Initial response to the Stroud District Councils' Environment Green paper

NB: A follow up Green party response is being prepared with more details and a draft is due out the second week in November 2006. 

An initial response to Stroud District Councils Environment Green paper by Cllr Philip Booth, Cllr Martin Whiteside, Cllr Gwen Belcher, Cllr John Marjoram and Cllr Sarah Lunnon on behalf of Stroud District Green party.  

6th September 2006

Download a copy of the Draft Environment Green Paper (26/07/2006) at:
http://www.stroud.gov.uk/docs/environment.asp?did=environment

Index:

1. Introduction
2. Consultation process: a missed opportunity
2.1. The document is bland.
2.2. The paper is bereft of targets.
2.3. The paper is weak on the ‘how’. 
2.4. Lots of advice but few carrots or sticks.
2.5 Wording needs to be clarified.
2.6. Consultation timing
3. 'Why we must act?' section
3.1. Strengthen wording re cause of climate change.
3.2. A positive message
3.3. We can make a difference
3.4. Building an economic future
3.5. Don't misrepresent situation
3.6. Ecological footprints
4. Additional issues to include in paper
4.1. Macro and micro issues are confusing
4.2. Green Infrastructure Planning.
4.3. Local Spatial strategy and sustainability appraisals .
4.4. Nuclear power and waste
4.5. Measuring success
4.6. Costs/benefits
4.7. Staff training and costs
4.8. 100% Renewables
4.9. Transport
4.10. Reducing waste
4.11. Nottingham Declaration
4.12. Need to fast track
5. Next steps
6. Notes

1. Introduction

At the Full Council meeting on 21st September there will be an opportunity to debate this Environment Green paper. Time will clearly be limited at that meeting so we have set out below our initial response to the paper plus some recommendations.

The Green party welcomes this exciting and positive paper on the environment and the many good proposals within it including the commitment to eradicate fuel poverty. Stroud has already achieved much - for example doorstep recycling and tackling energy efficiency with schemes like Warm and Well. However as the paper acknowledges much more is needed and in our view with much greater urgency.

Clearly as a Council we have challenges that relate to what policies come or don't come from central Government. We recognise that Westminister has a huge influence on what can be achieved locally (and indeed it should be doing very much more), but we also recognise that those issues are not directly part of this consultation. The Regional Spatial Strategy is another influential strategy that is not directly part of this consultation, but we nevertheless applaud the Council's recent submission that questions the RSS plan to increase CO2 emissions in the South West.

This Green paper rightly focuses on what can be done locally by all of us in the District. We hope very much that we can all work towards a Green vision for Stroud District that sets the example for other Councils to follow.

Some of our comments are critical, particularly around the consultation process, but we would like all to bear in mind that we applaud this move by the Council. Our comments are designed to improve and encourage further work on this exciting and vital project. This is after all not just about our environment, or about building a stronger local economy, it is also about building a better Stroud District for future generations.

2. Consultation process: a missed opportunity

We welcome the very comprehensive strategy to consult parish councils, schools, staff, organisations, the public and more. However there are some key problems with the style and content of this document if it is to be used for consultation leading to more specific policies.

2.1. The document is bland.

We need a bolder statement of where we want to go. There is hardly anything anyone would disagree with. It seems a missed opportunity to spend money and time on consulting on proposals that everyone would agree with? Climate change actually presents us with some interesting and hard choices – we should be consulting on these – to get guidance on which of the range of possible policies are supported by most people and which are not. What are the priorities? Wind turbines on our hills? Increasing Council Tax to pay for energy efficiency measures? Nuclear waste to be stored at Aston Down?

2.2. The paper is bereft of targets.

We need to plan not dream. The paper identifies many of the priorities that we need but without being clearer we will not be able to measure our progress towards achieving our goals. One small example – on home energy efficiency it talks about ‘reaching more people with advice and incentives and increasing take-up’.  However there is no indication of what proportion of houses we expect to reach and upgrade to what standard in the next 20 years. How many houses does this mean a year? How does this compare with our current progress? What sort of ‘scale-up’ is needed? What are the likely budget implications? Without this sort of analysis the list of actions are pretty meaningless – and the consultation much less useful. Who would not agree with the list of bland good intentions?

We don't for one moment doubt that setting targets is a challenge for all of us, but to move forward they are essential. Nearly all the current proposed actions lack targets and lack analysis about the scale of what needs to be done, this means nearly every action proposed is a good intention – nice but not very useful! The few targets mentioned only look ahead as far as 2008 (e.g. "Increase recycling rates to 30% by 2007/8 and then look to increase them further").  This could also be more helpful – we need to set a target for where we need to be in say 2020 and work back from there – that way we will know what we need to start doing now.

David Cameron in conjunction with Friends of the Earth has for example called for the Government to set an annual target of 3% reduction in CO2 emissions. Environment Secretary David Miliband has pledged all UK central government departments and their agencies will be carbon neutral within six years. Many Councils and corporations are developing strategies to become Carbon neutral. Milton Keynes has a carbon neutrality on all new developments exceeding five homes. Stroud District could work to become the first rural Carbon Neutral District.

2.3. The paper is weak on the ‘how’. 

For instance it has ‘Introduce measures to encourage recycling of water’ and ‘Introduce measures to reduce water use’.  Nobody would disagree with this in theory – but it is pretty meaningless to consult on this unless we know ‘how’ in practice (and it needs to go beyond just water butts).  Some actions people might be very happy with – other actions perhaps not – this is what, in our view, consultation should be about.

There are no clear proposals on stricter building and planning regulations to increase energy efficiency, water recycling etc.  This is a key opportunity for decreasing our environmental impact; however there are also some cost implications – often increasing initial costs, but decreasing running costs.  These are the sort of choices that we need to consult on – otherwise we will never know what people find acceptable.  What about relaxing some of the planning regulations on solar panels, micro-turbines etc – some of this is controversial – we need to consult on these. The Green Paper merely says ‘Review our Planning Policies with the aim of improving our climate change response’ – nobody would disagree with this: it is too vague to be meaningful to consult on.

2.4. Lots of advice but few carrots or sticks.

Looking down the action columns – they are full of ‘advise’, ‘educate’, ‘encourage’, ‘work more closely with’, ‘Review’ and ‘explore funding streams’.  This is all necessary – but doesn’t indicate significant commitment to achieving change. Any realistic strategy will need appropriate carrots and sticks.  These are the things that are likely to be controversial – and need to be in a Green Paper to be worth consulting on.

2.5 Wording needs to be clarified.
 
Examples include:
- "Prioritise biomass development …." - Prioritised over what? Insulation? Solar? Wind? Nuclear? Oil?
- "Empower communities by extending local leadership on the provision of our services" - It is not clear what this means.
2.6. Consultation timing

We have some concerns that the main media launch occurred in August before Full Council had the opportunity to debate these issues. This means that the above recommendations could not be made in time to improve the consultation process.

3. 'Why we must act?' section

3.1. Strengthen wording re cause of climate change.

We need to strengthen the wording that human activities are the cause of climate change (see for example section 3 under the heading 'Global problems'). While some people may consider that climate change is not man-made, the evidence is now overwhelmingly against them. Certainly some 'green groups' have been guilty of expressing unjustified certainty about the science of climate change, but as the Royal Society has pointed out, the overwhelming misinformation has come from lobbyists questioning the need to cut CO2 emissions. 2,000 scientists from 100 countries who make up the UN Intergovernmental Panel on Climate Change all agree and their latest report due out next year makes very grim reading. It confirms unquestionably that climate change is a man-made phenomenon and is happening faster and more seriously than previously expected. It is worth noting that not one of the 928 climate change-related articles published in peer-reviewed journals during the past ten years has doubted the cause of global warming, yet more than half of the published articles in the popular press have done just that.

If there are still doubters it is also worth noting that Zac Goldsmith, deputy chair of the Conservative party's quality of life policy group who says: "Climate change presents us with an uncomplicated choice. If we are wrong about the dangers, these initiatives come with no downside. But if we are right and we fail to act, the consequences don't bear thinking about."

See New Scientist article: "Climate change: Menace or myth?" 12 February 2005 at:
http://www.newscientist.com/channel/earth/climate-change/mg18524861.400

The Guardian commenting on leaked IPCC report 8 May 2006:
http://www.guardian.co.uk/climatechange/story/0,,1769825,00.html

3.2. A positive message

It is excellent that you note that: "And we need to dispel the myth that reducing emissions and waste (ie living 'greener') will mean a reduction in living standards, in order to make our plans a success. We would argue that this could be a more prominent part of the message. It is vital we get away from the doom and gloom and show that we can create a green future of greater employment, healthier food, stronger communities, warmer homes from better insulation and a future where, instead of hours in traffic jams, we have clean, safe, reliable public transport. A future self-sufficient in energy: a safer world where foreign policy isn't about securing fossil fuels in unstable parts of the world.

3.3. We can make a difference

The acknowledgment in the Introduction (section 2, Green paper) that we can play a part in tackling climate change  is very welcomed. However we consider we could emphasis more that by acting now we can make a difference. It is vital in our view that we empower people to show that all our actions make a difference. There is much work now on how best to educate, engage and empower people re tackling climate change in a positive way. Read for example the very useful "Painting the Town Green - How to persuade people to be environmentally friendly."

3.4. Building an economic future

Cllr Chas Fellows' 'Forward' recognises 'uncertainty over fuel prices and fuel supply' but the green paper does not mention this or argue that these proposals are also about building a stable future (i). There is strong evidence, accepted by governments, geologists and oil companies that fuel prices are set to rise significantly over coming years. We have already seen rises in gas prices by over 70% in 3 years. As Al Gore's new film, "An Inconvenient Truth", spells out very clearly, it is a myth that tackling climate change will cause global economic collapse. As he points out where initiatives have been taken by communities and corporations the effect has been hugely positive.

This green paper should be making it clear that the measures being proposed are also about building a stronger economic future for Stroud District.

3.5. Don't misrepresent situation

Under 'Global problems' the list of problems we can expect from climate change is indeed shocking. However the suggestion in the first paragraph of section 3 regarding the effects of climate change notes that some of the effects will be good and some bad. This gives the impression that the effects maybe evenly balanced between being good and bad. This could hardly be further from the truth: the impacts of climate change are, if we don't act, going to be catastrophic. The temperature rises and extreme weather will have massive impacts on every aspect of our lives: our economy, food supplies and much more will be seriously effected and any so-called benefits are likely to be minimal in the extreme.

3.6. Ecological footprints

We welcome that the Green paper recognises we need to change. The Draft RSS accepts the South West’s ecological footprint is unsustainable as it stands and notes the need to shift from our current ‘three planet’ lifestyle to one where we consume resources compatible with one planet. We consider this approach could be useful in helping people understand the need to change.

4. Additional issues to include in paper

We acknowledge decisions about what issues to include or not in the Green paper are difficult: we however consider the following should also be considered:

4.1. Macro and micro issues are confusing.

We welcome the attempt to cover all aspects of the environment, however we consider that many of the issues relating to public space management are different from climate change and waste. While there are hugely important biodiversity issues we consider that the majority of the Public Space Management issues should be covered in other Council Policy Documents.

4.2. Green Infrastructure Planning.

Given the inevitability of new developments in the District it is important to consider not just where it takes place but also how it is planned and implemented. There needs to be more mention in the Green paper of how the planning system can contribute to reductions in energy use eg by planning developments and individual buildings for maximum passive solar heating - south facing windows etc as well as providing cycle tracks and bicycle storage.

Green Infrastructure Planning provides a means of planning developments that are both wildlife and people friendly. Green Infrastructure (GI) consists of a network of linked green spaces, which meet people’s needs for recreation and quiet contemplation and encourage green transport modes such as cycling and walking, whilst also providing habitats and movement corridors for wildlife. As it is difficult to fit this sort of network into existing or planned networks of grey infrastructure – roads, utilities etc - it is important that green infrastructure is planned before or concurrently with the grey infrastructure (roads, utilities etc). The draft RSS for the South West recognises the importance of GI and it is hoped that such a policy will lead to a new emphasis on GI to be incorporated into the Local Development Documents produced by the local authorities.

See: Kambites et al (2006) Green Infrastructure Planning in the Swindon Urban-Rural Fringe, Countryside and Community Research Unit, University of Gloucestershire, available at:
http://www.glos.ac.uk/shareddata/dms/22B2F402BCD42A03964FAF8895B2E58E.pdf

4.3. Local Spatial strategy and sustainability appraisals.

There is no mention of a local Spatial Strategy, yet we know that having new build within walking distance of shops, schools, bus/train, pub/café, open space has a massive impact on sustainability and quality of life. This may mean higher density building in nodal locations close to these services (the spread of suburbia is increasingly recognised as unsustainable). Therefore the local spatial strategy should be included. The criteria for sustainability appraisal of both Council policies and development proposals needs to be defined within the overal policy.
 
4.4. Nuclear power and waste

4.4.1. Nuclear power is not mentioned in the consultation paper, yet this is an issue that will have implications for residents.

4.4.2. Nuclear waste: last year the 537 locations in Britain, that were previously identified as potential sites for disposing the UK's radioactive waste, were published by the nuclear waste agency, Nirex (Britain’s nuclear waste management agency). This was after they were forced into the public by use of the Freedom of Information Act. The list shows all the 537 sites before they were narrowed down to 12 then to a site near Sellafield that was chosen and subsequently turned down by a public enquiry in 1997. Nirex will now not rule out the possibility of any of the 537 sites being reconsidered. Gloucestershire sites include Aston Down, Berkeley, Hardwicke, Quedgeley, South Cerney and 4 others. The Committee on Radioactive Waste Management (CoRWM) now advocates burying the nuclear waste deep underground. We strongly object to the idea of ‘deep disposal’ (ii). Nuclear waste must be stored in above ground facilities to allow easy access in the event of something going wrong, and to ensure close monitoring. Burying toxic waste deep in the earth is an unproven, unsustainable and unpredictable route to follow (iii).

Incentives are proposed in the form of better roads, schools and other facilities to communities who accept nuclear waste. We do not accept that it is right to take such waste that will result in consequences for future generations living in this area.

4.4.3. Nuclear reactor sites: the Government has said new reactors are most likely to be sited on existing nuclear sites. Yet in the South West all three nuclear sites are at risk of flooding. Nirex reports in its summary of ‘Climate and Landscape Change’ that Berkeley and Oldbury have a “high risk of flooding”, while Hinkley is at risk of “flooding and erosion”. As noted above we still have no solution to nuclear waste and believe that by choosing nuclear power we will be choosing a less safe, more expensive, less popular and environmentally unsustainable option. The Government’s Sustainable Development Commission published a report on whether new nuclear power stations should be built in the UK. It concluded that no justification exists for implementing a new programme of construction for nuclear power. The Council should choose to take a lead like other Councils and support a green energy revolution rather than accepting nuclear power.

4.5. Measuring success

We have already mentioned the need for targets, but it is clear we also need to know how and what to measure. Without such a measurement we cannot assess improvements. This is an enormous challenge: some issues will be easier than others to measure. We welcome the move to improve data collection of energy use as this will be very useful in finding the way forward.

The Council's current move to develop Sustainability objectives in consultation with the public could be useful in measuring improvements across the whole District in a range of areas. For example it has been suggested that enhancing biodiversity could be measured by the number and condition of SSSI's and key sites, the number of TPO's, the percentage of greenfield sites and species indicators. However experience has shown that indicators can distort the reality: school league tables and hospital waiting lists are examples of this.

Other Councils are developing ways forward with this and we can no doubt learn from them. The Government have also just produced "Sustainable development indicators in your pocket 2006". The way those indicators are calculated could also be useful.

4.6. Costs/benefits

Clearly we at the early stages, but we need to assess what each project can bring in terms of benefits: sometimes these will be difficult to measure. For example a hydro power scheme will produce energy and an example that may encourage other projects to develop, but that same money put into energy efficiency measures may make more savings in terms of CO2 emissions and finance?

4.7. Staff training and costs

We consider that if this Green paper is to go forward with these projects then it will need more staff time and training to implement. A number of the measures will also have costs attached to them. We would argue that these could well mean that a rise in Council Tax is necessary: the measures are vital to build a strong local economy, reduce fuel poverty and tackle climate change. Many of the measures pay back within a few years and so are a good investment for the District.

4.8. 100% Renewables

We applaud the Council's commitment to a 'green' tariff: 97% of electricity supplied to council buildings was sourced from methane from landfill sites and we welcome plans to diversity purshasing of renewable electricity. We hope to see a rapid return to 100% purshasing of renewables and research into possibilities of schemes like Woking council's decentralised energy system (as celebrated by David Cameron) that offer opportunites for financial and carbon savings. See more re Woking: http://www.woking.gov.uk/html/queensaward/W-13.pdf

4.9. Transport

Transport and its huge contribution to climate change gets too little mention. While this is a hugely complex area it is vital it is given more space and consideration. In section 5 for example under  "How it will work" additional examples could include: cut 'food miles' by buying more local produce/goods, encourage more "walking buses" for schools. We need a complete review of transport related issues in the area and projects like the Interchange need to be given the highest priority.

4.10. Reducing waste
 
Reducing waste should be a higher priority with more emphasis on schemes to encourage Car Boots, use of charity shops and schemes like Second-hand Swap Sundays. The Council could talk to local businesses, particularly supermarkets and encourage more significant moves to reduce packaging ands waste.

4.11. Nottingham Declaration

The Council has talked about  joining the 130 or so Councils who have signed the Nottingham Declaration: a pledge to actively tackle climate change in their area and work with others to reduce emissions country-wide. So far Stroud District Council and Gloucestershire County Council have not signed, but locally Cheltenham Borough has signed. See: http://www.est.org.uk/housingbuildings/localauthorities/NottinghamDeclaration/
Other Councils like Norwiich and Bristol are also making a stand by completing motions to push for a national policy of Contraction and Convergence (iv): a policy that is seen by many across the political spectrum as the fairest and most likely to succeed internationally.

4.12. Need to fast track

Don't wait for Green paper. We can fast-track key policies. For example:
- schemes for composting biodegradable waste - such waste  makes up 40 to 60% of all household waste.
- Supplementary Planning re more energy efficient homes and renewables: many other Councils are leading the way on this and have shown it works. No members of the public we have spoken to disagree with the need to build houses that will cope with the problems of oil depletion and more severe climate conditions. See more re Milton Keynes:
http://www.est.org.uk/uploads/documents/housingbuildings/energy_planning_and_bc_miltonkeynes_cs.pdf
The London Borough of Merton, a pioneer in this field now has a website named after it: The Merton Rule:
http://themertonrule.org/the-merton-rule

5. Next steps

Our comments are by no means comprehensive. We welcome an opportunity to engage further in this process to develop a strategy for Stroud District.

There is much expertise and knowledge within the Stroud area and green issues are being seen as increasingly important by the public. The time is ripe. Let's do it!

6. Notes

(i) More re Peak Oil scenario: 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. The only viable option is to move fast towards renewable sources of energy, like wind power, biomass, tidal power and solar - plus reducing energy demands. 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.

(ii) See Glos Green party report at:
http://www.glosgreenparty.org.uk/index.php?option=com_content&task=view&id=1065&Itemid=72

(iii) In the past we have made miscalculations with the result that some nuclear storage containers quickly fell into a state of serious disintegration. Fortunately those containers have now been refurbished, but this experience clearly indicates the difficulty of assuring the lifetime of waste containers for hundreds of thousands of years when they are deep in the ground. In such circumstances, it cannot be known what geological or climatic changes will impact upon the containers or the waste in the event of further miscalculations or other errors, nor what the scale of any damage to the land or the population might be. Blair said in the past that new reactors cannot be built until there is a plan for disposing of radioactive waste. An editorial in New Scientist magazine notes that "Some advocates of nuclear power will doubtless argue that CoRWM has now provided that plan. This is optimism gone mad. Deciding to put waste down a hole, with no idea what form the repository should take or where it should be, is no more of a plan than has existed for the past 30 years." We do not have a solution to the problem of what to do with nuclear waste. CoRWM has said that disposal deep underground is the "best available" long-term solution for the waste, but has not expressed any preference for the type of geology in which a repository should be built. Nor has the committee been able to say whether the waste should be retrievable or not.

New Scientist 6th May 2006
http://www.newscientist.com/article/mg19025503.000.html

See the Green Party’s Alternative Energy Review is available at:
http://www.greenparty.org.uk/files/reports/2006/finalfinalTheAlternativeEnergyReport.pdf

(iv) See more re Contraction and Convergence at:
http://news.bbc.co.uk/1/hi/sci/tech/4994296.stm

Ends