AECOM support for local plans passing the carbon buck

I thought that I would share my latest experience of considering the merits of a draft local plan.  This comes with a Sustainability Appraisal from AECOM and the statement:

 "Focusing on the matter of minimising per capita CO2 emissions from the built environment (as opposed to emissions from transport), the proposed spatial strategy performs well in that there is a concentration of growth

at larger sites, potentially leading to opportunities to design-in low carbon infrastructure. However, there is little certainty, at this early stage.

No proposed LPP2 Development Policies are focused on climate change mitigation / low carbon development, recognising that a strong policy framework is provided by Core Policy 40 (Sustainable Design and Construction) and Core Policy 41 (Renewable Energy). ... Significant effects are not predicted, recognising that climate change is a global issue (and hence local actions can have only limited effect)."

There are three main problems with this Appraisal

1.  There are no policies in the plan to seek to re-balance the size of households with the size of housing.  The level of overcrowding is close to 3% and under-occupancy closer to 80%.  There is a desperate shortage of housing suitable for the elderly, no adequate policies supporting self/custom building or co-houisng and nothing about low carbon building.  

2.  The 'strong' policies referred to and relied on by AECOM are in 'response to climate change' and relate to the adaptation of housing to higher temperatures and flooding (CP40) and renewable generation (but not wind). 

3.  The achievement of carbon reduction targets is a global operation comprising personal and local actions.

For a district where residents and businesses emit substantially more carbon per capita than the global average to be supported by AECOM in this way is a little troubling.

The last point is that local plans drawn up along these lines are being adopted around the country after being found to be 'sound'  as inspectors are no more keen than planning authorities to take carbon emission reductions seriously.  And by concentrating on 'soundness' local plans are missing out on issues that could substantially increase the quality of life; co-housing, local food systems and a transition to lower car ownership and use (of ultra low emission vehicles). 

Planning to reduce carbon emissions 2

Less than a year ago I posted a link to the first edition of Planning to Reduce Carbon Emissions which claimed that land use planning could, if used to its full, be responsible for a 50% reduction in emissions  - perhaps with a few relatively minor tweaks to the law.  Quite a lot has happened on the research front and the transport section was criticised as being too weak, so here is an updated version. Planning to reduce carbon emissions 2

The Government promised to publish an Emissions Reduction Plan  in early 2017.  Nothing has appeared although it has (ominously) been renamed a Clean Growth Plan. And we know from a photograph taken of a civil servant's file that efforts to reduce carbon emissions are to be scaled back while the Government concentrates on Brexit being seen to have a rosy economic glow.

While the ERP/CGP is awaited (and Client Earth seem to be losing patience by issuing veiled threats of legal action) some councils are already doing their bit.  Lambeth LBC (and there might be others) is already requiring buildings to emit 35% less carbon than the equivalent built to Part L of the Building Regulations. And the developer is also expected to make a financial contribution to the council to enable the 65% of carbon emissions to be offset!  The assessment of planning applications is being carried out by environmental consultancy Bioregional.  I have seen an appeal against 4 conditions on a planning permission containing a condition along these lines but this particular condition was not challenged, a sign of general acceptance/approval of this approach to emissions reduction/clean growth or that appeals have been tried and failed.  But where is Sajid Javid and Gavin Barwell, our Secretary of State and Planning Minister? The ERP is the responsibility of Nick Hurd MP in the Business Department but January's Housing White Paper is in DCLG's court and it said next to nothing about carbon.

How can much criticised planning authorities progress with their local plans when a fundamental part of the evidence base (ie the ERP/CGP) is being withheld or delayed by the Government that has been their greatest critic?

More transport confusion

Last year (27/11)  I drew attention to the 'transport confusion' caused by the proposal to (re)build a railway between Oxford and Cambridge at the same time as proposing a road or 'expressway'.  A further report from the National Infrastructure Commission has been published showing no less enthusiasm for the road.  see https://www.gov.uk/government/publications/the-national-infrastructure-commissions-interim-report-into-the-cambridge-milton-keynes-oxford-corridor

This report does actually say that the potential conflicts and synergies need to be explored.

This report has been published  at the same time as 4 Parliamentary Select Committees are considering the future of the motor car in light of the pollution (particulates, NOX, CO2 and dust from tyres, brakes and roads) being caused by motor vehicles of all kinds but with the attention being focused on diesel engines.  The combination of science identifying the health risks (equivalent each year to the battle of the Somme) and the special legal duty of care to children (young lungs and brains particularly susceptible to damage) is a fantastic opportunity for Government to explain that there is no choice in reducing dependency on private cars with extraordinary public benefits for heath and well-being. How does a new road fit with this?

But the real point behind this blog is that the point about a rail link being delayed just as long as there remains the possibility of a road link was discussed with two of the most knowledgeable  experts in this field.  It seems that this conflict has been put very strongly to the NIC which is insistent that the expressway remains on the table.  The NIC remains impervious to the fact that  this will delay or derail the railway.

Those able to respond    (growthcorridorevidence@nic.gsi.gov.uk) could point out that the feeder roads are just that. Traffic would not start at either Oxford or Cambridge and  the heavily congested A34, A40, A420 will become even more congested, strangling the knowledge spine running along the A34 through Oxfordshire and defeating the claimed purpose of invigorating the scientific community along the east/west 'brain belt'.   Congestion is likely to increase on feeder roads at the eastern end.

But there is another point that could be made in support of the rail.  The justification for HS2 that the time savings between Liverpool, Manchester, Leeds and Birmingham to London has been abandoned in favour of a case that the new line is needed due to capacity problems on the West Coast Main Line.   Without the imperative of saving time, the possibility of a junction of east/west rail with HS2 becomes a very attractive proposition.  Currently many routes necessitate a change in London (adding to congestion) and being able to change trains  in the midlands (if there could be no slips) would greatly enhance the national rail network.

Unlocking hidden homes

I have mentioned it before, but the report by the Intergenerational Foundation cannot be recommended highly enough.

http://www.if.org.uk/archives/7779/unlocking-englands-hidden-homes

The consultation on the Housing White Paper ends on the 2 May  and I would urge all readers of DanthePlan, even if they do nothing else,  to draw the DCLG’s attention to the report by emailing  planningpolicyconsultation@communities.gsi.gov.uk

The only thing that I would add to the recommendations made in  Unlocking England’s Hidden Homes would be to say that Local Planning Authorities could make Local Development Orders  which can have the same effect as a change to the General Permitted Development Order  and can include conditions subject to which a change could be implemented as ‘permitted development’.  Clearly not as good as a change to the GPDO that would apply to all councils but could be done while waiting for the Government to take the necessary action.

I also think that achieving new dwellings for as little as 5k to sort out plumbing, electrics, partitions and possibly stairs, would compare so well with new building on greenfield land that councils should introduce permissive policies in their development plans (local and neighbourhood plans) where permission is (still) required, and count the new dwellings and even anticipated new dwellings, against their housing land supply figures.  Grants could be made available that could be recovered on the sale (or rent) of the new  dwelling(s) and even justify a  specialist team with the necessary skills to streamline the delivery.

Well done the IF