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ASSOCIATION OF HAMPSHIRE AND ISLE OF WIGHT AUTHORITIES
29TH MAY 1998
RESPONSE OF THE ASSOCIATION TO "OPPORTUNITIES FOR
A CONSULTATION PAPER ON A REVISED STRATEGY FOR SUSTAINABLE DEVELOPMENT
1.1 Sustainable development is about successfully reconciling the twin imperatives for economic development and environmental protection in ways which enhance the well-being of individuals and create viable societies and communities. Its central themes are community, consensus, participation and integration - of social, economic, cultural and environmental issues. It is not, however, a fixed 'blueprint' for the future. Rather it is an evolutionary process which should determine how we and future generations meet our needs, not what those needs are or will be. One useful definition is:
"Sustainable development improves the quality of life for people living today
without undermining the capacity of the Earth to support future generations."
1.2 The concept of sustainable development first gained widespread attention as a result of the 1992 "Earth Summit" when heads of government from almost every country signed up to "Agenda 21". This document sets out what, in general terms, `should be done to involve all sections of the community in both decision-making and action. It identifies a key role for local government in helping communities to decide what sustainable development means at local level and then finding ways to put their ideas into practice. Many UK local authorities are already undertaking this task through "Local Agenda 21" processes and the Prime Minister has asked all authorities to draw up Local Agenda 21 strategies by the year 2000.
1.3 An increasing number of local authorities see sustainable development as part of their mainstream work and acknowledge that it requires the development of new ways of working, both internally and externally. In particular it demands greater corporate working across different specialist functions, services and responsibilities; more co-operation between authorities and other agencies and organisations; building new partnerships and relationships with other organisations and the local community; and the full involvement of all sections of the community in decision-making.
2.1 On 4 February 1998, the Deputy Prime Minister launched a wide-ranging consultation document on a new sustainable development strategy entitled 'Opportunities for Change'. The existing strategy, published by the previous Government in 1994, provided a valuable summary of environmental issues but did not fully explore the social, economic and cultural aspects of sustainable development. The results of the current consultation exercise will provide a framework for a change of policy and inform a revised UK Sustainable Development Strategy to be published before the end of the year.
2.2 The objectives underlying the Government's view of sustainable development are
* Social progress which recognises everybody's needs
* Effective protection of the environment
* Prudent use of natural resources
* The maintenance of high and stable levels of growth and employment
3 GENERAL COMMENTS
3.1 The publication of the consultation document is welcome, in particular for its new broader definition of sustainable development and for the high profile that sustainable development has begun to receive. There are, however, a number of broad issues on which we feel it is important to comment before moving on to address the specific questions asked in the document. We have made detailed responses to some of these questions (repeated below in italics) and addressed others in a more general way.
3.2 The Government has recently issued a number of consultation documents on local authority activities and elements of sustainable development. The order in which they have been issued and the short timetable for responses has not been helpful. "Opportunities for change" has been published in the middle of a sequence of technical papers, some of which are still awaited, that are integral to the development of a sustainable development strategy. We will make responses to these papers, including that on sustainable tourism at later dates. It would have been useful if this sequence and timing had been better managed with this document published either at the beginning of the process as a framework for the technical papers, or at the end as a summary of the technical aspects.
3.3 The structure of the document is based around some of the Government's social, economic and environmental objectives. There are several other key policy areas which are either omitted or mentioned only briefly in the document that are essential for the attainment of sustainable development. They include:
* Health and its relationship to the environment and the economy
* Employment and the opportunities afforded by more sustainable economic activity
* Social exclusion and the alleviation of poverty
* Education and lifelong learning
* Culture and social activity
3.4 This approach tends to compartmentalise aspects of sustainable development and reinforces a number of artificial barriers that have previously been erected between related strategies, for instance Local Agenda 21 and Health for All. Clearer recognition must be made of the mutual aspects of these strategies. Indeed there are a number of current Government policy initiatives within which sustainable development can and should be incorporated. Clearly stating sustainable development objectives as priorities within these initiatives is essential to raising the profile and priority afforded to sustainable development within local authorities. The policy initiatives where this applies are:
* Best Value
* Modernising Local Democracy
* Regional Development Agencies
* Welfare to Work
* Health Action Zones
* Education Action Zones
3.5 The document contains a new definition of sustainable development that is largely welcomed. The greater recognition of the economic and social aspects of sustainable development is overdue. The definition, however, fails to recognise that there are any absolute limits imposed by the ability of natural systems to absorb
changes that human activity is forcing upon them. The inclusion of reference to "the themes of sustainable communities" (Appendix 1), a concept widely recognised in local government in particular, would have been welcome and useful.
3.6 The definition of sustainable development offered still struggles with the distinction between better quality of life and higher standard of living, with the latter's emphasis being much more focused on economic activity and consumerism. This leads to unpaid work and leisure time being undervalued or excluded although they undoubtedly contribute to quality of life.
4 KEEPING TRACK OF PROGRESS
We would welcome your views on a key set of indicators of sustainable development (Opportunities for Change, p6 para. 16)
4.1 Much work has already been conducted on indicators of sustainable development. Indicators must be locally determined with our communities rather than nationally imposed. It is our view that the most useful approach would be to encourage the adoption of the thirteen themes of sustainable communities (Appendix 2) developed by the LGMB as a framework for indicators. Local indicators could be set within this framework which reflect local priorities but could be aggregated regionally and nationally because they would refer to common themes. For instance, on the theme of access to goods and services other than by car, an urban indicator may be number of households within 400 metres of a bus stop, whereas in a rural setting the indicator might be the number of bus trips made to and from settlements of a given size.
4.2 This approach should also make it easier for these indicators to be integrated into the Best Value framework as indicators of "general and community health".
4.3 In order that sustainable development indicators are meaningful to all sectors of the community they must be capable of competing for attention with the traditional headline indicators of economic activity. Much discussion has already been held into the effect of having GDP as the core indicator of economic activity. The disaggregation of the core indicator into indicators of social and economic well-being (measures of economic activity, demand for resources, environmental stock etc.) would more accurately reflect the needs of sustainable development.
5 SUSTAINABLE GOODS AND SERVICES
We would welcome views on:
* How might Government best work in partnership with business sectors on establishing business strategies for sustainable development encompassing some or all of these elements?
* Which elements are likely to be the most effective?
* How useful is the market transformation concept and in which sectors?
* Would it be helpful or feasible to regulate to set minimum standards for energy and material use in production processes?
* What is the most effective way of encouraging business to meet the range of different requirements for communication and dialogue with employees, consumers, the financial community, business suppliers and customers and local communities? What role can published reports play? (p9 para. 27)
5.1 Local authorities have developed approaches to including sustainability criteria into both their own internal funding arrangements and external grant schemes that they administer. For instance, growth bid submissions may have to clearly demonstrate benefits in two of environment, health, economic and community areas in order to receive consideration. This sort of approach could be built into the wider range of financial assistance provided by central and local government and the proposed RDA's. This support could be particularly applicable in the small and medium sized enterprise sector where it could be allied to further support, provided through Training and Enterprise Councils, to deal with supply chain pressures and to support the company reporting process.
5.2 There is a growing body of experience and good practice in local authorities reporting environmental performance, particularly as required by LA-EMAS. This experience needs to be shared more widely, not only between local authorities but also with other sectors.
5.3 The market transformation approach advocated in the document is appropriate in some sectors. We are concerned though, at the lack of attention paid to the provision of goods and services in the voluntary and public sectors and to the financial market.
5.4 The setting of standards would be useful. These standards should call for programmed, time-tabled progress with targets set at the level of the market leader to create a ratchet effect whereby competitive advantage is achieved by being 'ahead of the field'. This approach will only be successful where Government, local authorities and others are able to encourage and enforce such standards without being undermined by other international agreements, such as the Multi-lateral Agreement on Investment.
5.5 The duty to deliver maximum return on investments is widely perceived as a barrier to local authorities taking account of other than financial matters in managing investment portfolios. New guidance is needed to encourage and enable local authorities to influence sustainable development through their investment strategies.
What kind of information, and delivered through what medium, would most influence consumers to buy more sustainable products and use them in a sustainable manner? (p11 para. 31)
5.6 Whatever information is supplied needs to be meaningful and relatively simple to comprehend. It is vital that there are enforceable standards with regard to claims made for sustainable goods and services. These standards must, at the least, be Europe wide. They must not, however, prevent diversity and innovation at the local level.
6 BUILDING SUSTAINABLE COMMUNITIES
We would be interested in views on:
* How best to incorporate the broader objectives of sustainable development within the planning system, in particular how best to integrate the social dimension; et al (p 13 para. 41)
6.1 The patterns of development likely to prove most sustainable are those which provide all facilities and opportunities for their citizens and allow for a high proportion of local needs to be met from local resources. Energy and transport issues are not the only critical measures. Focusing solely on trip distances for example could lead to town cramming, loss of green and recreation space, lack of cultivable land in towns and cities, and increased run-off and disruption of water movements.
6.2 The cumulative and synergistic effects of individual developments need to be recognised. Methodologies for assessing the implications of "development trajectories" for the future of individual settlements and larger geographic units should be developed and promulgated. In environmental terms, these could assess use of resources (energy, water and minerals) and conservation (biodiversity, landscape) and pollution (air and water). In economic terms, the "mix" and diversity of the local economy could be assessed - in part to ensure balanced development that meets local needs. In social terms, the aim would be to ensure that future development contributes to the creation of viable communities. The overall intention would be to provide a general scenario or framework of how a settlement or area could be developed in ways that promoted sustainability, within which the impact of individual developments could be evaluated. Such an approach would have strong links with community plans and LA21 strategies; help underpin Strategic and Local Plans; and provide a way of integrating activities such as catchment management plans or energy systems whose boundaries frequently do not coincide with Local Authority Boundaries.
6.3 Greater guidance is also required on sustainable development issues as material considerations in planning and development applications.
6.4 Supporting and actively promoting wider forms of consultation and participation in the process, such as village design statements and community visioning exercises, could draw on the existing and developing best practice in this field but only if Local Plan processes are amended to allow outcomes of such activities to be properly incorporated. Otherwise people's expectations of influence will be raised, only to be dashed as their views are ignored.
6.5 Guidance and encouragement of the inclusion of sustainability reporting within the planning process would be welcome. It may be that the approaches to 'significance' and 'effects evaluation' developed within LA-EMAS could be useful in this.
We would welcome views on what more can be done to promote sustainability in the construction industry, and in particular on what environmental, social and economic objectives we might have for the existing domestic and non-domestic stock. (p14 para. 46)
6.6 Homes need to be designed for life, in particular to be designed for accessibility and to allow for the changing needs of people throughout their lives, and to be constructed to make the most economic use of building materials and resources. The goal of pursuing 'healthy homes' is an obvious area of overlap between environmental sustainability, improved public health and combating social exclusion. Healthy homes should be easy to keep warm, make best use of ambient light and heat gain and be both cheap and comfortable to live in. To this end we would also support the introduction of the Energy Efficiency Bill as an Act.
6.7 The development control and building control functions of local government are both potentially useful tools in delivering sustainable development and local authorities need to be given the powers to encourage and enforce action through building control and development control. The Building Regulations need to be reviewed with a view to increasing energy efficiency, in particular through increasing the minimum standards for thermal insulation required in the construction of both domestic and non-domestic buildings. Opportunities to provide advice and assistance on retro-fitting existing buildings with energy and water conservation measures and renewable energy systems via local authority Building Control services should be explored
6.8 Guidance should be brought forward on improved energy efficiency, better use of passive solar light and heat gains and on the use of rain-water capture and use, as well as grey water re-use systems. Change of use requirements should also seek improved standards of insulation in non-domestic application by specifying a minimum standard.
6.9 Local authorities should be encouraged to support proposals from housing associations and other groups for innovative environmental, social and community housing projects that meet sustainability criteria. The government should work with relevant organisations to examine the extent to which financial and other factors that favour volume house-builders and large-scale developments inhibit small-scale, community led, low impact developments related to local needs which may be more sustainable.
We would welcome views on measures to tackle rural deprivation, and on ways to combine development and conservation in smaller rural areas. (p15, para. 49)
6.10 The proposed tax on greenfield sites may achieve effects in terms of encouraging brownfield development where such land is available. However, there is a risk that by adding to land prices this will further restrict the development of low cost rural housing. The ability to specify targets for and require the development of low cost housing is needed.
6.11 The pilot Arable Incentive Scheme is a valuable model of an approach that enables food production whilst conserving wildlife. The CAP reform process also needs to take account of approaches that encourage "part time" and low impact land based activities which are currently frequently priced out of operation, or prevented from initial development, by land prices. These activities are particularly useful in meeting local needs from local sources, and when tied to local processing, where value is added within the local setting and not at some distance, can provide greater economic and employment benefits to the rural community. The additional rural employment benefits of organic farms must also be emphasised and the well known differentials in support to organic and non-organic systems need to be addressed.
We would welcome views on the environmental goals to be pursued and the type of targeted measures that could usefully be incorporated into the reformed CAP
6.12 An extensive 'Hampshire Farming Study' has been conducted by Hampshire County Council, the chartered surveyors Dreweatt Neate and the University of Portsmouth. The following comments should be read in the light of that report and its recommendations for future policy development.
6.13 The future of sustainable farming in Europe will depend on the extent to which it proves possible to shift financial support structures away from agricultural production towards broader more socio-economic objectives in which the maintenance of low-input, biologically diverse systems and their rural communities is a major objective.
A strategy to achieve this should include the following:
* identify policies which act against the survival of low-input systems at the local and regional level, suggest restorative fiscal, social and other structures. This is based on the notion that primary need is to sustain the riches still remaining to us;
* research, devise and propose methods for incorporating traditional management methods with new practices in order to help overcome the problems of reconciling individual social and economic aspirations with low-input farming.;
* support the production and marketing of regional products which sustain low intensity systems;
* promote the expansion and restoration of low-intensity systems, including the restoration of habitats arising from extensive pastoralism, such as low-land heaths;
* promote the reduction in pesticide and chemical fertiliser use on intensive farmland and promote shifts in policy needed to achieve reductions in scale of use sufficient to restore significant plant and animal diversity and;
* develop and promote case studies which demonstrate the benefits of the above aims.
We would welcome your views on:
* How we can encourage regional and local decision makers to adopt innovative
solutions for sustainable development;
* What more could be done to give sustainable development, including Local Agenda 21, a higher profile in local communities, and how to promote more well-informed and effective participation in decision making. (p17, para. 59)
6.14 The concurrent consultations on Best Value and Local Democracy and Community Leadership should be considered in conjunction with this document. The duty to promote the economic, social and environmental wellbeing of an area should be a duty to promote and pursue sustainable development. Indeed both of those documents make reference to Local Agenda 21 and sustainable development. Many of the innovations in consultation and community leadership have been developed by local authorities in pursuing their Local Agenda 21 processes.
6.15 There is currently an overabundance of names for facets of the same process. LA21, Health for All, Community Plans etc. are all processes which seek to improve people's quality of life in a more sustainable way. Clarifying the relationships between these processes would help all tiers of local authority and would begin to break down some of the barriers to wider public understanding.
6.16 Local authorities must be encouraged to innovate and be given appropriate powers to innovate and to discharge the duty of care.
6.17 This must equally apply to the Regional Development Agencies and other public bodies.
6.18 The creation of a "Sustainable Development Challenge Fund" could help to galvanise local authority and community activity by asking for applications for financing innovative projects developed through clear and effective partnerships and embodying the principles of sustainable development.
What action should be taken in the short term to ensure that the environmental and social goals of energy policy can be achieved at the same time as economic objectives are met? (p18, para. 67)
6.19 The Home Energy Conservation Act has stimulated a great deal of activity and innovation by local authorities. This process needs to be further encouraged and extended by increases funding and co-ordination. HECA activities are already directed toward delivering environmental, health, social and economic outcomes. Many local authorities have extended the HECA process beyond the home to travel and the workplace. Encouraging the adoption of wider 'community energy conservation plans' which include the business community would strengthen this process and would further stimulate innovation in this field such as the wider adoption of private wire CHP plants.
6.20 The equalisation of VAT on energy conservation measures and fuel would send a strong signal of the importance attached to energy conservation and tackling fuel poverty, as well as being a practical measure to reduce the cost of carrying out these works.
We would welcome views on the priorities for Government in considering further policies to tackle air pollution. (p18, para. 69)
6.21 The Road Traffic Reduction (Targets) Bill needs to be brought forward. This will further stimulate activity prompted by the Road Traffic Reduction Act. Local authorities need to be more widely encouraged to develop commuter plans for their communities and to do this in partnership with local businesses and employers.
6.22 The Transport Policies and Programmes (TPP) process needs to be reviewed and guidance issued that relates TPP to traffic reduction as well as traffic management. TPP submissions should be permitted for travel awareness programmes.
7 MANAGING THE ENVIRONMENT AND RESOURCES
We would welcome views on what further action can be taken to ensure that our water resources are managed in a more sustainable way in future, including future priorities for freshwater. (p19, para 71)
7.1 There must be an increased emphasis on water conservation measures. Emphasis must be placed primarily upon the sustainable use of available resources rather than on capture and exploitation of new supplies. Investment in efficiency of use, including re-use measures, will yield greater benefits for consumers and the environment than would that in new capture and storage infrastructure. More information on "grey water" systems could be provided to developers, architects and planners. If necessary, Building Regulations should be adapted to facilitate use of such systems. This must also be extended to rain water and run off harvesting at points of use. Greater emphasis must be placed on the effect that the built environment has on disrupting ground and surface water flows, especially that on rainwater run off.
7.2 The implications for biodiversity of various approaches to water management are of paramount importance. Water transfer schemes as well as increased abstraction have unsustainable impacts on ecosystems.
7.3 As coastal counties Hampshire and the Isle of Wight are particularly concerned about the impact of global climate change and rising sea levels. The fact that sea levels are not mentioned in the consultation should not be reflected in the strategy.
We invite your views on how protection of wildlife habitats can be integrated more fully into policy making across society. (p20, para. 77)
7.4 The Hampshire Biodiversity Action Plan Partnership demonstrates the benefits of the BAP process. Government should strongly encourage all local authorities to produce Local BAPs linked into the local plan process through 'site alert' and into local authorities' environmental and nature conservation strategies so that they can act as supplementary planning guides. All BAP must include monitoring programmes.
7.5 The use of tools such as "Environmental Capital" in the planning process can provide a mechanism for more clearly recognising the biodiversity value of sites, including those outside of the formal scheduling framework and, therefore, not just the rare and nationally or regionally important sites but also those that have particular significance within their locality.
We will be seeking views on how forestry can most effectively make its contribution to sustainable development. (p21, para. 80)
7.6 While we await the technical paper on forestry as an opportunity for detailed comment there is a general point to be made. This paragraph only mentions the potential to increase UK timber production to reduce our burden on overseas forests. It is difficult to see how current rates of timber consumption can be met on the basis of sustainable forestry. Whilst we would welcome the regeneration and extension of woodland habitats and the renewal of damaged landscapes by appropriate woodland planting in the UK we do not see how timber consumption can be sustained at its current levels. Targets for reduction, defined by sector, must be established.
We would be interested on your views on:
* The potential for more efficient use of aggregates and increased use of recycled material. (p21, para. 81)
7.7 Although the Landfill Tax has some disadvantages it is most effective when combined with increased taxation of virgin aggregate, and tax breaks on the use of recycled aggregate. Building regulations could be used to further increase the use of recycled aggregates, and the further promotion of good practice within the construction industry in this field would be valuable.
8 SENDING THE RIGHT SIGNALS
We invite views on how economic instruments in general can be used to promote sustainable development (p22, para 84).
8.1 We welcome the wide consultation that is being held on the use of economic instruments. There are clearly a number of areas where the use of economic instruments has already has an effect, including the landfill tax and vehicle fuel types. We are particularly keen to see the use of economic instruments that deliver multiple benefits, such as the equalisation of VAT on energy conservation measures with energy consumption. This would have environmental, social, health and economic benefits and would also complement a number of existing initiatives, such as HECA.
We would welcome views on current initiatives for sustainable development information and education and what improvements might be made (p22, para 89).
8.2 We welcome the setting up of a Sustainable Development Education Panel and urge the adoption of an approach to "education for sustainability" which goes beyond environmental education and the adoption of education for sustainability as a cross-curricular theme. We would also encourage links to "citizenship education" and the opportunity that this affords for pursuing the wider aspects of sustainable development.
We invite views on how to promote decision-making at all levels of Government which takes full account of sustainable development (p29, para 92).
8.3 As has been mentioned above, the proposed duty of care to promote economic, social and environmental well-being should be framed as a duty to promote sustainable development. Making clear the links between sustainable development and Best Value will reinforce this.
8.4 The use of sustainability reporting is being increasingly adopted by local authorities. Best practice in this field should be promoted. A sustainability evaluation tool which builds upon the environmental effects evaluation procedures developed through LA-EMAS would be useful and would be less subjective than many previous attempts to consider sustainability implications. Sustainability appraisals should be included at policy making stages as well as for project implementation.
9 INTERNATIONAL CO-OPERATION AND DEVELOPMENT
We would welcome views on how to ensure that sustainable development objectives are introduced into the broad scope of international agreements, and which areas are the priorities for international action (p24, para 97).
9.1 Local authorities have long valued the opportunities for international linking and the ability to share and promote best practice internationally. The UK has been leading in the adoption and enforcement of European regulations. Local links can be developed around social, economic and environmental themes, particularly in Europe. The accord between Hampshire and New Hampshire, USA is an example that demonstrates an approach to international co-operation. The work of the Local Government International Bureau is also to be supported.
9.2 We are concerned by the possible future implications of the Multi-lateral Agreement on Investment on local authorities. The social and environmental consequences of the agreement still appear not to have been factored into discussions.
The thirteen themes of a sustainable community:
* Resources resources are used efficiently and waste is minimised by closing cycles.
* Pollution pollution is limited to levels which natural systems (including Human health) can cope with without damage.
* Biodiversity the diversity of nature is valued and protected.
* Local needs where possible, local needs are met locally.
* Basic needs everyone has access to good food, water, shelter, and fuel at a reasonable cost.
* Satisfying work everyone has the opportunity to undertake satisfying work in a diverse economy. The value of unpaid work is recognised, whilst payments for work are fair and fairly distributed.
* Health people's good health is protected by creating safe, clean pleasant environments and health services which emphasise prevention of illness as well as proper care for the sick.
* Access access to facilities, services, goods and other people is not achieved at the expense of the environment or limited to those with cars.
* Safety people live without fear of personal violence from crime or persecution.
* Knowledge everyone has access to the skills, knowledge and information needed to enable them to play a full part in society.
* Empowerment all sections of the community are empowered to participate in decision making processes.
* Leisure opportunities for culture, leisure and recreation which are not achieved at the expense of the environment are available to all.
* Distinctiveness Diversity and local distinctiveness are valued and protected. Settlements are "human" in scale and form.
|Author:||Nick Goulder, Policy Manager|
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