Examination of Witnesses (Questions 101-131)
MR GIDEON
AMOS OBE AND
DR HUGH
ELLIS
8 DECEMBER 2009
Q101 Chairman: Good morning and thank
you for coming in. You will have heard the previous evidence and,
as I said earlier, we have got about half an hour to try and get
through some of the key issues. Could I ask you to begin with
what demands you think adaptation places on the planning system?
Mr Amos: I think there are two
broad areas. Of course there are hundreds of areas of adaptation
one could look at but there are two broad areas clearly where
we need to adapt the environment. One is in terms of the increased
temperature, particularly exemplified by the urban heat island
effect, and the other is managing water in its broadest sense,
so that is fluvial flooding, coastal change and weather-related
rainfall flooding. Those are two very broad areas. Obviously one
could expand a lot more on all the adaptation measures needed,
and I suppose the main point I want to make in response to your
question, Chairman, is that the planning system, if you take a
decades-long perspective, actually is a huge lever to create major
environmental change. You can look at regional parks such as the
Lea Valley, you can look at green spaces throughout cities, the
fact that hundreds of our houses, post-War, have gardens, all
these changes to the landscape crucially have had planning behind
them, and of course river catchment planning is another tool in
that armoury. I suppose the benefit of an active and purposeful
approach to planning is that over the long term these changes
can be made and new development can be used as a catalyst to try
and retrofit the neighbouring neighbourhood at the same time.
I suppose those are the kinds of changes we would like to see
in the impacts of new development on existing towns and cities.
Q102 Chairman: So in that way the
planning system is capable of helping the country adapt to climate
change. Are there other ways in which the system itself needs
to be modified to make that easier for planners to make a contribution?
Mr Amos: I think the most important
thing for us is probably having a plan-led approach. There is
a lot of evidence before you and Members about the need for strategies
and the need for adaptation plans and green infrastructure strategies.
None of these land-use changes is really going to take shape unless
there is some sort of statutory plan-led process behind it. We
regarded it as a huge step forward in 1990 when developments and
planning applications became the subject of a plan-led approach.
As it happens, just a brief point of history, Chairman, 100 years
ago last Thursday Parliament got Royal Assent for the first Planning
Act in the world which empowered local authorities for the first
time to have development plans, `Town Planning Schemes', and that
unleashed a whole generation of garden cities and garden suburb-type
development. We will return to the subject of gardens, but I think
it just shows how important a plan-led approach is and how important
it is that we do not lose that in the next few years of undoubted
change in policy and legislation.
Q103 Chairman: On another point of
history, the plan-led process you referred to in 1990 occurred
when I was a Planning Minister.
Mr Amos: I was aware of that.
Q104 Colin Challen: You said that
the planning system must be transformed if climate change is to
be placed at the heart of decision-making. What is preventing
this from happening at present?
Dr Ellis: There are some complex
reasons and we touched on these in the coalition work we did producing
a framework for a new PPS[21]
on climate change, but two or three top headlines would be political
will, skills and culture, as perhaps the biggest driving force
behind the difficulties that planning has to deliver. There are
complexities in the structures of planning which we could probably
sort out as well, but there are also complexities about the duties
and priorities. One of the things that has to be addressed really
carefully is what tasks we set the planning system to do. At the
moment those tasks are confused and although there are critical
duties in the 2004 and 2008 Acts on climate change, those duties
are written in the weakest possible form, and so it is not surprising
they do not necessarily drive transformational change. That means
that local planners are conflicted about what they need to be
doing. In our view, there is no greater challenge than climate
change and the fact that we are not delivering anything like the
way we should on the ground is scandalous and we need to sort
it out, but that requires changes to skills and education and
it requires changes to duties, and it requires changes to resources.
Q105 Colin Challen: Are we going
to get a two-tier system where major infrastructure projects now
of course have a separate planning route and then there is all
the rest. Are there going to be any lessons learned when this
really comes into force next year?
Dr Ellis: I do not think the two
systems are well-related and there is already a fairly critical
lesson there about the kind of narrative that we need from top
to bottom on policy. There are the overarching principles of adaptation
which are really well established. We know what we need to deliver
mostly, but that kind of narrative is not clearly laid out. National
policy statements are extremely controversial obviously and Parliament
is examining them at the moment. The content on adaptation seems
to me to be relatively good, but underneath that what we found
is that the transformational PPS on climate change published in
2007 did not have that much effect on local government. Why did
it not? Because even though the rhetoric was strong, it did not
send a powerful enough signal to say that this is your first and
foremost priority.
Q106 Colin Challen: Can you give
me an example of that signal in terms of being able to translate
it into concrete terms?
Dr Ellis: We have sent the planning
system confused messages about priorities. We are talking about
nothing less than the most significant transformation of the system
post-War, and that requires very strong national prescriptive
guidance. There is no other way forward because the amount of
time we have left, given that we should have started adapting
our cities a decade ago, is extremely short and that means that
the overall national framework needs to set very clear guidance.
We need to have national centres for knowledge which we talk about
in our paper. It means that the profession needs to step up to
the challenge through a very radical education programme. On top
of all that you are talking about transforming local political
leadership on climate change.
Q107 Colin Challen: I get the impression
that perhaps we have conflicting PPSs, some advocating other priorities.
Could you provide any examples of that, if you agree?
Dr Ellis: There is definitely
a mixed message not between climate and housing but between climate
and economic development. Economic development post-Stern should
not be in conflict with dealing with climate change and a low-carbon
economy, but I think in many local planners' minds, the traditional
methods of economic development are taking precedence. That means
that we are still engineering our cities and urban spaces to be
problems for the future of climate change. We are not grasping
overall nationally the need, for example, to consider the redistribution
of population, which we are probably going to have to deal with
if we do not get an agreement to limit temperature change below
two degrees. That is the biggest conflict. Those things should
be integrated. There is a huge opportunity to deliver a low-carbon
economy but we have not managed somehow to grasp the opportunity
yet.
Q108 Colin Challen: Should PPSs be
so prescriptive that they prevent for example building new housing
on floodplains?
Dr Ellis: There is still certainly
some very disturbing practice given the risks of development on
floodplains. I hasten to add that means that we then have to find
sites for the housing we desperately need in other places, but
the coalition document asks DCLG for a higher level of prescription
for planning policy statements. To give you an example of the
precise conflict, a planning policy statement's status in planning
is defined only in case law, which is unhelpful. A national policy
statement has clearly defined legal status for the new national
framework. Those sorts of gaps and uncertainties could be resolved,
but essentially this is not like any public policy-making that
I have ever known. If we are to deal with climate change there
has to be a level of clear central framework.
Q109 Colin Challen: You make these
points; do you think the DCLG is listening?
Dr Ellis: Yes I do but I think
there are barriers to them delivering on the ground. They can
write what they like, but if local decision-makers and local practitioners
are not skilled enough to deliver it and do not have the resources
to deliver it and do not feel they have political support, then
plainly that has little effect.
Q110 Chairman: You mentioned that
you thought the draft national policy statements were quite helpful.
Do you want to enlarge on that a little bit?
Mr Amos: Can I declare an interest,
Chairman. I have accepted an appointment as an IPC[22]
commissioner so I am leaving all the questions on NPSs to my colleague.
Dr Ellis: The contents of section
five of the overarching Energy NPS for example sets out what I
regard as a reasonably straightforward, commonsense framework.
You need to think about adaptation. It would be desirable if our
new nuclear build was not within one metre of sea level, for example.
However, there are difficulties I think—and this is a very
important point—because the duties that exist on secretaries
of state in the preparation of NPSs on climate to think about
climate change have had some effect on adaptation and no effect
on mitigation, which we are frankly terrified about, but the question
is that those duties do not apply to the decision-maker, so there
is no duty to think about climate change inside the IPC or placed
upon the IPC. That means that there are big questions about whether
or not the IPC has a sufficient skill-set (although of course
there are some very talented people amongst the commissioners!)
for example to interpret properly the UKCIP projections or the
weather generator inside UKCIP to enable them to make a judgment
about whether or not any of our infrastructure, our nuclear build,
should be anywhere close to the North Sea, for example.
Q111 Chairman: Just on an example
local to my constituency, to respond to the likely establishment
of another nuclear power station at Sizewell and the definite
establishment of offshore wind power, National Grid are proposing
to upgrade the transmission capacity. They are doing that through
the upgrade of their overhead power lines. Presumably, an adaptation
strategy would encourage the burying of power lines rather than
creating more overhead ones at a time when one of the certainties
is bigger storms, higher winds and more violent conditions?
Dr Ellis: The IPC may very well
conclude that but that is certainly what they would have to consider,
absolutely.
Q112 Martin Horwood: I want to follow
up on this. That is quite a major spanner in the works you are
throwing in terms of the new nuclear build because almost all
the sites are going to be based on existing power station sites
which are almost all on the coastline.
Dr Ellis: Yes.
Q113 Martin Horwood: So you think
there is a major problem with the whole nuclear new build plan?
Dr Ellis: There is undoubtedly
a major problem. In TCPA[23]
in the climate unit we have three sets of science. We have the
IPC, we have the mainstream generally, but if we take where the
science is going on climate change and sea level rises, by mid-century,
if we do not get an agreement in Copenhagen, then the maximum
sea level rise, if we lose all the ice, is 22 metres.[24]
No-one is suggesting we get that necessarily by the end of the
century but it does not seem sensible to have nuclear facilities
with a lifetime of 150 years, 200 years post-decommissioning,
anywhere near sea level.
Q114 Martin Horwood: This is moving
back on to some of the comments you made about green infrastructure
and the planning of green infrastructure. CABE[25]
in their evidence suggested that one of the problems was the lack
of a clear national database of information about green infrastructure,
and that it was not properly mapped. Do you think that there would
be a benefit to planners in particular of having that database
and having a very clear process of mapping and identifying green
infrastructure?
Mr Amos: I think also one of the
points CABE made about assessing the quality of green space is
particularly important in terms of whether green infrastructure
are delivering the adaptational benefits or not, because there
is a whole variety, so having a database and knowledge in that
whole area has got to be beneficial. The short answer is yes.
Q115 Martin Horwood: What would you
include in that database? Would you include gardens and things
like that?
Mr Amos: Absolutely and clearly
the whole issue of back gardens is central to this whole debate.
There has been a small move forward with regulation to require
planning permission before paving over front gardens but we did
not make the same advance on back gardens and obviously with the
classification of back gardens as previously developed land, and
therefore brownfield land, the quantity of building on back gardens
has to be a serious concern given that 60% of new housing is meant
to be on brownfield. A huge amount of that could be impacting
on gardens. The way the data is collected at the moment means
that you cannot easily get at those figures. There is data on
the quantity of development on existing residential land, and
that is the closest you can get to an estimate of how much of
that is garden land. It is a very difficult issue. Obviously the
Mayor of London has been grappling with this as well. However,
it must be central to value urban green space, and green space
close to where people live, very highly in our planning processes,
if we are concerned about adaptation, and the current system,
partly because of the data gathering, does not do that.
Q116 Martin Horwood: Can I just ask
you about definitions. You said "urban green space"
but you also said "green space close to where people live".
I want to ask a specific question which is about some work that
the old Countryside Agency did before it was abolished talking
about "green space on the urban fringe", which is often
some of the most volcanically contentious in planning terms because
developers love it and local people obviously want to protect
it. Do you think that urban fringe countryside should also be
counted as part of that urban green space and identified and mapped
and protected in that way?
Mr Amos: Obviously we have pretty
tough green belt policy to protect that urban fringe if that is
the objective. I think for the adaptation debate what is particularly
important is the fact that, as the Manchester research shows,
a 10% decrease in green cover can mean a seven degree Celsius
change in temperature. That is a massive change in temperature.
It does not matter so much whether you are living on the urban
fringe or right in the centre of an urban area or in the middle
of suburban London, the important thing is to have that green
cover and those green spaces integrated with the way people are
living and where the housing and development is. I would suggest
it is of the same value whether it is on the urban fringe or further
in and we need to integrate these two much more closely.
Q117 Martin Horwood: Groundwork UK
suggested that all local authorities should be required to prepare
a green infrastructure strategy as part of their LDF? What do
you think of that?
Mr Amos: I think having an LDF
would probably be the first step in that direction.
Q118 Martin Horwood: Do you think
it is logical to do it on a local authority level or do you think,
given what we know about the landscape and catchment areas, that
these landscape policies need to be on a larger scale?
Mr Amos: Exactly. Obviously there
are some questions that can be dealt with entirely locally but
there are also huge issues that need to be dealt with at a strategic
level. Earlier with the previous witness you were mentioning river
catchment planning, which obviously crosses local authority boundaries.
We are concerned about rumblings of a move away from any kind
of strategic or regional planning given that these problems are
not local. We accept that the environmental debate is international,
do we not, and we accept that these things need to be tackled
over international boundaries. We need to recognise that when
it gets down to a UK level, and an England level, some of these
problems also breach, believe it or not, local authority boundaries.
We are going to have to have solutions. Those may be new solutions
on regional planning or sub-regional planning, different structures,
different governance and so forth, but we need to have a strategic
overview.
Q119 Martin Horwood: Can I ask you
about one specific sentence in your submission as well. In talking
about the 60% re-use of brownfield land for redevelopment target,
you said: "Regional Spatial Strategies and Local Development
Frameworks have used this target to encourage urban regeneration
and discourage potentially sustainable greenfield developments,
rather than considering the benefits of proactive planning and
re-use of brownfield and greenfield land to form a network of
green infrastructure to contribute towards adaptation."[26]
It is quite clear what the benefits of the proactive planning
approach are for urban areas, but are you actually saying that
local authorities could benefit the environment by proactively
planning greenfield sites as well?
Mr Amos: We are not suggesting
that every single application would be better done on greenfield
land—that would be quite wrong—but I think it does
fall to us to speak up for the point that there are occasions
where a greenfield location, particularly some which are very
heavily farmed with perhaps high levels of chemicals, very poor
biodiversity, perhaps neighbouring brownfield sites, could be
part of a development that actually brings about environmental
improvement through development. The RSPB has done a lot of work
about biodiversity in urban gardens. Some of these options do
come up, especially if public transport is also excellent perhaps
around a country station. The important thing is that we are very
happy to support the 60% brownfield target, but it is important
to recognise that there are opportunities to do highly sustainable
developments which improve the natural environment through development,
on occasion, and it is not as simple as saying greenfield will
always be bad.
Q120 Mark Lazarowicz: In your submissions
you say that there is a need for "a step change in the skills
and education of decision-makers, both political and professional,
in local and regional government."[27]
What evidence is there of a coherent strategy for delivering a
step change in the skills of planners? Is the necessary training
available or does it need to be put in place?
Dr Ellis: There is no doubt progress
and the RTPI[28]
have announced progress in the education of planners. I think
given the scale of the challenge I keep coming back to these words
"transformational change". That is not just about young
planners being trained on climate, which needs to be mainstreamed
much more centrally, but it is also about continuing professional
development. You almost need to take the profession out for a
month and re-skill them on climate change. When you look at some
of the statistics that are quoted in our submission from the Arup
study about the number of planning applications in authorities
that go through the system with no consideration of climate change
or adaptation at all, it is frightening. There is also the interface
between professional planners and particularly between elected
members and their training. Our experience of that is difficult
because there are some fantastic elected members out there prioritising
climate change, but there is also a significant body of elected
members who remain climate deniers, which is very difficult.
Q121 Mark Lazarowicz: Should central
government be doing anything to help address the skills gap?
Dr Ellis: Absolutely they should.
They need to put as much pressure as possible on the profession
to evolve and change and re-skill itself. That is partly about
resources. Some of that is pointing in the right direction. In
terms of communicating key strategies, to give one example, it
would be the renewable energy strategy, so a programme of communicating
that to both professionals and to elected members is absolutely
critical if we are going to get the right kind of renewable energy,
and the same applies to adaptation.
Q122 Mark Lazarowicz: Can local government
do more to either improve skills within a particular local authority
or even the climate of opinion or understanding amongst local
planners and local communities, for example?
Dr Ellis: I certainly think it
is beginning to happen, but the problem we have got is that it
is driven by events rather than driven by strategy, so we have
the North West, we have had floods elsewhere and we now have increasing
awareness in the profession about the allocation of housing in
extremely vulnerable areas to flood. We need to be more strategic
about that. That does require a big programme of public communication,
I guess, to make this work.
Q123 Mark Lazarowicz: I was interested
in what you were saying about a lot of local councillors denying
climate change. Are they denying climate change is happening or
do they just not think it is that important?
Dr Ellis: When you seek to pursue
climate through the energy route—I have been roasted many
a time, probably fairly, at events on renewable energy, particularly
onshore wind, so where you approach the climate debate from that
perspective there is tremendous resistance, perhaps for understandable
reasons. There simply is not the grasp of the scale and urgency
and there simply is not the accessible science or information.
One critical example of that is that UKCIP does a fantastic job
but the way that they have conveyed risk and probability through
their findings is not one that is easily understood, so what they
are saying is should you pick a 50/50 risk of a major event happening
or an 80% risk of it happening, and that kind of probability does
not work. What people need at the local level is, as the previous
witness said very well I think, a clear scenario about what will
happen in their community and then people can coalesce around
that.
Mr Amos: Could I add very briefly
that we are leading a European project to provide the skills and
methodology to produce Adaptation Action Plans which would then
do exactly as Hugh says: identify what the changes are in the
particular area and how then you respond to those through adaptation
measures in development plans.
Q124 Chairman: You have advocated
a Climate Change Technical Advice Body. Why on earth do we need
yet another organisation?
Dr Ellis: A coalition of 60 organisations
came up with that idea. I was very struck, given that there is
a huge presumption not to have another body and yet more complexity,
about the massive consensus there was around that. That is because
there needs to be, as I have just described, a body at sub-national
level really, providing local authorities with a trusted source
of information. There are two dimensions to it which are important.
The first is that we must not have adaptation organisations split
off from mitigation because strategising about both resolves the
conflicts that exist between them. Some mitigation strategies
will conflict with adaptation strategies. Unless that is done
and the methodologies and data are collected by one body, there
is a horrible risk of conflict between the two ideas. The CCTAB[29]
idea was not simply to re-create organisations but to pool the
information in an accessible form. It is interesting for example
that although the Environment Agency and UKCIP work well together,
I am sure, there is no formal agreement between the organisations
and there is significant uncertainty amongst local decision-makers
about what each organisation's remit might be. That is replicated
in mitigation, particularly in relation to information on energy
for example. The idea of the CCTAB is essentially a laboratory.
It is not a political body, if you like, but a laboratory where
you can access—and the phrase has been used—in a one-stop
shop everything you need to know to come up with a decent climate
response in a local authority area. There is a fairly desperate
need for that, although little sign that it will appear, because
the greatest sin of all in responding to climate change is the
fact that most local decision-makers do not know where to access
critical information that would really transform communities.
Q125 Chairman: If we accept there
is a case for this body, who will pay for it?
Dr Ellis: I have two responses
to that. The first one is we did not work out who would pay for
it. We hoped that it would sit within the regional planning function
and obviously there is debate about where the regional planning
function might go. There are other bodies and other examples of
how that is done, in relation to aggregates planning for example,
where it is dealt with in a similar way, so we were not thinking
of creating an entirely new structure. It sits within the regional
planning function, but the other side of that coin, which is reflected
by Stern and the Manchester mini Stern,[30]
is simply the cost of not having an effective response to climate
change, which seems to be so appalling and so extreme. I do not
mind if we go down and lose the argument on climate change for
good reasons but losing the argument on climate change because
we could not find the data does seem to be too appalling a prospect
to contemplate.
Q126 Martin Horwood: Lots of the
issues we have talked about today touch on areas outside of planning.
We have talked about energy and water management and things like
that, and you could add in transport and health. The only body
that exists to co-ordinate the response to adaptation at the moment
is the Government's Adapting to Climate Change Programme. Do you
think that has the necessary resources and clout to actually bring
all these different people together and make them work together
in a co-ordinated way?
Dr Ellis: All I can say is that
I do not see it happening at the moment. I would suspect that
the departmental split on responsibilities for climate change
will probably have to be considered very carefully. There is certainly
a need for a strong unity of purpose between the three departments
with responsibilities on climate change, in particular the relationship
between Defra and DCLG. I am not suggesting they do not work well
with each other but it is in the nature of departmental conflicts
that we do not have time for any kind of uncertainty. Let me apply
this test: are we driving towards adaptation in urban and rural
areas effectively enough to avoid significant damage to civil
society and the economy? No, absolutely not. What that will require
is a much more unified approach, centrally, to dealing with adaptation
and much more resource.
Q127 Chairman: What can the planning
statistics tell us about how current buildings are being improved?
Mr Amos: I covered this in one
of my earlier answers, Chairman. Actually it does not tell us
an awful lot. One of the crucial issues that we have already pointed
to is how much development is going on in urban gardens, and the
figures do not tell us that specifically. There are all sorts
of other things the data do not tell us. For example, planning
permissions are not monitored so we do not know how many permissions
are out there. We know there are a number of decisions but we
do not know what permissions have been granted, so the debate
about the effectiveness of planning and adaptation and a whole
range of other areas is somewhat obfuscated by that. I guess we
are really arguing, particularly with regard to development of
green space, that there might always be important development
impacts on flooding, water management patterns, those kinds of
impacts of development which we need to be gathering some data
on, and we are not at the moment.
Q128 Chairman: What is the cost of
doing that?
Mr Amos: When the TCPA is large
enough to have a huge financial department we could estimate the
cost, but I am afraid we have not got that far in our submission,
Chairman.
Q129 Mark Lazarowicz: As you well
know, 80% of the buildings that will be around in 2015 have already
been built. Does the Government have a coherent approach to encouraging
the adaptation of existing buildings and what should the Government
be doing to encourage owners of those builders to do so?
Mr Amos: One of the interesting
things about planning is that when it comes to climate the whole
area is going to change. It does not actually matter whether it
is an area zoned for development. The whole country is going to
be subject to a change in temperature and other changes, so environmental
change will be happening across existing urban built-up areas
and sites of new development, so to answer your question I think
that we need to be seizing the opportunities that new development
offer to retrofit existing neighbourhoods. We also of course need
retrofitting of existing neighbourhoods even where there is no
new development, and that might be regeneration schemes. Ironically,
it could be the case—and Hugh referred to movements of population
earlier—that large amounts of our housing stock become pretty
much untenable, for example very small flats in highly dense urban
areas with a heat island effect, with insufficient ventilation,
these kinds of units may need to be replaced on a fairly large
scale, so ironically there may be an even greater need for development
and redevelopment of existing neighbourhoods as well as retrofitting
of the buildings one keeps.
Dr Ellis: There is a priority
in terms of section 106 or CIL[31]
money that is generated through planning, particularly on the
social justice aspect of that, because some of the scenarios the
University of Manchester are generating for where Manchester city
might end up are already indicating that the urban heat island
effect is much more severe and will have a much more lasting effect
on populations who are least able to adapt to it. If there was
prioritisation about the retrofitting it would certainly be in
that direction.
Q130 Chairman: Do you think there
is an opportunity to encourage both retrofit but also in the case
of new build better environmental standards by offering people
concessions in the planning system? One of the perennial complaints
is the delays that are incurred by developers. If there was a
fast track offered for schemes which achieved higher environmental
standards, would that be appropriate?
Mr Amos: Do you mean like eco-towns,
Chairman?
Q131 Chairman: There are all sorts
of other problems associated with that but someone who is trying
to get permission to put up a dozen houses on the edge of a village,
it might take him two or three years to get through the process.
If it could be given in two or three months by saying these will
be zero-emissions houses, would that be a good idea?
Mr Amos: I mention eco-towns partly
in jest, but it was an attempt to do something quickly in terms
of an exemplar. It ran into some problems, although now the local
authorities are very supportive. I suppose there is always a danger
of setting up a special procedure in planning for a special kind
of development. My stock answer would be that if it is such an
excellent development, it should be getting permission straight
away anyway, it should be meeting all the policies and standards,
so it should be fast-tracked. Why that is not happening is another
question. I do not know if my colleague wants to add anything.
Dr Ellis: Absolutely. I would
also highlight one of the recommendations in the coalition document
which is about climate change being the first amongst equals of
material considerations. At the moment climate change is so novel
I have yet to see a planning application refused because of its
climate impact, even now, which is again fairly disastrous. If
climate change was raised up as one of the critical considerations,
then in theory that would solve that problem because developers
coming along being able to meet that high standard on climate
change would find their pathway through the planning system much
easier.
Chairman: I think we have probably come
to the end of our time. Thank you very much for coming. Climate
is a very crucial aspect to all of this so we are grateful to
you for your evidence.
21 Planning Policy Statement Back
22
Infrastructure Planning Commission Back
23
Town and Country Planning Association. Back
24
Note from witness: These comments on the prospect of a much higher
sea level rise than government predictions are based on a paper
by Jim Hansen, "Scientific reticence and sea level rise",
published on 24 May 2007. Back
25
Commission for Architecture and the Built Environment Back
26
Ev 52 Back
27
Ev 50 Back
28
Royal Town Planning Institute Back
29
Climate Change Technical Advice Body Back
30
Deloitte MCS ltd, "Mini-Stern for Manchester: Assessing
the economic impact of EU and UK climate change policy on Manchester
City Region and the North West, September 2008 Back
31
Community Infrastructure Levy Back
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