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).