31st March 2007

As part of the new planning system future planning policy documents will need to be accompanied by Sustainability Appraisals. These will examine such issues and how they feed into the policies of the relevant plan. The council has commissioned a scoping report for future sustainability appraisals and we need your comments on the methodology proposed. The scoping report is intended to define the key environmental and sustainability issues for the whole of Stroud District. It is available on Stroud District website.

Green party submission re Local Development Framework Sustainability Appraisal Scoping Report 2007

Compiled by Cllrs Philip Booth and Sarah Lunnon

Introduction

The production of this sustainability scoping document is to be welcomed, as is the process of consultation that is taking place.

Our major comment of the document is that while it raises many important issues of sustainability it fails to address sufficiently key sustainability issues of robustness of the local economy, climate change and local food and fuel security (energy production).

Sections on waste and climate change appear less robust than Stroud District Councils own Environment Strategy paper and are not satisfactorily integrated into other sections. Indeed by listing climate change as chapter 10 it seems to suggest equal weight is attached to this as the other areas of consideration.  We consider that the issue of reducing carbon emissions is so important that it should be included in the majority of the SA / SEA objectives.

In many ways this appears to be a “business-as-usual” approach when what is needed is more radical action.

We welcome the opportunity to have further discussion and input into this important report.

Comments on report

The following comments relate to the particular sections in the report:

3 Health

3.6 An increased focus on healthy lifestyles is required

3.7 SA / SEA Objective – To maintain and improve the community’s health with accessible healthcare for residents.

Over the last 20 years several Nordic countries have increased the health of their nation by designing an environment in which exercise has become part of everyday living (walking and cycling as transport not leisure pursuits), rather than something undertaken as an activity (eg as a sport or in a gym)

Objective:  

• Increase in cycling and pedestrian activity, increase in independent mobility for children.
  
•  Address the design of streets and roads and traffic speeds so people will cycle and walk from choice.

4 Economy

4.5.1 Promoting tourism makes no mention of the environmental impact of tourism. CO2 emissions from extra travel. No mention of help to industry to reduce its environmental impact or support environmental initiatives. No mention of how climate change is likely to affect the economy, no mention of localisation of markets, energy supplies or food production.

Further promotion of tourism locally is viewed as a positive way forward yet there is no analysis quoted to support this: tourism can have a negative impact on the economy (it is very sensitive to external factors changing, increased air fares, fears of terrorist activity, change in fashionable destinations), availability of housing and the environment as noted in section 14 Biodiversity.

Tourism expansion seems to contradict the aim in section 5 to provide high paid employment to help reduce commuting out of the district.

4.4 It is clearly difficult to predict how economies will develop. The draft Regional Spatial Strategy 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). Indeed there is rising concern about the remaining levels of oil supplies.

Peak Oil is the point at which oil production rises to its highest point before declining. Almost all expert opinion 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. This will impact considerably on the economy yet there is no analysis of this.

In part as a response to this Sweden is planning to be free of oil dependence by 2020 while others like Portland City Council, Oregon are developing specific strategies to address key  vulnerabilities resulting from the uncertainties around supply and affordability of oil.

Objectives - to adopt the draft Regional Spatial Strategy's Strategic Sustainability Assessment (SSA) alternative approach to the regions development. That report notes the Draft RSS aim to develop the economy within environmental limits, and the uncertainties outside of the control and influence of the South West. To that end the SSA 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).

In section 4.33 of the SSA it is noted: “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.

Stroud District Council's submission to the draft RSS called for a look at this alternative.

5 Employment

See response to section 4. We would question the assumption that economic growth is required and that it needs to be employment led.

5.3.1 Specific mention of Creative industries and their growing contribution to the economy has been omitted from this section and the Employment section. Yet they currently contribute £808 million annual turnover in Gloucestershire (ie 4.2% of total turnover).

Objectives – To develop employment that is less dependent upon national and international links, which has reduced exposure to external factors, making it more resilient to outside shocks, and at the same time reduces its ecological footprint.

6 Transport and Accessibility

6.6 Objectives - To promote traffic reduction and encourage more sustainable alternative forms of transport.

Section 6 does not mention cycling: in some parts of Europe 60% of commuter traffic is by bike. This figure is because of a planning and transport regime which has design transport by bike into its built environment. It has not happened because of a fundamental difference between us and N. Europeans or a difference in topology or weather conditions. This is particularly relevant for children as it is the only legal means which they can use to travel moderate distances independently.

Falling levels of pedestrian activity and cycling is not identified as a problem, neither is the reduction in child independence due to parental assessment of roads as too risk for children to access without supervision.

There is no acknowledgement that increased pedestrian and cycle rates can help meet health and environmental targets.

No identification of social street activity as a fundamental use of the road network. Social street activity helps to form community relations and reduce feelings of isolation.

Proposed Objectives -

• Increase cycle journeys taken by all age groups
• Increase pedestrian journeys by all age groups
• Ensure cycle and pedestrian routes form a fundamental not negotiable part of all new development.
• Identify social street activity as part of building sustainable communities
• Reduce journeys taken by private car

7 Crime and Safety

What steps will be taken to ensure that a reduction in road fatalities and casualties figures is based on roads being safer and not on vulnerable road users retreating from or limiting their access to the network?

The feeling and ambiance of roads needs to be addressed rather than relying of figures to prove that roads are safe. There is a need to socialise roads rather than relying on speed and casualty figures, this is an important safety concern which is quite literally on residents doorsteps and regularly tops their list of concerns.

Proposed Objectives – To provide pleasant roads and streets designed to accommodate all traffic at 20 mph in all residential areas with a minimum of signage and heavy engineering.

8 Housing

Proposed Objectives:

• Zero carbon development
• Micro energy generation at source,
• Tackling the current housing stocks CO2 emissions

9 Cultural Landscape

The importance of architecture that is not listed should also be recognised. The appearance of streets and the affect of signage and road furniture should become more important and a recognised civic function of one statutory body. Entrances to civic areas and public buildings should be improved eg, parks. Locally important and distinctive buildings should be recognised.

Proposed Objectives:

• Use of planning legislation to ensure that all new build complements the historic cultural landscape.
• Ensure that streets and roads are recognised as part of the cultural landscape and that importance is attached to their appearance. Streets and roads account for over 60% of open public space.

10 Climate Change

It is our consideration that this section should be relatively small and that all other sections of this document should contain climate change objectives. Each sections objectives should state how they will contribute towards meeting CO2 reduction targets.

Climate change is not an exact science, many scientists are now calling for a 60% cut in emissions by 2025.

With regard to vehicle use in the district it is worth considering that all of the out-lying villages in the district developed without the provision of private motorized personnel transport.

Proposed Objectives:
 

• Remove bio-fuels target, evidence suggests that the production of bio-fuels produce large amounts of CO2
• Reduced the mileage for undertaken by SDC staff, reduce the amount of fossil fuel used
• Use electric cars supplied by renewable resources

12. Soil

Organic farming has a key role in soil protection and should be supported. Organic farming also does not require the massive energy inputs in the form of fertilisers, pesticides etc and so can help tackle climate change and reduce our reliance on oil.


13. Water

We need improved community access to rivers and streams, improved water quality and greater application and emphasis on Sustainable Urban Drainage Systems (SUDs).
 
The likely increase of drought and flood conditions resulting from climate change will have a massive impact which has not been satisfactorily explored

Other issues that have not been taken into account sufficiently:

• £313m spent each year dealing with pesticides, nitrates and other contaminants ie 10% of costs of drinking water
• raw sewage is regularly discharged into our brooks and streams
• clean-up of water supplies uses chemicals and energy intensive ultra-violet treatment: the water industry emits 2.6% of UK carbon emissions
• most of us flush 50 litres of water down the loo everyday: need for more greywater solutions and water conservation measures
• power station cooling accounting for 39% of national water
• consumption: our current methods of sewage treatment and water supply are very energy intensive - a move towards more reed beds and other SUDs solutions would have a significant impact.

15. Landscape

- a wider debate is needed about what constitutes a valued landscape.  Gloucestershire Highways last year cut down many hundreds if not thousands of roadside trees justifying it as "Maintaining and restoring the character of a distinctive landscape" - yet the Cotswold landscape is itself, man-made and once upon a time was wooded. The loss of the significant wildlife benefits from mature trees that also filter transport pollution and tackle climate change should be part of the equation.


16. Waste

Failure to mention 'Pay as you Throw' or discounts for those who produce less waste as a way of reducing the increasing in tonnage.

Proposed Objectives

• Consideration of strategies to reduce quantity of waste produced Introduce a ‘pay as you throw’ scheme
• Introduce financial incentives for those who produce small amounts of waste
• We need to state opposition to incineration. Incineration has a number of issues associated with the process, including concerns over air quality and highly contaminated residual by-product. Incineration contracts can lead to the production of waste to meet legally set quantities.
• 
    Pyrolosis might be acceptable for a small limited amount of waste.
  

ENDS