West Friends of the Earth write in their briefing: "RSS itself acknowledges that unless it puts 'sustainable development at the heart of the strategy, growth has the potential to erode the very quality of life that makes the region distinctive'. Despite the strong statements of principle, there is much in the draft RSS that gives cause for concern, and suggests that growth will lead to degradation of the environment, growing emissions (from transport in particular) and a reduced quality of life for many people across the region."

2.3.2 Greenhouse emissions set to rise

The SSA concludes in it’s “Summary of likely sustainability effects of the draft RSS” (page ix) that that there will be 'an increase in greenhouse gas emissions, despite strong policies on energy efficiency, as a result of increased traffic and air travel'. Additional concerns of the SSA include that “the overall effects on greenhouse gas emissions of the approach to high economic growth and connectivity do not appear to have been considered” (14.37 SSA) and that the Draft RSS is “not clear” how the need to reduce climate change influenced the strategy (Table 6.1. page 79 SSA).

2.3.3 New developments

Policy RE5 of the draft RSS requires all new developments of 10 houses or more to reduce their carbon dioxide emissions by a minimum of 10% through the provision of on-site renewable energy generation. For larger developments Development Policy G specifies that they should be “carbon neutral”. Taken together these policies mark a radical shift in the energy standards of buildings in the South West and would contribute significantly to carbon reduction targets. In addition, Policy RE5 would stimulate a boom in domestic scale renewable energy and energy efficiency measures (such as heat pumps, micro Combined Heat and Power boilers, solar hot water, space heating and electricity) and so would have widespread economic benefits.

We agree with Friends of the Earth and others who strongly supports these policies, but would also argue that the proportion of energy from renewables could be progressively raised to more than 10%.

2.3.4 Renewable energy targets

Policy RE1 sets targets for renewable electricity generation in the South West, in line with Government targets. These are for at least 10% of the region’s electricity consumption to come from such sources by 2010, and 20% by 2020. However other regions are now setting more ambitious targets than central Government and in our view it is quite wrong for the South West, with some of the best renewable energy resources in Europe, to have one of the lowest targets.

2.3.5 Conclusions

We cannot cannot express more strongly our concerns that the Draft RSS will lead to an increase in greenhouse gas emissions. This will have huge impacts on our environment and economy. This in our view is unconscionable. The SSA identifies transport and higher performance in energy efficiency across the domestic, industrial and commercial sectors as two key aspects (7.11 SSA). Both these need greater consideration in the RSS along with other measures mentioned and reducing waste and unnecessary consumption.


2.4 Airport development proposals must not go ahead (3)

2.4.1 Draft RSS is misleading

The Draft RSS argues that there will be “some sustainability benefits” from reduced road travel to Gatwick and Heathrow (5.4.12 Draft RSS). As pointed out in the SSA this is misleading (11.19 and 11.20). Indeed we find it quite extraordinary that the Draft RSS could make such claims that are completely at odds with the facts. As the SSA notes:
(i) Climate change impacts are much less per surface transport per passenger kilometre compared to air transport: it is better for people to do as much as possible of their journey by surface before flying and (ii) Government policy is not to displace flights from other regions but to increase capacity both in and outside the South East.

2.4.2 Forecast growth is absurd

The forecast growth from 4.5million passengers per annum in 2000 to almost 20 million by 2030 is absurd in the light of forecasts regarding oil prices and other environmental and economic considerations. The South West has seen rises in air travel higher than the English average (8) but as with the national picture much of the current aviation growth is not based on ‘need’ but artificially inflated demand: the five-fold growth of passenger movements in the past ten years is the result of an artificial and unsustainable bubble brought about by discounted fares from budget airlines. The aviation industry has benefited from vast subsidies in the form of tax exemption on fuel and total exemption from the need to contribute to local infrastructure, public transport etc.

2.4.3. Airport will mean greater tourist deficits for region

The recent Friends of the Earth report, "Why airport expansion is bad for regional economies" makes a strong case that needs answering (4). The UK already runs a massive economic deficit from air travel. Foreign visitors arriving by air spent nearly £11 billion in the UK in 2004 but UK residents flying out spent £26 million abroad: a loss to the UK economy of £15 billion. The FoE report estimates that airport expansions in the South West will lead to a massive £30 billion currency outflow between 2004 and 2020.

Bristol International Airport’s Master Plan acknowledges that tourism will make up 80% of passenger numbers, and that those leaving the UK will out number those arriving here by many times. Domestic spending already accounts for 83% of tourism spending: if more people travel abroad then the amount they spend here will reduce. As the analysis in the Friends of the Earth report shows when these factors and others are taken into account then airport expansions will lead to economic drain not economic boom. Another factor is that there is evidence to suggest increasing flights from local airports encourages the growth of second homes abroad: this will again impact negatively on local shops and businesses.

2.4.4 Aviation subsidies damage environment and our economy

The aviation industry enjoys a privileged tax-free status through duty free on flights outside the EU and exemption from tax on aviation fuel and VAT. These exemptions add up to about £10 billion per year for the UK alone of which less than £1 billion is recovered through Air Passenger Duty. Instead of subsidising air travel this money could be used to provide better public transport or public services like schools and hospitals.

The expansion of the airport will be heavily dependent on public subsidy, through the provision of infrastructure to serve the airport, and through many tax incentives that give unfair advantage to aviation over other more sustainable transport providers. It would not make sense to base plans on expansion on the unsustainable use of these incentives, which will certainly be removed within the lifetime of these proposals.

Of all European Union countries, the UK is the worst offender when it comes to passing the hidden costs of aviation on to society as a whole. The UK generates over a quarter of the European Union's hidden aviation costs that include health costs and the costs of climate change. The overall hidden economic costs of the European Union's aviation sector are currently estimated at £14.7 billion a year - of which the UK alone accounts for 26% (5). This doesn't include the costs of aviation accidents, accident services, and direct subsidies like the £500 million given to BAe to help it develop a new airbus. Hidden subsidies to the aviation sector also include the costs of building and maintaining the surface transport infrastructure which serves airports - costs which are growing fast in parallel with the growth of aviation.

2.4.5 Fuel prices will make flying too expensive for most people

The price of jet fuel continues to rise by huge amounts. The airlines have tried to absorb this price hike, keeping fares low and hoping for the best: worldwide some have posted massive losses, some are reported to be close to bankruptcy. Fuel prices may stabilise again in the short term - and may even come down - but the reality is that this is a taste of the future: a taste of the effects of when oil demand outstrips supply.

James May, CEO of the Air Transport Association writing in the New York Times said: "No business model of any airline can survive with sustained jet-fuel prices of $90 to $100 a barrel." Yet those are exactly the prices predicted by many experts in the relatively near future; a major natural or manmade disruption could bring them about in a day. There is no relief in sight. This situation cannot be sustained. Within some years or less affordable passenger flight will be history.

It is quite extraordinary that this most significant factor has been left out of the Government’s plans for expansion and the Draft RSS. A basic understanding of economics shows that oil prices rising means airfares will skyrocket and schedules will be pared to the bone. As airlines fail and the surviving carriers cut back, flights will be fewer, especially to smaller cities. None but the rich will holiday abroad.

2.4.6 Climate Change: airport will undermine efforts in all other sectors

The SSA (11.20 in the response to TR9) says: "The RSS should explicitly resist airport expansion, because it would undermine all the efforts within other sections of the draft RSS to reduce greenhouse gas emissions.”

Aviation is responsible for the fastest growing source of greenhouse gases with emissions from air traffic doubling since 1990 and set to quintuple. Yet the Department of Transport does not require airports to take climate change in to account with their expansion proposals. Worse still the effects of aviation are particularly severe due to the special nature of the atmosphere in which many aircraft fly. It has been calculated for example that on a London to Sydney flight the carbon emitted per passenger is equivalent to a Mini driving around the earth 640 times (6). Trains are 19 times more carbon efficient than planes. 70% of EU flights are under 1000km and with trains capable of travelling at 300kph we should be expanding a fast rail network.

The Government has set a target to cut emissions by 60 per cent by 2050. If aviation emissions continue to grow at the current rate it will make it virtually impossible for the 60 per cent target to be met. Improvements in aircraft technology can only deliver 1 per cent a year cuts in emissions so allowing a maximum passenger growth of 1 per cent a year would only stabilise emissions.

2.4.7 One Planet living unachievable with airport expansions

We welcome that the Draft RSS accepts the South West’s ecological footprint is unsustainable as it stands. It notes the need to shift from our current ‘three planet’ lifestyle to one where we consume resources compatible with one planet (1.6.2 Draft RSS). SD1 specifically states that the region’s Ecological Footprint will be stabilised and then reduced by: “Requiring a shift towards the more sustainable modes of transport.”

Looking at Bristol we can see that BIA’s Master Plan for access to the airport is wholly inadequate to deal with the additional numbers travelling to the proposed airport expansion. Promoting connections to motorways will continue the trend of car reliance and negative social and health impacts related to this.  However far more damaging is the significant increase in proposed flights: as noted above expanding airports would undermine all the efforts within other sections of the Draft RSS to reduce greenhouse gas emissions. Expanding the airport will lead to an increase in consumption of natural resources, thereby increasing the region's ecological footprint in direct opposition to the Draft RSS’s stated aims.

2.4.8 Noise, pollution and health

Aircraft noise is a serious health issue for those living close to airports and for those living near flight paths. Studies show that children in schools under flight paths may have their reading age delayed by six months by the noise. Noise from aircraft can also have cardiovascular and psycho physiological effects on human health. A Swedish study found that living under a flight path can increase the likelihood of having high blood pressure by 80 per cent .

BIA’s Master Plan tries to show that expansion of services will not be detrimental to those who are affected by aircraft noise. It does this by relying on decibel levels yet both the World Health Organisation and the European Union recommend levels lower than that used in the Master Plan.

Aircraft engines emit various pollutants including nitrogen oxides and particulates which have significant impacts on human health and on natural ecosystems. Studies around Zurich Airport and Stockholm Arlanda Airport show that aviation contributes a significant share of total emissions within a well-defined geographical area.  Binding EU health limits are being introduced to limit nitrogen oxide concentrations for people to 40microgrammes/m3 by 2010. Some have suggested it maybe hard to reach this target currently let alone in the future. We need better current air quality monitoring to assess the validity of this claim. Local air pollution is already a major problem in many parts of the region, with Government targets being breached quite regularly. Greater numbers of aircraft flying over the region can only exacerbate this.

2.4.9 Conclusions

We agree with and support in the most strongest terms, the SSA when it states in it’s conclusions: “Withdraw the airport development proposals included in the Aviation White Paper since all other gains in CO2 emissions will be cancelled out by growth in air traffic alone, and introduce fuel taxes that reflect the environmental cost of air travel.”

We agree we need an introduction of fuel tax on aviation fuel plus emission charges and increased landing charges on aircraft, reflecting the 'polluter pays' principle. It is worth noting that the reductions in ticket prices have meant that the wealthy fly more often. The Civil Aviation Authority's Passenger Survey in 2003 found that the average passenger salary at low-fare airline airport Stansted in the UK was £46,000, while a report by the Institute for Public Policy Research in the UK also showed that the top three social classes take more than 75% of low cost flights. Clearly, suggestions that flight numbers are rising as a result of an increase in poorer people taking more flights is misleading - it is richer people flying more often that is spearheading the dangerous increase in carbon emissions.

2.5  No to casinos

2.5.1 We agree with the SSA (14.27) when they state that: “The SSA has examined research undertaken in both the US and the UK, which has found that the negative impacts of a new regional casino are likely to be significant, and are likely to outweigh any benefits. Evidence in the US suggests that casinos cause significant increases in crime. Research in the UK indicates many further problems

2.5.2 Conclusion

Agree with SSA that CA1 should be deleted from the Draft RSS.

3. Notes