Stroud District Green Party

Comments on Stroud District Council Draft Environmental Strategy and Delivery Plans

Version that went to Cabinet 7 December 2006
Deadline for comment 15 January 2007

Submitted by Cllr Martin Whiteside on behalf of Stroud District Green party: 14 January 2007

Introduction

The Green Party welcomes this opportunity to make a third submission on this strategy development process.  We note substantial improvements since the initial draft presented for consultation in Autumn 2006, particularly with the inclusion of some targets and delivery strategies.  We realise that the document presented to Cabinet is still a work in progress and we look forward to further substantial improvement.

General Points

1. The strategy is weak on proposed actions beyond the ‘immediate priority actions’ listed.  This is supposed to be a strategy for 2007-20027 and we would expect to see some more longer term actions suggested, even if these need subsequent revision with experience.

2. The delivery plans are weakly linked to the proposed strategy and the targets in the strategy are not carried forward into the delivery plans.  Therefore it is not clear how and whether the delivery plans will actually deliver the targets set-out in the strategy.

3. Many of the targets seem to reflect Government minimums.  We would like to see Stroud do better than this.  In addition we would like to see more ‘early weighting’ of targets – as earlier savings have both a more beneficial overall impact on climate change and are easier to achieve.  We would also like to see more management orientated target intervals – rather than long gaps in which slippage can occur.

4. There are significant gaps in the strategy including: 

4.1. Transport is a major polluter that could wipe-out all the gains made elsewhere, it was also the 5th most common issue arising from the consultation. Although not a direct responsibility of the District there are important opportunities to work with others to influence this sector which have been missed in the strategy.  More could also be done to green the Council’s and our contractors transport.

4.2. Targets and strategies to enable local businesses and social enterprises to produce more sustainably for the local markets and to profit from new green opportunities are weak or non-existent.

4.3. There are no clear plans to improve the water quality in our streams.

4.4. Some key ‘Local state of the Environment Indicators’ (Appendix 3) are not addressed by the strategy – they should be addressed.

Priority 1 – More for Less

1. The recycling targets are too low - 2014/15 targets compare unfavourably with what some of the best performing UK Councils are already achieving and the 2019/20 targets compare unfavourably with what some European  countries are already achieving.  We would like Stroud (and Gloucestershire) to be a leader, not a follower in recycling.

2. Recycling targets should make it clear that the rates do not include garden waste (composting should be prioritised to deal with garden waste and if collection of garden waste is to be included in the future then considerable more ambitious targets will be needed.

3. The single most important target is omitted – the need to reduce the total waste produced per head.  We would like to see ambitious targets for this (and to be achieved without use of incineration).

Priority 2 – Confronting our Greatest Threat

1. As this is the greatest threat it should be Priority 1.

2. We recognise that the planning guidance action has been overtaken by recent Government guidance and would like to see a revision in light of this.

3. 40% house:3.1. We would like it made clear whether the percentages of houses reaching the ‘40% house standard’ refers to new build or to the existing stock.
3.2. Why acknowledging the usefulness of ‘exemplars’ – it is important also to note that this is not the most efficient way of achieving climate change savings – see below.

4. There is no proposed action for 99% of existing dwellings prior to 2010 (some actions are mentioned in the delivery plan and under ‘community aspirations’, but no actions or quantification are given in the strategy) – there needs to be.  This is probably where the most significant and cost effective saving can be made and should be a priority – particularly on the quick wins of insulation and draft proofing.  In addition to targeted grants, we would like to see the Council investigate the possibility of loans for energy saving measures – to be paid back out of the household’s cost savings.  This should be part of the ‘one-stop shop’ approach.

5. We would like to see Stroud Valleys Project included alongside the Gloucestershire Wildlife Trust in understanding the impact of Climate Change on the District’s natural environment.

6. Under the aspirations for community savings of 17%, 30% & 60% of Carbon dioxide emissions:
6.1. Although there are reasons for using a 1990 baseline, we also need to know where we are now, in order to be able to know the immediate challenge and measure progress to 2010, 2020, 2035.  Are these figures available at District level?

6.2. Transport needs to be included in these figures.

6.3. New research from the Tyndale Centre and elsewhere suggests the targets given are too low – there needs to be provision for reviewing these figures in light of the latest scientific guidelines. 
6.4. Why is the 2010 figure 17% compared to the Government guideline of 20%?

6.5. Typo - the renewable energy should be MW not mW (a mega-watt is somewhat different from a milli-watt).

Priority 3 - Clean, Green and Safe

1. We would like to see new major development and all development covered by the Canal Area Action Plan to be designed and managed to maximise biodiversity.

2. We would like to see a clear strategy for making our streams safe and healthy for wildlife and safe for our children to paddle in.

3. Streets and roads make up around 40% of public space.  We would like to see ‘safer streets’ made a commitment, including prioritising use by pedestrians and cyclists, ‘shared space’ schemes, 20mph limits in all residential areas and close to schools etc.

4. We would like to see a clear commitment to work with others to decrease traffic, increase bus usage, achieve a transport interchange and practical strategies to achieve these.  This should include spatial strategies in local development frameworks that reduce vehicle movement and support public transport, walking and cycling.  This should also include policies in favour of local facilities such as POs, shops, car clubs etc.

5. We would like to see a clear commitment to the canal corridor being a green transport route, including suitable provision for walking and commuting cyclists.

Priority 4 – from local to global

1. ‘Keeping the Council focussed on environmental limits’ will require a step change in understanding and attitude by councillors and officers in all areas of our work.  This needs training, new procedures and new attitudes – this needs to be planned and action taken.  How much is really being done to implement, update targets and monitor the Councils 1999/2000 travel plan with its 2003 targets?  What happened to the 1996 SDC Environmental Strategy?

2. We would like to see a number of initiatives suggested during the consultation to be actively investigated as part of the next stage of the process.  This could include:
2.1. The viability of a wood re-use project (not just wood-chip burning).
2.2. The viability of using bye-laws or other incentives to reduce free plastic bags from shops.
2.3. Expand the work with others to build the local skill base necessary for a greener economy;

3. We would like to see Stroud’s rich cultural heritage actively used to promote and reinforce the strategy – making the task more fun, interesting and sustainable.

Appendix 3 – Local state of the environment indicators

1. This list needs clarity on how these will be measured and how often, the current baseline and the targets. 

2. Targets should be referenced through to the strategy and delivery plan to ensure that sufficient action is being taken to reach the targets – otherwise the process is flawed.

3. Care is needed with ‘perverse targets’  (e.g. reduced pedestrian and cyclist road casualties can be achieved by less walking and cycling – rather than by making walking and cycling safer!)

4. Target 42 should include travel to school.

5. The council should look at the possibility of using a more holistic ‘footprinting’ methodology for monitoring overall progress.

Delivery Plans

1. These need to be strengthened to actually deliver the strategy, including clear linkages to the targets in the main strategy and Appendix 3 and with clearer milestones.

2. There is (inevitably) lots of jargon and acronyms in the delivery plans, which make them inaccessible to outsiders.  This requires a clear glossary and more explanation of some of the initiatives in the text.