10th March 2007

Stroud District Green party made another submission to the draft Regional Spatial Strategy a couple of weeks ago. Cllr Philip Booth who helped with that submission and earlier submissions was also instrumental in getting Stroud District Council to sign up to the ground-breaking statement below as their contribution.

The public examination of the draft RSS begins on 17th April and will run for 9 weeks. 

Philip Booth said: "It seems astonishing, but draft RSS plans to increase climate-changing CO2 emissions in the region over the next 20 years. This is despite agreement across the political spectrum that we must cut emissions by at least 60 to 90% by 2050. This RSS document is probably the most important planning document in the South West. It will have huge implications on how Gloucestershire is developed: the number of houses, types of development, investment in transport and more. It has some good points but fails spectacularly when it comes to climate change."

Philip Booth added: "I applaud Stroud District Council for submitting a clear statement that rejects airport expansions and calls for reconsideration of the whole RSS document in the light of the increase in emissions it will give rise to." 

Philip Booth added: "We now await to see if all these comments have been considered properly. Greens have given a huge welcome to the South-East England Regional Assembly who have just demanded a halt to plans to expand the region’s airport capacity. We need to hear the same in the South West."

Each of the statements below had to be copied 30 times to be sent and presented in a certain format so that they could be included in the presentations in Exeter. The Green party's initial report can be found here but there have been various other reports including a report to SDC re their initial submission.

Stroud District Council statement re the Draft Regional Spatial Strategy (RSS).

While noting some significant steps forward in the Draft RSS, StroudDistrict Council notes that the Strategic Sustainability Assessment (SSA)
concludes that the Draft RSS will lead to an increase in greenhouse gas
emissions.

In the light of this and the most serious threat climate change presents, we
urge a reconsideration of the Draft RSS. We need a strategy that ensures the
region plays its part in reducing CO2 emissions by at least 60% by 2050 in
line with current Government guidelines. A strategy that will lead to a rise
in emissions is wholly unacceptable.

We recognise this is a significant challenge, but we consider that the
scientific evidence on climate change leaves us no other option. An
important step in the right direction could be made by ending support for
airport development proposals in the Draft RSS. We note that the SSA
concluded, that if such proposals go ahead then "all other gains in CO2
emissions will be cancelled out by growth in air traffic alone."

Final Stroud District Green party statement re draft RSS

1. Climate change

We believe that the the RSS is woefully inadequate in addressing the issue of climate change, to the extent that it is morally criminal. The Greens have worked hard to try to ensure the regional planners took climate change and congestion into account when developing the RSS, but these efforts appear to have been largely ignored. The Sustainability Appraisal of the strategy clearly states that this plan means carbon emissions will rise and not fall, traffic congestion and pollution will worsen and the region will not be prepared for the effects of global warming.

It is alarming that the SSA concludes that the RSS is “highly unlikely” to reduce non-renewable energy consumption and greenhouse gas emissions.

As this plan has been judged to be unlikely to reduce emissions, it is therefore contrary to Government and many local council policies. The SSA identifies transport and higher performance in energy efficiency across the domestic, industrial and commercial sectors as two key aspects that need more work. The document should be clearly indicating the method of progressively reducing carbon use. This would be in line with the Government’s official climate change objectives, namely to make a cut of 20% of CO2 emissions from 1990 levels by 2020. By the year 2050, the Government accept a 60% reduction is required to maintain stability of a 2-degree temperature increase at the current level. But many scientists are now arguing that we have already crossed critical thresholds on climate change and ecosystem degradation. They assert that these figures are an underestimate of what is needed and actually considerably larger cuts are necessary.

We believe that no airport expansion proposals should go ahead. The SSA draws the conclusion that if expansion does go ahead, then all other gains in CO2 emissions will be cancelled out by growth in air traffic alone. The Government’s target to cut emissions by 60% by 2050 will be a virtually impossible target to be met if aviation emissions continue to grow at the current rate. Improvements in aircraft technology can deliver only a 1% per year cut in emissions, so that in order to only stabilise emissions the greatest possible growth in passenger numbers could be not more than 1%.

We cannot overstate the importance of our grave concerns that the RSS will lead to an increase in greenhouse gas emissions. This increase will have huge impacts on our environment and our economy. In our view this is unconscionable and it is essential that the extent of its potentially damaging effects is fully recognised. The SSA’s identification of transport and higher performance in energy efficiency indicates that these issues require greater consideration in the RSS along with the other measures mentioned, and the reduction of waste and unnecessary consumption. As the Stern Report has graphically illustrated, doing nothing to combat climate change now will cost us dearly in the long run. The Strategy has missed an opportunity to tackle the country’s number one challenge, and its own SSA admits as much. The only acceptable strategy is one that plays its part in meeting greenhouse gas and other sustainability criteria.

We strongly recommend a rejection of this dangerous and morally indefensible plan. The only acceptable plan would be one that accepts cuts in carbon emissions in line with Government targets.




2. Sustainability Appraisal - to what extent the SSA informed the RSS

It is evident that the Strategic Sustainability Appraisal is not having sufficient influence upon the RSS, which makes us question its purpose and value. There are many instances where the aims of the RSS and its SSA are at variance, and there seems little point in having an SSA if its findings are to be disregarded.

The objectives of the Draft RSS in “What Sort of Region Do We Want To Be?”, are focused entirely upon development and economic growth, with no emphasis given to quality of life, equality, reducing poverty and exclusion, or creating a sustainable footprint. We consider that the alternative approach suggested by the SSA to the region’s development should be adopted. The SSA affirms its belief that a reasonable alternative to the RSS is an approach to development and activity in the region that is less dependent upon its national and international links. We consider this along with factors like considering happiness will bring the most economic, social and environmental long-term benefits to the region.

With regard to climate change, the SSA states quite unequivocally that the region’s greenhouse gas emissions are too high, and that climate change is likely to lead to a range of challenges, including increased risk of flooding from rivers and along the coast. There may also be issues in some parts of the region over the amount of water available to meet the needs of homes, business and agriculture. While the SSA notes some significant steps forward, it concludes that the RSS fails to address the subject to an adequate or satisfactory extent.

The SSA supports our belief that the RSS should resist airport expansion, because it would undermine all efforts within other sections of the RSS to reduce greenhouse gas emissions. The SSA also notes that it is better for people to do as much as possible of their journey by surface before flying, as the climate change impacts of surface transport per passenger kilometre are lower than air travel. The Government now accepts that Britain is unlikely to meet its own domestically set targets of cutting emissions by 20% below 1990 levels by 2010. The SSA notes an increase in greenhouse gas emissions, increasing car use, the environmental consequences of high economic growth and the need fo improved rail links in its summary of likely sustainability effects of the RSS. While some efforts have been made to improve sustainability, the SSA comments, “The main issue will be delivery.”

The SSA clearly doubts that everyone will benefit from the predicted economic growth. It questions whether any advantage will be gained by those who are in most need, such as deprived communities in both urban and rural areas. The RSS itself makes an acknowledgement that there are many uncertainties surrounding its forecasts. While there is a recognition that the economy is becoming ever more globalised, this raises concerns that if the South West is not able to compete in this economy, then local businesses are likely to suffer.

Furthermore, the greater the scale of growth, then the less chance there is that any region will be able to retain its unique character. The SSA considers that the scale and pace of growth that is proposed in the RSS mean it will be difficult to deliver development that is in accordance with the principles set out in Policies SD1 to SD4 (which cover our ecological footprint, climate change, the environment and natural resources, and sustainable communities).  While these the principles will help improve the sustainability performance of the region, it is unlikely that on their own they will be able to mitigate the impacts of continued growth.




3. Level of economic change

The RSS economic forecast is seriously flawed and the document appears not to have fully considered other economic scenarios. The RSS is based upon forecasts of relatively high-growth scenarios, but acknowledges that there are uncertainties surrounding its economic forecasts.  Furthermore, it appears to have an unsophisticated approach to economic growth, which fails to distinguish between dissimilar types of economic growth. The plan notes the need to follow “a low carbon and low resource consuming approach”, stating that factors such as the price of fuel will be important shapers of the region and that in many cases these factors will have very unpredictable effects in the long term. While this recognition is welcomed, the proposals to put this approach into practice are wholly inadequate and entirely too nebulous.

There are some good ideas in the Strategy, but as long as we have unrestricted economic growth as the number one target, then the environment and people’s quality of life will remain of secondary importance. The RSS is based upon a model and prediction of economic growth which does not take into account likely changes in external factors during the next 20 years. In concentrating on growth it fails to look at the strategies required for the  transformation of the existing economy which are needed to address these external challenges and create a sustainable local economy. The  RSS must consider and develop additional plans that take account of different economic forecasts, including the predicted energy price  rises. If this is not done, it could have serious implications for the region as a whole. A larger issue is not about growth per se. It is about managing the economic change that is necessary to move towards  sustainability and meeting the welfare needs of the population in a very different world economic environment in 2026.  This is far from being adequately addressed in the RSS.

One key scenario missing from the report is that of Peak Oil, the point at which oil production rises to its highest point before declining. Almost all expert opinion already agrees that it is fast approaching and will possibly arrive within five years, and almost certainly within fifteen. The significance of Peak Oil can hardly be overstated, as oil is the fundamental underpinning of our economy. When the oil runs out the economic and social dislocation will be unprecedented. However, Peak Oil not only represents a danger but creates opportunities for the region, if properly planned for. But in order for these to be realised, many aspects of the RSS will need greater consideration. For example, we disagree with the RSS that in the future “less land is likely to be used primarily for food production”. If oil prices rise as predicted by some then this will make the transportation of food (including flying) over long distances more expensive. 

There is currently little room for manouvre to adjust the RSS if economic forecasts should change. The RSS must take account of the likely energy price rises by moving with far more urgency towards a low carbon economy; this is essential if we are to build a stronger economic future for the South West. It is vital to consider what steps need to be taken in the South West to minimise  the adverse impacts from the contradictions within the existing model, particularly noted by the SSA.



4. Transport

We would expect a twenty-year guide on transport to be much more ambitious in its environmental aims, especially with regard to the reduction of congestion and CO2 emissions. But the whole approach of the RSS is far too timid on these issues, and fails to set any tangible targets. We therefore feel that the present Spatial Strategy will not succeed in cutting traffic movements, especially with inward migration proposals. In this country 24% of carbon  emissions come from transportation movements, and the RSS proposals will not produce the desired changes. It is known that oil demand will very soon outstrip supply, yet this most significant factor has been left out of the Government’s plans for expansion and the Draft RSS.

The Environment Agency reports that the South West has the highest number of journeys made by car, the second highest increase in traffic volume and some of the least accessible bus services in England. In addition, the average person in the South West travelled 7,919 miles in 2003-4, more than in any other region and significantly higher than the English average. One of the key areas where the RSS falls down is in that there are no proposals for more major integrated public transport systems, and no major improvements to our rail system. Our current rail network has been in existence for over 150 years, and with our dwindling oil supply and CO2 emissions it is necessary for an increase in the number of lines across the South West and the doubling of capacity of our current lines to be planned and endorsed. However, it is also clear that only a drastic reduction in fare rates together with increased reliability will make the public leave their cars at home.

 We believe vehemently that airport expansions must not go ahead. Aviation is the fastest growing source of greenhouse gases, with emissions from air traffic doubling since 1990 and set to quintuple. Yet the Department for Transport does not require BIA or any other airport to take climate change into account when expansion is proposed. It is vitally important to remember that trains are 19 times more carbon efficient than planes, while at the same time 70% of EU flights are short haul journeys of less than 1000km. The consequence of this disparity in carbon emissions between planes and trains cannot be overstated, nor must it be overlooked. With trains now capable of travelling at 300kph, we should be looking not towards airport expansion but towards the growth of a fast rail network.

The Green Party view the proposed expansion of aviation in the region as deeply alarming. The RSS argues that there will be “some sustainability benefits” from reduced road travel to Gatwick and Heathrow. However, as pointed out in the SSA, this is quite misleading. We find it extraordinary that the RSS can make such claims that are completely at odds with the facts, and we can only conclude that this is a weak attempt to try and defend an insupportable policy. Climate change is the greatest environmental and indeed economic challenge facing the world. Airport expansion runs counter to any long term view of economics or sustainability. Furthermore, we agree with the SSA that we need an introduction of fuel tax on aviation fuel, as well as emission charges and increased landing charges on aircraft.

In addition, the economy will suffer as a result of airport expansion. Foreign visitors arriving by air spent nearly £11 billion in the UK, but UK residents flying out spent £26 billion abroad, representing a loss to our economy of £15 billion. FoE estimates that airport expansions in the South West will lead to a massive £30 billion currency outflow between 2004 and 2020.



5. Renewable energy


As Greens, we welcome those positive steps which have been expounded in the RSS. For example, Policy RE5 requires all new developments of 10 houses or more to reduce their CO2 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. However, at the same time we also argue that the proportion of energy from renewables could be progressively raised to more than 10%.

Furthermore, with Peak Oil likely to be upon us within the next ten years, it is imperative that we ask ourselves what major constructive measures are left to us in other areas. We have only one option that is both realistic and desirable - to move quickly towards renewable sources of energy, like wind power, biomass, tidal power and solar, while at the same time reducing energy demands. While we applaud the Draft RSS for recognising the requirement for expansion in renewables, the need is for a substantially greater and much faster switch to this option.

The South West has the second highest household electricity consumption rate in Great Britain. Currently only 3% of the region’s electricity consumption comes from renewables. 35% is from wind power, 7.5% hydro-electricity, 47% landfill gas, 8% sewage gas, 2% advanced treatment of waste and under 0.5% from photovoltaic solar electricity. Regen SW (2006) note that the region is making very slow progress towards its 2010 renewable energy target of securing 11-15% of generating capacity from renewable sources, and that the target will be missed unless the rate of construction increases. In the light of this work by Regen SW, the region will need to consider whether to adopt a target for onsite renewable energy generation on all new developments.

Policy RE1 in the RSS 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 those set by 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.



6. Waste management

Reducing waste in the first place, the most important factor of all, is noted and welcomed but policies to show how this will be achieved are largely missing in the Draft RSS. The SSA stresses this point, encouraging the minimisation of waste production of in the first place (e.g. by reducing consumption) which would put waste management into the sustainability context of the RSS as a whole. The SSA also notes that the amount of materials consumed in the region is continuing to increase, along with the amount of waste, despite improvements in recycling.

The RSS notes that with regard to radioactive waste they will await the recommendations of the Committee on Radioactive Waste Management (CoRWM). These have now been published and advocate burying the waste deep underground, after decades of interim storage to allow for intensified research to address ‘uncertainties’. We strongly object to the idea of ‘deep disposal’. 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.

We should not forget that in many ways recycling is a failure and certainly will never represent a complete answer. Crushing, pulping and smelting materials is unnecessary, hugely energy intensive and damaging to our environment. We need to start reclaiming and reusing materials rather than destroying and then reproducing them. In any case, the value of recycling here is not being fully recognised or realised. England still has one of the lowest rates of recycling in Europe, with the Netherlands recycling 64% of its waste, Germany 57% and Denmark 41%. The South West managed 27% of domestic waste while England’s average was 23%.

But we do have a choice in this matter. We can either adopt a policy of low levels of recycling with incineration, along with all its damaging effects upon the environment and health, or we can do as the Green Party advocates, encouraging high levels of reuse, recycling and composting with a small remainder of waste for treatment. We would like to see the RSS adopt the greener option. At the very least there should be a phase-out of the disposal by incineration or landfill of any waste that can be re-used, recycled or composted.