Introduction 

We recognise that the task of setting targets within the strategy is not easy. However to avoid the environmental strategy being a list of good intentions, SDC needs to be clear what targets it is trying to achieve through the strategy and how it will go about achieving them. This is accepted good management practice.

Below are 8 minimum requirements for an acceptable environmental strategy (this list is not exclusive – other issues also need to be tackled – we have just outlined 8 of the most important without which the strategy would be meaningless). These requirements cover those things that SDC must do to put its own house in order and what it needs to do to promote sustainability among households and businesses in the District [1].

This report was written before seeing the draft possible targets just released by SDC. We welcome this move and while we have not considered these fully we recognise that the targets split into control and influencing targets is a sensible move. The range and types of target are good although there is no influencing target for transport and none for non domestic buildings or businesses. We also recognise that long timeframe targets don't work very well which is why we have set an annual target.

We look forward to further discussions about proposed targets, priorities and implementation. One key aspect to consider will be how the District will devolve power and funds to Parishes and Towns to enable them to take these ideas forward.

Cllr Martin Whiteside on behalf of Stroud District Green party
5th November 2006


Contents

1. Overall Goals
2. Waste Reduction, Re-use and Recycling
3. Energy use in buildings
4. Transport
5. Green Spaces, Green Infrastructure Planning, Water and Flood Management
6. Local Energy Generation
7. Encouraging a more sustainable economy
8. Monitoring and Adjusting
9. Notes


1.  Overall Goals

Clear goals are required to which the other components of the strategy contribute. Two goals are suggested:

1a – An annual reduction of at least 3%  in greenhouse gas emissions[2] by the SDC and by households and businesses within the District [3].

1b – Maintaining and enhancing the biodiversity, environmental quality and access to greenspace for those living and working in the District [4].

Points 2-8 below suggest some of the key ways these overall goals can be reached.



2. Waste Reduction, Re-use and Recycling

Stroud currently produces and average of 345 kg of landfill waste per person per year and recycles 22%. This compares with the best performing Boroughs of x? kg waste and 40% plus recycled [5].

2a – To achieve a yearly reduction of waste sent to landfill of 3% and to reach and remain in the top 10% nationally of low waste producers by 2007/8.

2b - To exceed the Government target of a reduction in the amount of biodegradable waste going to landfill by 65% in 2020 compared to 1995 levels.

 2c – to recycle 36%[6] by 2007/8 and to achieve a 5% annual improvement in recycling thereafter; and to reach and remain in the top 10% of Councils nationally for recycling by 2008/9.

 To achieve this some of the actions that will be required are:

- More public education about what can be recycled on the doorstep and at other sites.

- Three stream waste collection (recyclables – including cardboard and all plastics, kitchen bio-degradables, and landfill): look at moving towards some fortnightly collections.

- Community composting schemes like Bisley in every Parish.

- Local composting of kitchen bio-degradables.

- Aim to reduce waste arising from council buildings.
 
- Promotion of re-use enterprises – wood, furniture, ‘Gloucestershire Freecycle’, ‘exchange sheds’ etc.

- Promotion of ‘real nappies’.

- Work with retailers and consumers to encourage less packaging.

- Work with local business to encourage ‘Reduction, Re-use and Recycling’.

- Look at the possibility of by-laws to encourage supermarkets to charge for plastic bags and charge fast food outlets to pay for the litter they cause.

- Continue special measures to assist older and disabled people with their recycling and waste disposal.

- "Pay-as-you-throw" measures maybe needed in future if above policies are not effective in reducing waste.



3. Energy use in buildings

Buildings account for an around one third of total energy use. Three quarters of that is energy for heating and hot water, the remaining quarter being electrical. Emissions are however more evenly split between heat and electricity as the latter involve large inefficiencies in conventional production and supply. The targets suggested will bring SDC in line with the best performing Councils in the country:

3a – Reduce the non-renewable energy used by Council owned and/or run buildings by 3% per year.

3b – Use planning policy to require the highest enforcable standards for all new developments. For example a Eco-home/BREEAM standard of ‘good’ or better, all new developments over 5 houses or over 1000 sqm to reach ‘very good’ or better[7].

3c - All new non-residential development above a threshold of 1,000 sqm will be expected to incorporate renewable energy production equipment to provide at least 10% of predicted energy requirements[8].

3d – Provide advice, support and incentives to enable existing dwellings and non-residential to reduce non-renewable energy use by 3% per year.

To achieve this some of the actions that will be required are:

- To develop planning policy to incorporate highest standards of energy efficiency for new build, extension and renovation.

- Ensure building control has the resources and tools required to fully implement the standards.

- Work with local training colleges to provide training for the construction industry in working to the new standards.

- Work with GCC to establish a Gloucestershire Sustainable Building Trust (as already exists in most other counties in the SW).

- A survey of Council owned buildings and an investment plan, linked to maintenance schedules, to achieve the necessary reductions through insulation, energy use efficiency measures and the increased use of renewables.

- By end 2007/8 an adopted Local Development Framework detailing energy efficiency standards.

·- Increased publicity, advice, financial support and simplified planning procedure for domestic energy saving and domestic renewable energy generation [9].

- Promotion of an annual award for ‘Sustainable Development’ within the District.

- Return to purchasing 100% of the Council's electricity from sustainable sources by 2006/7.

- Consider a target of purchasing 100% of the Council’s thermal energy requirements from sustainable sources by 2010/11.

- Explore possibilities of encouraging all householders to switch to a green tariff for their electricity use: arrangements could be made with green energy providers like Good Energy or Ecotricity to ensure financially competitive prices.



4.  Transport

Transport accounts for 25/30% of greenhouse gas emissions and has been one of the fastest growing sources. Traffic noise, accidents, fear of accidents, congestion and pollution are also major environmental hazards in the District. Although transport is not a direct responsibility of SDC the Council has significant points of leverage:

4a – Work with others to establishing a transport interchange in Stroud and reverse the decline in bus usage throughout the District.

4b – Work with others to reduce lorry and car traffic throughout the District and the environmental impact of this traffic.

4c – Reduce the environmental impact of SDCs own transport, contractors and travel to work needs by 3% per year.

To achieve this some of the actions that will be required are:

- Take a leading role in establishing the transport interchange in Stroud.

- Ensure that the Canal regeneration is accompanied by a cycle track suitable for commuting.

- Support the implementation of ‘Shared Spaces’; 20mph limits in residential areas and near schools; safe, pleasant and direct walking and cycling routes to schools, shops, jobs and services.

- Work with the County Council to promote accessibility to buses and trains.

- Ensure all new developments are designed to facilitate walking, cycling and access to public transport. Developments should also include measures like car sharing schemes.

- Strengthen spatial strategies which ensure that new developments, whether residential, employment, retail or services reduce the need to travel by car or transport by lorry.

- Revise and monitor SDC’s Green Travel Plan to ensure the targets are sufficient and achieved so that the 3% annual target is met[10]. New initiatives will be required such as car sharing clubs and appropriate incentives to share lifts or to use more energy efficient transport.

- Council contracting procedures (principally for household waste collection) to support a 3% annual reduction in environmental impact (energy efficiency of fleet, biodiesel, location of depots etc.)

- Promotion of schemes such as car clubs, lift share registers, home delivery etc.

- Support rail improvements: the reintroduction of the second track from Stroud to Swindon, to increase the frequency of both passenger and freight trains and improvements to the line from Gloucester to Bristol (Parkway and Temple Meads) to increase use and reduce car journeys to Bristol.

- Where SDC is a consultee, to have a presumption against schemes and strategies that increase overall greenhouse gas emissions such as airport expansion and large road schemes[11].
 


5.  Green Spaces, Green Infrastructure Planning, Water and Flood Management

Green spaces and green corridors produce many benefits for wildlife and for people to connect with the countryside, for health and wellbeing [i]. This needs active planning, management and protection – not an afterthought after roads, canals and buildings have been installed. Climate change is predicted to result in more severe storms and also dryer summers – therefore there is a need for both flood prevention and management and drought mitigation.  Pumping domestic water and sewage is also a major user of energy.

5a – Create and maintain a coherent network of accessible, multifunctional sites (including parks, woodland, informal open spaces, nature reserves and historic sites) as well as linkages (such as river/canal corridors and floodplains, wildlife corridors and greenways) that enhance wellbeing.

5b – Enhance biodiversity of the District

5c – Improve flood management, water use and sewers in the District

To achieve this some of the actions that will be required are:

- Carry out an audit of Green Space provision in the district and, in consultation with local people, produce a map showing green spaces and the links between them.

- Manage existing green spaces for people and wildlife [12].

- Specify appropriate native wildflower low maintenance mixes for all amenity planting in new house and industrial development

- Use the planning system to improve the network of green spaces by the use of site-specific development briefs or area action plans and planning conditions on specific development proposals. All planning application for one or more new house must include an implementation plan to improve the biodiversity of the development site within 3 year of completion of the development. All new industrial development to contribute to delivering one or more targets in Gloucestershire Biodiversity Action Plan

- Set targets in new LDF for creation 100ha of new reedbed and wetland habitat within the plan period.

- Delivery of all targets already signed up to in Gloucestershire Biodiversity Action Plan

- Full implementation of the new duty under Section 40 of the Natural Environment and Rural Communities Act to conserve and enhance biodiversity in all thier activities.

- Become local champion for one local or nation Biodiversity action plan priority species (eg water voles, great crested newts, white clawed crayfish or pipistrelle bats - the latter would be the easiest  as bat boxes could be included in all suitable council buildings and be part of planning conditions in new build)

- Designation of 5 local nature reserves of the next 5 years

- Provide 5 year memoradum of agreement with biological record centre.

- Put in artificial otter holts on council owned land at Ebley mill

- Develop a stronger policy to promote allotments: transport of food generates a significant proportion of the pollution generated by vehicles. The need to reduce food miles is widely recognised. One of the ways of achieving this at the district level is through supporting local retailers who purchase locally and through encouraging local people to have allotments.

 - End growth in impermeable surfaces: Severn Trent Water estimate that areas of hard standing (housebuilding, roads, drives and patios) in their region are increasing at 4% each year. This adds considerably to drainage problems which are likely to get worse in future years with more extreme weather conditions forecast. Porous areas of hard standing should be encouraged in all new developments and householders and businesses made aware of their importance.

- SDC should support house builders in reducing the amount of water used in the construction of new developments and should consider opportunities to more effectively manage water resources during the lifetime of the development. Such initiatives would include policies that support incorporating water minimisation devices into dwelling designs, enabling grey water recycling and rainwater harvesting and landscaping and planting that requires minimum watering.

- Support and expand the use of 'Sustainable Urban Drainage Systems (SUDS).

- Reduce pollutants getting into water courses: Poole Council for example have introduced a "Yellow Fish" scheme where drains are labeled to discourage inappropriate use.

- Oppose measures to introduce GM crops into the District.

- Encourage measures to reuse water eg water butts.

- Reduce water use from Council facilities.

- Continue to support and coordinate developing sustainable solutions to local watercourses.

- Improve awareness re public health issues relating to sewage discharges.


6. Local Energy Generation

Community scale renewable energy projects have the capability of delivering a significant proportion of the energy consumed locally, particularly when overall energy consumption has been reduced by efficiency and energy saving measures. This not only reduces carbon emissions but also reduces dependency on fossil fuels which will continue to become more expensive and less secure. It is also good for the local economy and will help achieve the sustainable economy targets.

Note: due to the very low base a % increase per year is not realistic as target for growth of renewable energy generation. There is also significant lead time in setting up many community scale projects, for example establishing biomass harvest will take several years minimum. However once more detailed plans are in place intermediate targets should be set and assessed to ensure the longer term 2020 targets can be achieved.


6a - To exceed, at a local level, the UK government target of 20% electricity generation from renewable sources by 2020.

6b - To reach at least 10% provision of heating fuel from local resources by 2020.

6c - To reach at least 10% provision of biofuels from local resources, either recycled cooking oil or locally grown feedstock.


To achieve this some of the actions that will be required are:

- Promote the installation of appropriate micro renewables on all types of buildings.

- Work to develop a framework for community scale wind power, perhaps based on the Ecotricity merchant wind power model.

- Be an active participant in ongoing process to harness the Severn Estuary tidal flows.

- Encourage local cultivation and distribution of biomass for heating and CHP, for example by facilitating secure long term supply contracts for farmers.

- Actively encourage the use of CHP for larger buildings and high density housing developments.

- Support local production and distribution of biofuels for transport use.

- Implement plans for hydro power scheme at Ebley Mill or use money for a similar
or better performing exemplar project.

- Support the development of plans to exploit the local potential for small scale hydro power throughout the valleys.

- Encourage development of carbon sinks for local offsetting through long term woodland renewal, protection and enhancement of Severn Vale wetlands and encouragement of organic farming practices that lock up carbon in top soil (this also saves energy by lessening the use of energy intensive nitrogen fertilisers).

7.  Encouraging a more sustainable economy

A strong diverse local economy, producing a substantial proportion of the goods consumed by the local area in the local area, tends to be more resilient to external shocks and has greater local circulation of wealth[13]. A more localised economy also generates less traffic, which helps meet District energy reduction targets.

7a – Increase the value of the local multiplier (lm3) by 1% per year[14].

7b – Increase the amount of consumed products being produced within 30 miles[15] of the District Boundary by 2% each year.

To achieve this some of the actions that will be required are:

- Support initiatives (e.g. farmers’ markets, community supported agriculture, local business links) which encourage a more localised economy.

- Support local training institutions to develop ‘Green Technology Courses’ to train/retrain trades-people in energy efficient construction and micro-generation.

- Support local businesses and social enterprises to make use of the new opportunities in recycling and energy efficient technologies etc.

- Integrate cultural initiatives into strategy to help foster more fun, imagination and inspiration.


8.  Monitoring and Adjusting

Having an environmental strategy and targets only makes sense if progress is monitored and adjustments are made in order to reach or exceed the targets. In addition as new research will show whether the existing targets are sufficient and also suggest other approaches – SDC needs to keep up to date with the latest knowledge and adjust its strategy and activities accordingly.

8a – Use an environmental footprint methodology to monitor the overall climate change impact of Stroud District at regular intervals[16].

8b – Monitor a small number of additional indicators to track progress in the implementation of the environmental strategy, use these to produce an annual ‘State of the Stroud Environment Report’ which should include adjustments needed to the plan and the budget requirements necessary to make these adjustments.

To achieve this some of the actions that will be required are:

- An environmental strategy cuts across and requires change in all parts of the Council, this will require a change management process and training of all staff.

- SDC targets need to be annual or biannual to allow for meaningful monitoring and to give a sense of urgency.

- Many of the targets will not be reached without support and change from Central Government – SDC will need to join with other Councils to lobby for appropriate changes.

- Many of the targets will require change by individual citizens, SDC will need to play the role of a community leader on environmental issues. Public Education is particularly important, and this can include feeding-back on progress made by the whole community in meeting targets.

- Commit to the Nottingham Declaration and support the 'Big Ask' campaign.


9. Notes

[1] The targets given in each case are the suggested minimum required – we would be delighted if the SDC wishes to propose tougher targets in any instance or to define them more clearly according to its own criteria.
[2] Kyoto basket of six greenhouse gases (CO2, CH4, N2O, SF6, HFCs, PFCs
[3] The 3% reduction is the amount set by Friends of the Earth and other organisations as part of the ‘Big Ask’ campaign. Achieving the 3% reduction is a joint responsibility of different tiers of government, individuals and businesses, however SDC is expected to do all within its power to ensure Stroud District exceeds the target. Many experts consider 6% to be a more reasonable figure. It is therefore suggested that this figure be reviewed yearly, in accordance with the latest scientific advice, and revised as required – see for instance ECOFYS 2006 – Developing a Carbon Budget for the UK.
[4] SDC needs to develop and monitor some indicators for this target.
[5] St Edmundsbury Borough Council achieves 50.46% and South Glos 41% (Defra 2006)
[6] This was the missed target for March 2006 (Gloucestershire Joint Municipal Waste Management Strategy 2002).
[7]  AECB gold and silver standards develop Eco-home standards further and should be considered www.aecb.net (these have been developed in part by local building energy experts John Willoughby and Peter Warm).
[8] This is the ‘Merton Rule’ in accordance with PPS 22 and is explained in more detail in www.themertonrule.org
[9] See also list of actions recommended by the 40% house initiative www.40percent.org.uk
[10] Current targets do not seem to be sufficient and it is unclear to what extent they are being monitored. Officer time to support this work was reduced in the restructuring of 2006.
T1          To increase commuting by walking from 5% in 1999 to 7% in 2003 and to 9% by 2009
T2          To increase by cycling from 4% in 1999 to 5% in 2003 and to 6% by 2009
T3          Set up a car share database. Target date: 1/12/2001 (was this done?)
T4          To increase the numbers of staff car sharing year on year.
T5          To reduce the percentage of employees travelling to work in a single occupancy vehicle from 74% in 1999, to 69% by 2003, and to 65% by 2006, and to 62% by 2009
T6          To achieve a reduction of 2% from the 2000/01 baseline of business travel miles by car (staff: 489,193;  members 20,832) by 2003/04, and a further 2% by 2007
T7          To produce a sustainable travel map for the site, including timetables, and distribute this to staff and councillors.    Target date: 1/4/02  (was this done?)
T9          To establish a corporate home working policy with the objective of 5% of employees working from home 1 day a month by Dec 02 (= 20 days per month), and 7% by 2009
T10       To follow government guidelines regarding e-government, to reduce the public’s need to travel to Ebley Mill
[11]  SDC was one of the few consultees to criticise the Regional Spatial Strategy for planning to increase emissions, particularly in relation to airport expansion - "all other gains in CO2 emissions will be cancelled out by growth in air traffic alone". Stroud District is rightly concerned that airport expansions in the region would wipe out any environmental gains made by this District and impact negatively on the regions environment and economy. It is inequitable to require local businesses to reduce their emissions further only to see rises in emissions resulting from aviation.”
[12] Whilst some Green Spaces such as playing fields cannot be managed for wildlife and some wildlife habitats would be damaged by too much human use, many spaces can be dual purpose.
[13] This is in compliance with the SDCs submission to the Regional Spatial Strategy which said: The Council agree with the conclusion at paragraph 8.24 of the Strategic Sustainability Appraisal accompanying the RSS where it states: “a reasonable alternative to the draft RSS that should be examined in detail is an approach to development and activity in the region that is less dependent upon its national and international links, and footloose investment. This could help reduce its exposure to external factors, making it more resilient to outside shocks, and at the same time reduce its ecological footprint. Whilst this would go against the grain of current thinking, it may offer alternative sustainability advantages that have not yet been explored.” An investigation of an alternative approach to the regions development may bring the most economic and environmental long term benefits to Stroud District and the rest of the region. There is currently little room to adjust the RSS if economic forecasts change.
[14] local multiplier 3 - lm3 takes its name from the Keynesian multiplier, which has been used since the early 20th century to measure how income entering an economy then circulates within it. The theory is that a change in income has a multiplied impact on that economy. It’s been adapted for use at the local level, with only three rounds of spending measured – hence Local Multiplier 3. See New Economics Foundation. The Local Multiplier 3 (lm3) tool enables a community organisation, business leader, or government official to measure how much an organisation or initiative impacts on the local economy. And more importantly, lm3 helps you work out where you need to make changes to improve that impact.
[15] 30 miles is the limit used by the National Association of Farmers Markets to define local produce.
[16] Advice should be sought on the most cost-effective time interval for monitoring should be.
[i] A commitment to green infrastructure improvement will be a core policy in the LDF consistent with the commitment to green infrastructure planning in the draft Regional Spatial Strategy 2006-2026 (SW Regional Assembly, 2006). Ref: Kambites,C.,Owen, S.et al (2006) Green Infrastructure Planning in the Swindon urban-rural fringe, unpublished report to the Great Western Community Forest, available online at http://www.glos.ac.uk