Written evidence from South Wiltshire
Agenda 21 (ARSS 52)
1. ABOUT
SOUTH WILTSHIRE
AGENDA 21
South Wiltshire Agenda 21 was established in the
1990s. Our goal is to work towards a sustainable society where
we do not consume more than our fair share of the earth's resources
and do not compromise the ability of the earth to sustain life
for future generations. We seek to achieve our aims by lobbying
for policy change at global, national and local level and encouraging
individual behaviour change. The group's members include over
50 individuals and 30 organisations, 4 schools and seven businesses
in the South Wiltshire area (Salisbury and surrounds).
2. SUMMARY
2.1 Our particular concern in respect of the
abolition of Regional Spatial Strategies relates to consideration
of "the arrangements which should be put in place to ensure
appropriate cooperation between local planning authorities on
matters formerly covered by regional spatial strategies (eg waste,
minerals, flooding, the natural environment, renewable energy,
etc)."
2.2 Our evidence covers the following:
Some thoughts on sustainable development and the
need for a "one planet" life style from the South West
Regional Spatial Strategy (RSS) which was starting to move towards
a more sustainable framework for development in the region.
An example is given from the South West in respect
of transport demonstrating the need for a clear regional transport
policy if infrastructure investment is to be targeted appropriately
and sustainably.
There is a requirement for a Strategic Environmental
Assessment (SEA) to be undertaken which considers the overall
impacts of development. It is not clear how this will be provided
in the absence of the SEA provided by the RSS.
We believe that the UK is likely to be in breach
of the EU Habitats Directive if current regional Habitats Regulation
Assessment work and the conclusions arising from this are now
to be disregarded.
We are concerned that the Local Enterprise Partnerships,
which seemingly will form a replacement for the RSS planning framework,
focus exclusively on economic development and do not provide enough
emphasis on the environment or sustainable development.
3. THE SUSTAINABLE
DEVELOPMENT PERSPECTIVE
3.1 In the South West Region, where our group
is based, we were pleased to see written acknowledgement in the
RSS of the importance of living within environmental limits: "There
is a tension which the RSS must help resolve, between further
population and economic growth and the imperative to reduce resource
consumption and, most importantly, the decoupling of growth and
CO2 emissions. Consumption of natural resources or
"ecological footprint" has a global impact. Growing
demands for built development, infrastructure, food, fresh water,
natural materials and energy, seriously risk the erosion of environmental
quality and the life systems on which we all depend. The South
West's ecological footprint is unsustainable as it stands. If
everyone on the planet consumed such a quantity of natural resources
and energy as an average South West resident, three planets would
be needed to support life on Earth. Consequently, a shift is needed
towards "one planet", lower consumption, with lifestyles
which are more resource efficient."[71]
3.2 There is recognition in the SW RSS (para
1.6.7) that "The need to stabilise and then reduce the
region's ecological footprint in the light of continued economic
growth and lifestyle choices requires active promotion of efficient
use of resources by business and individuals, adopting a "low
carbon" approach. Regional action alone is unlikely to be
sufficient and will require a step change in the attitude of individuals
to the environmental impacts of their consumption choices in terms
of the goods and services purchased and the consequences of unlimited,
relatively cheap travel. National and international action is
also essential."
3.3 This thoughtful and considered approach which
has been one of the strands in the SW RSS has led to some challenging
questioning of some long established dogmas which have held sway
for decades in the shire counties of the South West. An example
of one of these is the aspiration to dual the A303 for its entire
length which is covered in section 4 below.
4. SW REGIONAL
TRANSPORT POLICY—A303
DUALLING ASPIRATIONS
4.1 The Strategic Sustainability Assessment (SSA)
of the draft SW RSS prepared in March 2006 referred back to an
earlier July 2005 commentary which had noted that:
"The aim of the proposed strategy to deliver
the capacity and services to encourage a switch to rail from road
is commended from a sustainability point of view. However, this
could easily be undermined by, firstly, the difficulty in securing
the funding to deliver the improvements to rail required and the
speed with which this can take place, and secondly, the upgrading
of the A303/A358, which will provide a "more attractive"
alternative. We recommend that SWRA needs to reconsider how it
can achieve the aim of improving quality of life and access to
opportunities in the region with less travel. In particular, the
assumption that providing a second motorway-standard road link
deep into the Peninsula is essential to the future well being
of the region needs to be examined more critically." [72]
4.2 The draft RSS published in June 2006 noted
that the SSA had expressed a fear "that improvements to the
strategic road routes such as the M4/M5 and A303/A358 may increase
traffic flows whilst not bringing the economic benefits wished
for." Nevertheless despite these reservations there was at
that stage still a policy (TR3) to "achieve a second strategic
route into the region from London to dual carriageway standard
utilising the A303-A358 in order to improve the resilience of
the inter-regional network and maintain the competitiveness of
the South West".[73]
4.3 The version of the SW RSS incorporating the
Secretary of State's changes issued in July 2008 removed references
to the policy for a second strategic route. The cancellation of
the A303 Stonehenge improvement scheme in December 2007, after
cost estimates for the proposed tunnel had risen to £540
million, may have had some bearing on this although this is not
the reason given, which was that the policy implied that "the
Exeter-London (via Taunton and/or Salisbury) [corridor] should
be given greater priority over other regionally important corridors.
We do not consider sufficient evidence has been put forward to
support this view."[74]
4.4 The local authorities along the A303 appear
to be having some difficulty in assimilating this change in policy,
with the South Wiltshire Core Strategy published in July 2009
still taking the line that "Studies have confirmed the
need to overcome these problems by dualling the A303 along its
length" and stating that "Wiltshire Council will
work collaboratively with agencies, such as the Highways Agency
and the Department of Transport, to try and achieve an acceptable
solution to the dualling of the A303."[75]
4.5 In the context of the inquiry into the abolition
of the Regional Spatial Strategy we believe the above example
serves to illustrate both the cross-boundary nature of transport
planning and the reluctance which there may be to accept a policy
agenda which incorporates sustainable development principles.
A radical rethink of current transport policy is required if we
are to meet the challenges set by carbon reduction targets in
the coming decades. There is no evidence that the local planning
authorities will propose or promote the greener alternatives which
are required unless they are steered in that direction by strong
regional and corridor based transport policies.
5. STRATEGIC
ENVIRONMENTAL ASSESSMENT
AND HABITATS
REGULATION ASSESSMENT
5.1 Linked to the RSS in the SW region—and
presumably in other regions also—is the Sustainability Assessment
(SSA) process which combines the requirements of a sustainability
appraisal under PPS 11, and a Strategic Environmental Assessment
(SEA) under the European SEA Directive. The removal of the mechanism
whereby the cumulative impacts of development across the region
are assessed must surely be a cause for some concern, especially
as one of the reasons why the current RSS process in the South
West had stalled was due to concerns regarding potential breaches
of the Habitats Directive.
5.2 An example of combined impacts of development
affecting environmental assets is provided by the River Avon Special
Area of Conservation (SAC). The Habitats Regulation Assessment
(HRA) prepared for the SW RSS concluded, inter alia, that there
was no certainty that there would not be an adverse impact on
the River Avon SAC[76]
due to the scale of development being proposed at Bournemouth
and Poole HMA, Swindon HMA, Salisbury HMA, Bournemouth, Poole
and Salisbury SSCTs. It is noted in the HRA (para 3.9) that existing
public water supply abstraction is already having a significant
adverse effect on the interest features of the Avon special area
of conservation (SAC)—before demand is increased by large
RSS housing allocations in the housing management areas (HMAs)
of Bournemouth and Poole, Swindon and Salisbury.
5.3 The above is just one example, the Executive
Summary of the HRA lists 37 SPA, SAC and Ramsar sites where it
is uncertain whether adverse effects on integrity will remain
following incorporation of the HRA recommendations into the Secretary
of State's Proposed Changes to the South West RSS.[77]
The uncertain effects relate to the water abstraction, water quality
and air quality impacts of development, and in many instances
the protected site would be impacted by development in more than
one local planning authority area.
5.4 It is not readily apparent, in the absence
of the RSS and environmental assessments associated with it, who
will be responsible for assessing the "in combination"
effects of development in the future. Presumably this would require
joint working between the local planning authorities involved.
However it is hard to see how this would work, or how agreement
would be reached regarding whose plans should be modified should
"in combination" effects be identified.
5.5 It is worth stressing that an assessment
of the potential effects of development on European sites is not
a mere technicality which can be brushed aside. As the HRA for
the SW RSS makes clear "The HRA should conclude whether
or not a proposal or policy in a development plan would adversely
affect the integrity of the site in question…. Significantly,
HRA is based on a rigorous application of the precautionary principle
and therefore requires those undertaking the exercise to prove
that the plan will not have an adverse effect on the site's integrity.
Where uncertainty or doubt remains, an adverse impact should be
assumed".[78]
5.6 The European Union has powers to take infringement
proceedings against a member state who is in breach of the regulations.
Here in the South West region an example of where this could happen
is given by the current ongoing investigation into the decision
making process in Wiltshire and the South West region resulting
from a petition (EU ref 440.053)[79]
submitted on behalf of the White Horse Alliance. This relates
to an alleged failure of the British authorities to comply with
the EC Habitats Directive in connection with the proposed Westbury
bypass and other major highway schemes.
6. THE WAY
FORWARD
6.1 It is not clear how, or whether, the goals
of the "Local Enterprise Partnerships" which are proposed
will incorporate environmental targets such as carbon reduction.
The Expression of Interest in a Local Enterprise Partnership for
Gloucestershire, Swindon and Wiltshire gives no indication that
this is being considered. The term "environment" is
only used in the context of the "environment" for economic
or business growth, and an "environment" where "the
role of the state, and its interventions, is significantly rolled
back."[80]
6.2 Against this "laissez-faire" background
it is not apparent how the current work done at a regional level
to consider the "in combination" effects of development
will be dealt with. The now de-coupled Local Authorities in the
South West region have inherited a list of regional allocations
and infrastructure schemes which could potentially breach the
Habitats Directive due to their "in combination" adverse
impact. As things stand we believe the abolition of the Regional
Spatial Strategies and (seemingly) the shelving of the Habitats
Regulations Assessments which accompanied them would lead to the
UK being in breach of the EU Habitats Directive.
6.3 Our group is of the opinion that insufficient
emphasis was given to environmental considerations in planning
and decision making under the previous RSS regime. However, at
least in the South West region, there was some evidence that the
"economic growth at all costs" model was being challenged
at the regional level, and environmental assessment work was questioning
some of the levels and types of development being proposed. We
need more environmental safeguards in place - but without the
RSS and its associated studies and reports we have fewer. We hope
the Communities and Local Government Committee will rise to the
challenge of ensuring that the "greenest government ever"
will swiftly put in place a planning framework to replace the
RSS which will provide more and not less environmental protection.
September 2010
71 The Draft Revised Regional Spatial Strategy For
The South West incorporating the Secretary of State's Proposed
Changes - for Public Consultation July 2008 Para 1.6.2. Back
72
Strategic Sustainability Assessment of the Draft South West Regional
Spatial Strategy prepared for South West Regional Assembly by
Land Use Consultants with Collingwood Environmental Planning and
Levett-Therivel Sustainability Consultants March 2006 (para 6.12). Back
73
Draft South West Regional Spatial Strategy, South West Regional
Assembly, June 2006 Section 5 Transport. Back
74
SW RSS Schedule of the Secretary of States proposed changes &
reasons for public consultation, July 2008, p.193. Back
75
South Wiltshire Core Strategy Proposed Submission Document, Wiltshire
Council, July 2009, para 8.24. Back
76
South West Regional Spatial Strategy Proposed Changes Habitats
Regulations Assessment Final Report Prepared for Secretary of
State for Communities & Local Government by Land Use Consultants
in association with Levett-Therivel Sustainability Consultants
July 2008, para 3.10. Back
77
South West Regional Spatial Strategy Proposed Changes Habitats
Regulations Assessment Executive Summary prepared for Secretary
of State for Communities & Local Government by Land Use Consultants
in association with Levett-Therivel Sustainability Consultants
July 2008, Table 1. Back
78
South West Regional Spatial Strategy Proposed Changes Habitats
Regulations Assessment Final Report Prepared for Secretary of
State for Communities & Local Government by Land Use Consultants
in association with Levett-Therivel Sustainability Consultants
July 2008, para 1.5. Back
79
See http://www.europarl.europa.eu/meetdocs/2009_2014/organes/peti/peti_20100531_1500.htm Back
80
Expression of Interest The Local Enterprise Partnership for Gloucestershire,
Swindon and Wiltshire, available on the web at http://www.wsep.org/media/uploads/LocalEnterprisePartnershipExpressionofInterest2.pdf
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