Our Plan – SHFoE responses

Our Plan is the Local Plan for the South Hams which is currently being prepared. Here’s a link to the SHDC page http://www.southhams.gov.uk/ourplan

SHDC produces a series of newsletters to inform the community of what it’s doing. These newsletters are vague, almost to the point of irrelevance. SHFoE’s responses to  newsletters 4 and 5 are below.

Newsletter 4: Heritage and the Environment

This newsletter represents another dumbing down of the planning process and states the obvious, identifies issues of real concern and offers few solutions. It’s nice to be told how many SSSIs we have in the district and it’s nice to know how much of the district is AONB, but that information is not necessarily what we want to see in a planning document. We need to know exactly what the Council proposes to do to safeguard our environment and heritage and that is exactly what is lacking.

A considerable amount of work has been done by SHDC over the years to produce planning policies and it seems that all this work has gone. The argument that the NPPF requires this does not hold water – the NPPF is vague enough for LPAs to be very specific and still be within NPPF requirements.  In the place of previous policy we are offered the most banal and vague alternative it is possible to imagine, and this does a great disservice to the communities you serve and the heritage and environment we value.

There is little left to say other than rather than redrafting policies and producing slick(ish) newsletters and not so slick videos, go back to the policies that were consulted and published in 2010 and try and make them work.

POLICY SUGGESTION 1: In order to appreciate and manage the conservation and environmental challenges we face, there must be collaboration with all parties involved in managing and conserving the landscape and environment from the start of any project, especially those projects which affect conservation areas, AONB or other important landscape designations. Collaboration needs to include statutory bodies, landowners, developers, architects, local authorities, builders, consumers, infrastructure providers (etc) from the start of any project.  Our Plan will include policies which enable such collaboration.

POLICY SUGGESTION 2: Include Policy DP2 and Policy DP5 from the Development Policies DPD (copied below as they seem to have been forgotten).

DP2: Landscape Character

  1. Development proposals will need to demonstrate how they conserve and / or enhance the South Hams landscape character, including coastal areas, estuaries, river valleys, undulating uplands and other landscapes, by:
  2. reflecting the needs and issues set out in identified landscape character areas;
  3. ensuring its location, siting, layout, scale and design conserves and/or enhances what is special and locally distinctive about the landscape character (including its historic, biodiversity and cultural character);
  4. retaining, integrating and enhancing distinctive features such as trees, ancient woodlands, field boundaries, walls, hedgerows, watercourses and river valleys;
  5. avoiding unsympathetic intrusion in the wider landscape, such as detrimental impact on the character of skylines or views from public vantage points and light pollution; and
  6. respecting the unspoilt nature and tranquillity of the area.
  7. The undeveloped coast (defined on the Proposals Map) will be protected and proposals will be considered against regional policy and relevant local guidance.

 DP5: Biodiversity and Geological Conservation

  1. Development will conserve, enhance and / or restore the biodiversity within the South Hams by:
  1. protecting habitats and species identified for retention in the Biodiversity Action Plans;
  2. providing the Special Areas of Conservation and Special Protection Areas with the highest level of protection and enhancement;
  3. providing on-site mitigation for both species and habitats, where possible, or off-site compensation for the loss of any habitats or species;
  4. providing for the management of habitats and species;
  5. maintaining the integrity of important networks of natural habitats, such as the strong network of river valleys linking Dartmoor National Park to the sea;
  6. enhancing existing habitats and networks of habitats and providing roosting, nesting and feeding opportunities for rare and protected species; and
  7. having regard to the Habitats Directive and Regulations.
  1. Where development is likely to have an adverse effect on a Site of Special ScientificInterest (SSSI), planning permission will not be granted.

An exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts on the site that make it of special scientific interest and any broader impacts on the wider network of SSSIs.

  1. Development likely to have an adverse effect on the nature conservation or geological interest within Strategic Nature Areas, National Nature Reserves, County

Wildlife Sites, County Geological Sites, Ancient Woodland or sites/features identified as having similar substantive interest, including veteran trees, will not be permitted, unless the benefits of the development clearly outweigh the identified biodiversity or geological value of the site/feature.

Post Script: During the 1970’s there were 660 reported disasters around the world including drought, floods, extreme temperature events, wildfires and storms.  In the 2000’s there were 3.322 – a fivefold increase.  Globally 2011 holds the record for disasters – total damages reaching 380 billion dollars.  (Quoted from “This Changes Everything” by Naomi Kline)

 It’s high time that everyone from parish council level upwards began to realise that this problem is not some far away disaster that will happen in Bangladesh or the Pacific Ocean, it’s here, right now.  Ask anyone who lives in the Somerset Levels!

Re: Issue 5 – Our Resources

This is a depressing document which poses many questions, doesn’t offer many answers and the few answers that are offered are vague and unenforceable. This newsletter does little more than state the obvious. There’s little to disagree with, but the overall feeling is that there’s nothing at all any of us can do other than make vague suggestions which are easy to discount or create a case against. Granted it’s a difficult situation and Local Planning Authorities are stretched, but the LPA does have a duty to at least try and protect our resources and suggest some enthusiastic if not radical responses. Compared to the SHDC documents which have gone before (e.g.  The Development polices DPD) this newsletter is anodyne at best.

Re: Renewable Energy Challenges:

In the preamble to this section you say “At present, South Hams has a relatively low level of renewable energy deployment in SW England, and a high level of potential renewable energy resources.” Surely this is the opportunity to say how you are going to change this for the better, but it is an opportunity missed. Instead you identify three challenges, two of which are not area specific and are so vague they can hardly be called challenges.

Challenge 1 asks a question (no question mark though):  “How can renewable energy resources be maximised in an appropriate manner that is sensitive to the landscape, settlements and rurally isolated dwellings of South Hams”.

Good question. I’d expect a Planning authority to come up with something like an answer here. POLICY SUGGESTION: This is the place to say, for example, that the landscape is important, but so is renewable energy and that Our Plan will support generation of energy using wind, wave, tidal and solar power as well as from sewage, food and farm waste (etc).  Our Plan aims to ensure Solar Farms are sited appropriately and as far as possible will not be sited in the AONB. Our Plan will have comprehensive policies to guide this which will include land underneath the solar panels being used effectively etc etc.

Challenge 2  (“To help our communities appreciate the energy challenges that we face, and that energy security and continuity of supply are issues of increasing importance”) contains no sense of how this could be delivered and ignores the fact that many in these communities are already very aware of energy challenges and energy security, especially those in fuel poverty and those trying to create a more sustainable future as far as energy is concerned.

POLICY SUGGESTION: Here is the right place to look at energy costs and fuel poverty and the lack of collaboration that is inherent in planning, development, building and infrastructure provision. You could say something like:  In order to appreciate and then manage the energy challenges we face, there must be collaboration with all parties involved in delivering development – including landowners, developers, architects, local authorities, builders, consumers, infrastructure providers  etc etc- from the start of any project.  Our Plan will include policies which enable such collaboration. Our Plan will also include sustainable building policies in response to the growing body of regulation which requires organisations to reduce their energy usage and/or build in renewable energy onsite etc etc.

Challenge 3 (“To accept that all areas of the UK have a responsibility to deliver renewable energy schemes. For a long time we have been able to rely on a constant supply of energy from distant sources, but with traditional energy resources increasingly scarce, expensive and unreliable, we all need to take more ownership of where our energy comes from if we want to ensure a sustainable energy supply.”) is similarly woolly and doesn’t say how it can be achieved. It is not very clear who must do the accepting in this “challenge” and feels like a very passive if not defeated statement. If we start from this very negative position, it is difficult to see how aspirations can be raised.

This answer looks as if it may be trying to tick the “duty to cooperate box” but chickened out. As with everything else in the document it’s too vague to be meaningful.

POLICY SUGGESTION: It would be better to say something like: Our Plan will support local renewable green energy to counter the uncertainty of energy provision from further afield, tackle climate change and help us to take ownership of where our energy comes from in order to ensure a sustainable energy supply. Our Plan will have policies to support creating new industries and jobs in the renewable energy sector etc etc. As landscape designations often cross administrative district boundaries, Our Plan will seek to have policies about local renewable green energy  which are shared with other adjoining LPAs.

Under Sustainable Construction Challenges you say “Many of our older buildings do not retain heat efficiently through poor insulation and poorly sealed doors and windows.”   Yes. And? What are we to do about it? The policies suggest nothing that will be effective.

Suggested additional policy areas:

Include the whole of DP4 Sustainable Construction from the Development Policies DPD (copied below as they seem to have been forgotten).

  1. Development should be adaptable, anticipating change in household needs and family structures throughout their lifetime as well as anticipating the impacts of climate change.
  2. Development should use locally sourced materials where possible, and minimise the use of materials, by using recycled materials in the construction of the development and minimising waste during construction.
  3. Development will avoid or mitigate any increase to the risks of floods occurring or to their severity both on site and elsewhere.
  4. Development should avoid or mitigate any risk from contaminated land, erosion or instability.
  5. Development should avoid or mitigate any harm to water, land or air from noise, fumes, dust, vibrations, light or heat.
  6. Buildings will be sited and orientated to maximise passive solar gain.
  7. Notwithstanding the national standards that prevail at the time an application is made, development should be carried out to the highest standards of sustainable construction where viable and practicable.
  8. At least 10% of the energy to be used in new development of more than 10 dwellings or 1,000m2 of non-residential floorspace should come from decentralised and renewable or low-carbon sources, unless, having regard to the type of development involved and its design, this is not feasible or viable.
  9. Development comprising 10 or more dwellings should meet “Lifetime Home Standards” on at least 25% of homes.
  10. Large scale development should provide for Combined Heat and Power schemes, where appropriate.