South East Climate Change Partnership S Response to the South East Plan (Consultation Draft

Response to the draft South East Plan

7

Response to the South East England Regional Assembly -

A Clear Vision for the South East: The South East Plan

Draft for public consultation

On behalf of the Executive Committee of the

South East Climate Change Partnership

April 2005

SECCP, c/o SEEDA, Cross Lanes, Guildford, Surrey GU1 1YA

Tel: 020 8541 7972Fax: 01483 484 247E-mail:

Web:

Introduction

The South East Climate Change Partnership (SECCP) thanks the South East England Regional Assembly (SEERA) for the opportunity to comment on the draft South East Plan. The Executive Committee also thanks SECCP’s Planning Sector Group for leading the development of this response.

Further information on SECCP is provided in Appendix 1.

SECCP welcomes the identification of climate change as a cross-cutting theme in the draft Plan (paragraphs 3.4 to 3.6) and the inclusion of a specific policy (CC2) with supporting text (paragraph 1.5) on climate change. There are limited other references to climate change elsewhere in the draft Plan, mainly in section D5 which contains the policies for sustainable natural resource management.

SECCP’s comments on the draft Plan are aimed at assisting SEERA to improve the Plan. They take account of the Climate Change Principles for the Regional Spatial Strategy (the South East Plan), which we submitted to SEERA’s Natural Resources and Climate Change Advisory Group in June 2004; this is contained in Appendix 2.

A general point that we wish to emphasise is that awareness of climate change issues is very low at all levels and there is thus a danger that planners will not see mitigation of the causes or adaptation to the impacts as priorities. Consequently, it is imperative that the South East Plan be clear and consistent about climate changeand the need for implementation of mitigation and adaptation measures at all planning levels.

General comments

It is encouraging that climate change is recognised as one of the main cross-cutting themes in the South East Plan. However, although there are several good references throughout the document, climate change issues need to be incorporated in some of the policies in order for the topic to be properly integrated. Climate change is relatively well treated in section D5 but not in the other parts of section D. Thus the Plan gives the impression that climate change is solely an “environmental” issue whereas in reality it is just as relevant to other policy areas including housing, the economy, infrastructure and transport.

The overwhelming impression is that the Plan is driven by economic forces, and that where there is any conflict between economic interests and climate change considerations, the economic imperative prevails. The section and policy on Aviation is a prime example. If this is the case, then at the very least the Plan should make it clear that this judgement has been made.

Even where there are policies or schemes that are in line with the climate change agenda, sometimes there are doubts concerning delivery or implementation. For example, in Table 3 on page 108 (transport investment framework) which lists several schemes to improve public transport, there are several worthy schemes but bearing in mind what has happened to the South Hampshire Rapid Transit scheme there must be serious doubts about implementation.

One of the functions of the South East Plan is to provide an adequate framework for drafting plans at a lower level, for example Local Development Frameworks. It fails to do this with regard to climate change issues.

To provide guiding principles for LDFs concerning climate change mitigation, the Plan ought to include such policies as:

• New developments must be designed to standards of high energy efficiency;
• New developments must have good accessibility by public transport and to a good range of local services (e.g. shops);
• Encouragement will be given to the development and use of renewable sources of energy, such as wind power, biomass, etc.
• Relevant plans must provide for schemes which maximise re-use and recycling of waste and provide for the use of greenhouse gases such as methane.

To provide guiding principles for LDFs concerning climate change adaptation, the Plan ought to include such policies as:

• New developments must be guided to locations that best offer protection from the likely impacts of climate change, including flooding, drought, etc.
• New development must be located to minimise implications for supply of and demand for essential services such as water OR [to be more specific to water] New development will not be allowed in locations where the means of supplying water is not sustainable.
• The layout and design of new developments must demonstrate adequate resilience and/or adaptation to the likely effects of climate change.

Therefore we feel that the draft Plan has missed a major opportunity to set out a framework to plan positively within the South East Region to mitigate the impact of development and associated activity on climate change; to put in place measures to ensure adaptation to climate change; and to promote the opportunities that climate change presents.

In particular we are concerned that the draft Plan fails to de-couple economic prosperity and quality of life from one of the major drivers of climate change – carbon emissions (see our specific comments below on the Vision expressed in the draft Plan).

In addition, the draft Plan fails to express and follow through the links between the various cross-cutting themes and to carry these through to the individual policies. For example it is unclear what account has been taken of climate change in setting the overall scale and distribution of housing development in the region.

The Plan should acknowledge that there are potential conflicts between mitigating climate change and some of its other policies, for example those on air transport, and how these are to be resolved.

Overall, we are concerned that climate change is not, in reality, treated as being truly cross-cutting. It is mainly covered in the section dealing with the natural environment (and even so, does not even feature in D6…). Whilst policy D5 is very good it does not appear to have influenced other regional policies or sub-regional policies.

If climate change were already a mainstream issue, dealing with it under Section A and D1 would be sufficient. However, because awareness is so low, it needs to be emphasised in each policy area asexplicitly as it already is for D5.

Awareness of climate change issues is very low and there is the danger that planners will not see it as a priority. There is thus a much higher burden on the South East Plan to be clear and consistent, and to expect implementation as appropriate in a regional spatial strategy. Key messages that the Plan should convey are:

• The climate is changing fast, largely as a result of human activity. In the medium and long-term action we taker now, for example to cut greenhouse gas emissions, can help reduce the pace, and possibly the scale, of change.

• In Britain, the impact of climate change is likely to be greater in the South East than in any other region.

• The changes in the climate will bring many opportunities, for example for new enterprises, but will also cause problems that will need to be tackled, for example how to respond to rising sea levels.

• There is a lot we can do to prepare ourselves for these changes, and the Plan should pave the way for this, particularly by giving clear guidance to local planning authorities on what they should be doing.

Where issues cannot be covered adequately in the Plan itself because of pressures on space, proper technical background papers should be provided.

Specific comments

Plan reference / SECCP comment
Section A Challenges
3. Cross-cutting themes (paragraphs 3.4 to 3.6, page 9) / This section needs to be strengthened and reinforced at other key points of the document. Specific points – which are important for audiences of the SE Plan as well as for the Assembly:

1. Emphasise the growing consensus on the increasing human causes of climate change (alongside natural causes).
2. Remove references to Australia and America: it is not appropriate to name them here, and in any case there is a diversity of views and actions in these countries (e.g. with many US states and cities being proactive on mitigation and some US and Australian states seeking to sue their federal governments for inaction!).
3. The Plan should mention that Kyoto agreement is now in force and the debate is now about what the next stage is and how non-Kyoto nations can be engaged.
4. Emphasise the inevitability of further climate change over the life of the South East Plan (and beyond) because of legacy of greenhouse gas emissions etc.
5. Put genuine uncertainty about future “pace and form” of climate change into context: there is uncertainty about all aspects of the future (social, economic and environmental), but we still make plans and invest in ‘the future’. We have to use the best knowledge we have – and we know enough to start now on both mitigation and adaptation.
6. Emphasise the long-term nature of climate change (but it has started), the scope of the actual impacts (e.g. social, economic & environmental), rather than the changing climate variables (e.g. average temperature, rainfall etc) [the former have meaning to people, the latter don’t] and the need to build this into decision-making now. The word “resilience” should be used in this context – for organisations, communities & the region as a whole.
7. There are ‘no regret’ or ‘low regret’ options for adaptation, and also opportunities as well as risks.
8. Mention the UKCIP02 climate change scenarios and use the maps for the UK and the South East to illustrate these. Maps have been used effectively throughout the document: climate change maps would help ensure the point isn’t lost.

Resource Use (Paragraph 3.8, page 10) / It would be useful to make explicit reference to Factor Four (or Factor Ten) to indicate the scale of the opportunity (Factor Four is certainly achievable!), and to link this to climate change through the need to decouple prosperity from carbon emissions. The cross-cutting themes need to link together.
4. Plan parameters and principles (paragraph 4.2, pages 10 and 11) / Those objectives which relate to cross-cutting issues such as climate change should be given a higher priority than the other objectives set out in this list.
5. The Plan Vision (Paragraphs 5.x, page 11 and 12) / We feel that the Vision is weak, lacks clarity, is not inspirational or aspirational enough, and is not sufficiently specific to the South East.
With respect to climate change and related issues it could be strengthened by a statement along the lines of “the South East, as most prosperous region in Britain but also the one that consumes the most non-renewable resources and the one potentially most affected by climate change, will lead the way in developing a vibrant, low carbon economy, which mitigates and adapts to climate change”.
Scales of change and forecasts (paragraphs 6.x, page 12 to 20) / This is probably the best place to include climate change projections in some detail, with maps. Most of the South East Plan users will not be familiar with this, so it is important that the document is as explicit as possible, perhaps with sign-posting to an appendix.
Section B – Context (pages 21 to 27) / Text on how climate change links with the issues in this section would be helpful. For example:

• Impacts of climate change in other parts of the world – impacts on SE economy and role in Europe etc.

• Aviation. Obvious links – both mitigation and adaptation (e.g. to increasing inwards tourism as people choose to avoid the Mediterranean etc…)
• Infrastructure. Again, obvious – but the additional point that adaptation will require new infrastructure (e.g. reservoirs), as well as changes to existing infrastructure.

Section C – Strategy options & sustainability (pages 28 - 44)
Statement of policy (pages 29 and 30) / The Plan should state that Govt guidance on regional spatial strategies requires the South East Plan to take account of climate change.
2.2.1 mentions “increased adaptation and mitigation” – presumably this is to climate change? This should be explicit, to avoid confusion.
2.2.3 The Plan explicitly aims for 3% pa growth in GVA. It should be explicit that this must be decoupled from carbon emissions (and ‘embedded’ carbon?) – and also from environmental impacts generally – in order to deliver on the cross-cutting themes of climate change and resource use in section A and the related policies in Section D. For adaptation, it is important that growth is also decoupled from demand for water.
Options for growth (pages 30 to 39) / It is not clear what account has been taken of the need to mitigate and adapt to climate change in the selection of the overall scale of growth and options for its spatial distribution. This should be made explicit, even if the answer if “none”.
Sustainability Appraisal (pages 39 to 44) / It is not clear whether the various proofing exercises (rural, futures etc) have specifically addressed climate change issues.
Section D – Regional policy framework

D1 – Cross-cutting policies

(pages 47 to 54) / There is useful commentary on climate change here (paragraph 1.5), but it needs to be strengthened (e.g. climate change impacts will vary across the region) and linked back to section A.
Policy CC2 (page 48) is too vague (“have regard to”) and weak (“seek to support”).
Other cross-cutting policies (e.g. CC3) commit to “will” and “should” and emphasise the “relevant authorities.” This emphasis on requirements / obligations should also be reflected in CC2, as well as formal wording on the need for resilience, flexibility and innovation for adaptation. This also reinforces the need for the implementation plan and sustainability appraisal to demonstrate how other policies should deliver the climate change policy.
D2 – Economy and Tourism (pages 55 to 68) / This section should state that climate change is a major factor to be taken into account in how the region’s economy should develop.
Policy RE1 (page 58) should make specific reference to climate change.
The section and policies on Tourism (pages 63 to 65) should make specific reference to the impacts of climate change.
D3 – Housing (pages 69 to 82) / There is no evidence that the Plan has taken into account the impact of climate change in its assessment of the scale and distribution of housing growth. This is a severe omission, and must be put right.
In particular, it must be shown that the overall scale of growth proposed takes account of factors other than economic and demographic ones.
Policy H3 should make specific reference to the need to take account of the need to mitigate and adapt to climate change in selecting locations for new housing.
Policies H5 and H6 should make specific reference to the need for housing density, design, sizes and types to be such that they mitigate and adapt to climate change. This principle should also apply to Policy H7, as the existing stock of homes far outnumbers the number of new homes likely to be built, and therefore adapting the existing stock to climate change will potentially bring the greatest benefits.
D4 – Communications and Transport (pages 83 to 112) / We acknowledge that the Plan seeks a modal shift in transport, better management of transport systems and promotion of alternatives to travel. However, transport-related emissions of greenhouse gases continue to rise. The Plan needs to be more explicit in recognising the impacts of transport on climate change, to address the challenges with greater urgency and to demonstrate how appropriate responses will be delivered.
D5 – Sustainable natural resource management (page 113 to 144) / This section is generally very good, which probably reflects the commitment and hard work applied by the Natural Resources & Climate Change AdvisoryGroup. However, there is some scope for improvement. Climate change is not simply an environmental issue and therefore should not just feature in this part of section D but throughout it. Climate change is as relevant to housing, economy, transport etc as it is to natural resources, and that is why it has been adopted as a cross-cutting theme.
Although there are good references in the accompanying text, policies NRM1, NRM3 and NRM4 ought to include references to at least ‘take account of climate change’ to ensure this important topic is not overlooked.
Sustainable construction: the wording in paragraph 1.18 to use BREEAM standards should be strengthened by replacing “should be used” with “…will be required to be used, with developments expected to achieve a minimum of “very good” and increasingly “excellent” standards”. This wording should be included in one of the policies – e.g. EN1 clause (ii) – to give it due weight, and the wording of Policy CC3 on page 48 should be aligned to be consistent. Cross references would be helpful.
Policies NRM4 and NRM5 tackle habitat creation/re-creation but could also mention planning for, or allowing for, the migration of habitats and species as the climate changes, as part of a strategic approach to biodiversity conservation.
Woodlands – should include reference to the benefits of woodland planting and management for climate change mitigation and adaptation.
Air Quality: Policy NRM7 – it would be better to amend (iv) to say “encouraging improved energy efficiency and increasing the proportion of energy generated from renewable sources”.
Energy Efficiency: Policy EN1 – the wording in the introduction (i.e. “LDDs may expect the incorporation of high standards of energy efficiency”) is weak; high standards should be a requirement. The use of BREEAM standards should be a requirement (see above). Remove the words “where appropriate” from clause (ii).
D6 – Countryside & landscape management (pages 145 to 147) / The section includes 3 policies: C1 relates to the New ForestNational Park; C2 AONBs; and, C3 Landscape and Countryside management outside designated areas (i.e. everywhere else).
The importance of ‘active and creative management’ is stressed as a means of resolving conflicting pressures on the region’s countryside. Whilst this is to be welcomed, no mention is made of the potential impact of climate change on the management of the region’s countryside, either through physical changes (e.g. erosion in coastal areas, loss of beech trees in the Chilterns or increased fire risk on heathland and woodland), or adaptation measures that we may expect to take in the ways we manage the countryside (e.g. changes in agricultural practice, use of land for flood storage).