Stroud District Council Environment Green Paper 

Bisley-with-Lypiatt Parish Council's response to the SDC Environment Green Paper.

Introduction

First of all we welcome this Paper. As we understand it the purpose of the Environment Paper is to:

  1. Guide SDC in its operations
  2. To set standards and guidelines for the SDC district, businesses and its inhabitants
  3. To set standards and guidelines for parish and town councils, businesses and residents.

We think it should be all of these, but this should be made clear. We believe that SDC must be pro-active, and drive this forward with determination. SDC have the capacity to initiate exemplar projects so they should exploit that. Moreover SDC need to be flexible enough to respond to, or facilitate the initiation of exemplar projects by others and ensure sufficient support is made available that success and confidence is created.

Our General Response

We consider that the general tenor of the Paper is bland to the extent that no one can disagree with it. It therefore presents a problem for those being consulted because there is nothing challenging, controversial or demanding in the Paper, nor are there any

  • Targets and timetables
  • Prioritisation (no ranking for what is practically achievable by different levels of government)
  • Cost/benefit analysis
  • Sticks or carrots – no enforcement or encouragement, no measurements of success.

There is a lamentable lack of urgency about the Paper. There is no eco-footprint analysis. Unpredictable weather patterns and increased risk of flash flooding means that if we continue to behave as we do, by the end of the century the sea level is likely to rise by one metre (reference taken from SDC’s Environment paper). That means that some Parishes in Stroud District could be at risk – for example, Arlingham, possibly Berkeley (where the nuclear power station is located) and others on the edge of the Severn. We noted nothing about flood management or community disruption. Planning should have a key role here in community consultation and forward planning.

There is also a lack of vision, clarity or coherence about policy – about who could do what and therefore what we as a Parish might be expected to do and how. We believe that Parish and Town Councils should have policies that inform their work with the Local Area Agreements and Village Design Statements - but this is not even hinted at in the Paper.

We consider that the District Council seemed to be claiming it could do MORE things than we believe it can. This has the potential of the District trying to do everything themselves, at once, which could result in failure on all fronts. Unfortunately we feel that the language of the Paper indicates that the District Council is not ready to devolve power and funds to encourage others, like Parish and Town Councils, to act effectively and in a real working collaboration. Whilst welcoming the vague notion of extending 'local leadership' this Parish Council is concerned that this is yet another instance of the District handing over responsibility without power or funds.

Finally we feel there is a lack of ambition and real challenge in the vision. If other local authorities can agree Zero Waste targets by 2020 why can't Stroud? If Bristol City Council and others can sign up to the 'Big Ask' (Footnote 1) campaign, why can't Stroud? If a Council like Milton Keynes can adopt carbon neutrality on all new developments exceeding five homes, why can't Stroud? If many local authorities for 2 years now have had the Merton Principle embedded in their planning policies what has happened to Stroud?(Footnote 2). Stroud should be leading, not trying to catch up.

KEY AREAS OF CONCERN

  1. PLANNING

    The role of planning is critical. We felt that Stroud District Council has been insufficiently forward thinking in planning terms and could do better. For example Stroud District Council should adopt the Merton Rule (Footnote 2) . Renewable energy and energy efficiency measures and targets must be addressed at the planning stage, as a condition of approval, before Planning Consent is granted. Once consent is granted Building Regulations, which are set as minimum requirements, are just considered by developers as standards to be met. Efforts should be made to improve the energy and water efficiency of the existing housing stock by raising the profile of the issue and what the possible solutions may be, offer grants, and use the planning process to trigger solutions. Every household could have water butts / meters to save water; every new development could be carbon neutral; it should be mandatory for every new development to use local or recycled materials in the building process. We welcomed the WISE homes scheme but the 26 new private and affordable dwellings development on WindyRidge in Bisley was a lost opportunity. (Footnote 2) Encouragement not barriers should be part of the District’s planning polices for home energy generation. Ways in which this can be achieved within the AONB must be addressed.

    We believe that the planning authority should devise ways in which to support Parish and Town Councils work with local communities more closely to help them develop appropriate ways of addressing local energy needs – cooperatively owned wind generators for example.

    The new Local Plan goes some way to encouraging home-working, but it should do more to discourage excessive transport use by encouraging opportunities for local employment, cooperative and sustainable community ventures, and local shopping especially in rural areas where 'out commuting' is a significant part of the economy. Planning has the power to demand a better relationship between housing, work, retail and school, encouraging communities to live, work, shop and be educated (as far as is possible) in the same locality. Planning has the power to insist on safe footpaths and cycle paths especially in rural areas to encourage walking and cycling. It also has the power to request developer contribution to bus services in relation to new developments.

    We are aware that the District Council has a heavy planning caseload. We believe that most minor domestic applications (for conservatories and the like) should be devolved to Parish Councils to deal with, releasing District Planners to have the thinking and negotiating focus to deal much more effectively in relation to the environmental implications of large complex developments.

  2. TRANSPORT

    We believe that the District Council has an educative, campaigning, funding and planning role with regard to all forms of transport.

    The District should campaign on behalf of everyone with Regional and County government for better provision of footpaths, cycle paths and public transport. The District should help support Parish Council initiatives by lobbying the County Council to significantly improve safe walking and cycling in rural areas, and through the Local Strategic Partnership continue to enhance public transport initiatives such as the Night Bus.

    The District Council should actively encourage a ‘grow your own’ food campaign in partnership with Parish and Town Councils and other voluntary groups, and confirm the commitment in the Local Plan that no allotment land is threatened by development.

    The District could work more pro-actively with Regional Government, County Council, Business Link and others, to ensure that there are increased work opportunities in rural areas to discourage out commuting. The District Council should support the re-skilling of individuals so that they can change their career paths so that they feel comfortable and happy and able to afford to work in their own communities rather than out-commuting. The District could work more closely with business to encourage businesses to allow more home working, thus reducing the need to travel.

    Finally the District should set an example. It should cut its own travel through increased 'e' working and home working, by radically reducing the perks of purchase of 'essential' cars for staff, and by reducing or cutting its mileage allowances to its staff and councillors. It should commit to the 'Nottingham Declaration' and/or the 'Big Ask' campaign to reduce emissions. The District Council could introduce the tax break scheme (IR 176) that allows new employees to buy a bicycle tax free to use for commuting, or better still buy bikes for its employees.

  3. WASTE

    We feel that this is the one area of District policy that is moving in the right direction. We agree with widening the scope for recycling such as plastics. However Stroud is nowhere near the top few local authorities for recycling and the UK as a whole is one of the worst recycling nations in Europe. The government's target of 60% carbon emissions by 2050 is challenged by scientific data that recommends a 90% cut if the 2% increase in CO2 is to be avoided. We strongly believe that the District Council has to accept that there is a cost to addressing waste and that extending contracts or rolling out community based programmes should not be market driven but environmentally driven.

    We believe that the District does not do enough to negotiate with (and shame) business to reduce packaging – a waste minimisation campaign is essential. Less packaging will mean less litter – a key problem for rural parishes.

    The District could actively encourage small local repair businesses – through grants via/in partnership with Parish Councils, working with Stroud College re training, and/or reduced business rates if necessary.

    We believe that key policies, for example composting biodegradable waste, should and could move ahead a lot faster through devolution of responsibility. Compost bins should be given free to individual households; every food outlet (pubs for instance) supported to encourage the purchase of small food accelerator composters (Footnote 3). Community based schemes should be devolved to Parishes – every community should be funded to set up its own local biodegradable waste schemes, including community composting, and local food composting immediately. Clusters of Parishes should be funded to purchase food digesters with collections management – and planning permission - to run these. It is not a solution to wait for volunteers; Parishes should be funded to set these schemes up – green waste should be dealt with at a local level and preferably food waste too.

  4. FURTHER POINTS

    We were concerned that:

    1. There was no mention of farming and agriculture and the opportunities for diversification especially for local biomass, biofuels, or increased local food production. There was no mention of GMO's.
    2. There was no mention of biodiversity at all. This surprised us.
    3. We should like to propose a inquiry/feasibility study for a District Energy Plan, broken down to Parish / Town level to evolve 'local ownership'
    4. Whilst community issues are mentioned throughout the Paper there were no recommendations as to how to encourage broader support for the idea and practice of sustainable communities. We believe that this Paper would be greatly strengthened through the inclusion of cultural policies such as Local Distinctiveness campaigns and other imaginative ways of inspiring collective experience and purpose that politics no longer can.

  5. CONCLUSION

    The District Council should allow its powers and appropriate funds to be devolved to local communities, Parishes and Towns, to enable the process of 'local ownership' and responsibility to develop.

FOOTNOTES

  1. The 'Big Ask' is a 'Friends of the Earth' campaign calling for 3% year on year reductions in greenhouse gas emissions in the UK. Half of UK MP's (cross-party) are signed up to it and local authorities are also signing up – again from across the political spectrum.

  2. The Merton Rule : www.themertonrule.org

    The original 2003 Merton Rule reads: - 'All new non-residential development above a threshold of 1,000 sqm will be expected to incorporate renewable energy production equipment to provide at least 10% of predicted energy requirements.' This has since been adopted, extended and exceeded, or is in the process of being, by 177 authorities.

    Many Councils throughout England have, through PPG22, integrated the 'Merton Rule' for renewable energy. Through Building Regulations the planning authority has the power to set higher, although these are policed as minimum standards, for renewable energy, insulation, insist on water and energy meters on new developments/applications.

    Below is a copy of a press release from 6/7/06; SDC need a fast track process to implement the changes needed quickly.

    The removal and reduction of planning restrictions on small scale micro-generation schemes – including solar panels and small turbines – will come into effect next year, the government has confirmed. Planning minister, Yvette Cooper, has promised to publish detailed proposals for the new planning regime in the autumn, which will clarify the position on equipment size and its impact on neighbours. This initiative forms part of the administration's review of permitted development rights and will be included as part of a planned new Householder Permitted Development Order. Cooper said: 'It is absurd that you should be able to put a satellite dish up on your house but should have to wrestle with the planning process for small microgeneration which is no more obtrusive and can have a real impact on tackling climate change'.

  3. Housing Developments:

    The Windy Ridge (2004-5) development in Bisley was a huge lost opportunity for the District Council to demonstrate environmentally appropriate thinking. Instead it ignored all the Parish Council's recommendations with regard to the sustainability of the development, arguing that these were 'not planning considerations'.

  4. Community and Food Composting

    Bisley’s Community composting scheme is almost too successful but is an interesting test / pilot for the District. Bisley now has a body of local expertise. Small efficient accelerator food composting systems are now available on the market (for example