Read our response to the Local Plan Review below.
SOUTH STAFFORDSHIRE LOCAL PLAN REVIEW CONSULTATION RESPONSE
CONTENTS
Introduction
Release of Greenbelt
Housing numbers and Duty to Cooperate
Climate Change Implications
Transport and Infrastructure
Population Growth
Introduction
South Staffordshire Green Party would like to make the following responses to the Local Plan Review in relation to the Preferred Options Consultation. South Staffordshire Green Party recognises the need for housing delivery in the district, but argues that this must be placed within the larger context of the climate crises which poses grave threats to us all. The exploration of all other available options regarding need for Greenbelt release must take precedence. Equally, housing must be built that is net zero carbon, and that is fit for a future world that no longer relies on fossil fuels. It is the responsibility of the Local Authority to deliver a climate-conscious local plan.
South Staffordshire is described as a rural district, 80% of which lies within the West Midlands Greenbelt. There are 27 parishes and a handful of large villages but no dominant settlement.
The preferred options as it stands projects a very large population growth, with little infrastructure to support such growth. It presents the promise of climate change mitigation, but does not build this into the Local Plan. It considers a 30% reduction in the CO2e for new builds to be sufficient, at a time when any increase in emissions pushes us further toward catastrophic climate change.
Release of Greenbelt
From the NPPF:
The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.
A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt.
Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.
Whilst the government may have set huge housebuilding targets, and South Staffordshire Council wants to assist with reaching those targets, the “Very Special Circumstances” that must be present for release of land from the Greenbelt are not robustly met.
Fundamentally, releasing Greenbelt land transforms land from a carbon sink, into a carbon source.
Housing numbers and Duty to Cooperate
Significant concerns have been raised around the figures proposed by South Staffordshire Council to contribute to the housing shortfall in the GBHMA. The figure proposed by South Staffordshire Council to contribute to unmet housing need in Birmingham is 4000 dwellings. South Staffordshire considers the provision of almost an equal number of houses to its own housing need as a ‘proportionate and justified contribution’.
Moreover the figure seems to have been arrived at either arbitrarily, or based on outdated figures. The first clear point of contention is that the housing figures for GBHMA include a 35% uplift, mandated by the government in relation to proposed planning reforms. However, this additional uplift should not be applied to housing that is delivered outside the twenty cities selected. The 35% uplift should be met within those chosen cities.
Secondly, the most up to date calculations on demographic need have not been used to calculate Birmingham’s housing requirement in the first place. South Staffordshire have accepted the housing shortfall figures and worked from that, without evaluating more recent data or the changing circumstances.
In South Staffordshire itself, the Plan will in fact over-supply housing.
Windfalls have been underestimated. According to the SHELAA, windfalls have consistently exceeded 100 d.p.a every year since 2006 (see page 27 of the SHELAA) which would amount to 1500 over the plan period. Including these more realistic windfall provisions, one can provide more than enough housing for the needs of South Staffordshire and make a more reasonable contribution to the Black Country shortfall.
Climate Change Implications
Though the climate change impacts of the development set out in the Local Plan Review are numerous, there are two major factors that emerge relating to Climate Change. Firstly – emissions generated by the new developments themselves both during construction and over the lifecycle of the buildings. Secondly – the significant increase in vehicular traffic, and associated emissions the addition of 8,881 new homes in the district as a whole will contribute to the already overburdened road network. These serious issues are exacerbated by the loss of greenbelt land and the inevitable destruction of trees, hedgerows and wildlife habitats that will occur in order to facilitate new development.
The fact is, the energy involved in building and then operating every new UK home adds to the UK’s overall CO2 emissions at a time when there is an urgent need to reduce them.”
From the Staffordshire Baseline Report:
Without a combination of grid decarbonisation and widespread switching to ULEVs (and the displacement of traditionally-fuelled vehicles) the district has no hope of reducing emissions. In fact the level of new development could result in up to a 7% increase in emissions.
Based on this, South Staffordshire, having declared a Climate Emergency and committed in their Climate Change Strategy to “ensuring that the district fully contributes to local efforts to reduce the impacts of climate change” the new Local Plan should address these three issues when setting out the planning framework for all new development in South Staffordshire. Regrettably, it does not.
New buildings
Sizeable carbon emissions arising from the built environment are attributable not only to the use of built assets (operational emissions) but also to their construction (embodied emissions). Operational emissions result from energy consumption in the day-to-day running of a property, while embodied emissions arise from producing, procuring and installing the materials and components that make up a structure. These also include the lifetime emissions from maintenance, repair, replacement and ultimately demolition and disposal.
If the carbon inputs of all aspects of constructing, maintaining, operating, retrofitting, and demolishing buildings are not measured and not included in emission calculations, there is a significant danger that although targets may be met, carbon emissions are not in fact reduced and the risk of catastrophic climate change increases exponentially.
Whilst Section 6 of the Local Plan Review Preferred Options document commits to achieve a 31% carbon reduction, in line with the government’s interim uplift in standards, effective from June 2022, it does not make clear whether it will commit to a reduction in both operational and embodied emissions. As described above, addressing only operational emissions (which is implied from the discussions around energy generation) potentially ignores 50% of the life cycle emissions of residential buildings. Even with a 31% reduction in emissions the housing numbers proposed in the new Local Plan will generate in the region of half a million tonnes of CO2e in the construction phase alone.
Relying on National Planning Regulations to dictate standards is insufficient. The 2018 Hackitt Review of Building Regulations and Fire Safety identified worrying deficiencies in the current system of Building Regulations. Compliance is weak, and there is indifference around build quality and confusion over roles and responsibilities. The exploitation of loopholes means new homes are still being built which do not meet even the current minimum standards: Just 1% of new homes in 2018 were Energy Performance Certificate band A.
The new Local Plan must embed significantly higher standards for new-build homes to ensure that all new homes in South Staffordshire are ready for net zero by having a high standard of energy efficiency and low carbon heating installed as standard to be ready to comply with 2025 the Future Homes Standard. There is consensus that By 2025 at the latest, no new homes should connect to the gas grid.Instead they should have low-carbon heating systems such as heat pumps and low-carbon heat networks. These obligations should be built into the Local Plan. In the South Staffordshire Council Climate Change Strategy, the council cites the preparation of the Local Plan as an opportunity to minimise the climate impact of growth. The strategic planning responsibilities referred to in the document include; promoting sustainable design in buildings and wider developments, promoting climate resilient buildings and using planning mechanisms and obligations to contribute to climate actions. The new Local Plan does not address these strategic responsibilities. The Preferred Options document states:
It is critical that the new Local Plan provides greater ambition and measures for mitigating and adapting to climate change than previous Local Plans.
There is however, no analysis of the climate change impact of the plan, let alone a strategy for how to mitigate those impacts.
The impact of removing land from Greenbelt for development goes further than the five purposes set out in the NPPF – it turns land that acts as a carbon sink into a carbon source. It is vital therefore from a climate change perspective to keep the release of Greenbelt land to an absolute minimum.
Current housing need figures for GBHMA should be more comprehensively assessed, and vacant dwellings and vacant social housing (which in 2018 in the West Midlands number 28,293
and 1,714 respectively) included in the assessment to provide a more thorough picture of the real housing need in the GBHMA. In order to minimise the climate change impact of new developments, release of greenbelt for urban fringe sites should be under moratorium until all sites in the GBHMA have been exhausted, not only through the planning process, but to delivery.
There must be a comprehensive assessment of vacant dwellings in South Staffordshire that could be brought forward for refurbishment. In 2018 there were 1,079 vacant dwellings in South Staffordshire. As former president of the American Institute of Architects, Carl Elefante, consistently points out: “The greenest building is the one that is already built”. Refurbishing and retrofitting existing buildings can not only reduce the need to sacrifice greenbelt land in South Staffordshire for new buildings; Heritage Counts research shows that when a typical historic building is responsibly refurbished and retrofitted, when the whole life of the building is considered, it will emit less carbon by 2050 than a new building.
Global warming of 1.5°C and 2°C will be exceeded during the 21st century unless deep reductions in carbon dioxide (CO2) and other greenhouse gas emissions occur in the coming decades.
It is clearer than ever following the most recent IPCC report, every opportunity to save on CO2e must be taken.
There are several serious omissions in the Local Plan relating to Strategic Objective 12:
Ensure that our communities are resilient and adaptable to the effects of climate change. Deliver appropriate climate change mitigation through renewable energy generation and ensuring that developments are designed and located in a way that delivers greater energy conservation and reduces carbon emissions.
The detail provided on the design and location of developments in insufficient and does not suggest this objective has been approached with any gravity. There is no mention of sites allocated for the renewable energy generation on which the objective seems to rely completely for mitigation.
Planning applications for Battery Storage Sites have been received in Lower Penn which require the release of Greenbelt land. Since decarbonisation of the grid is an essential part of climate change mitigation, Strategic Objective 12 should mean that BSSs and other renewable energy generation sites that are needed to facilitate the decarbonisation of the electricity grid must be integrated into the Local Plan.
Transport and Infrastructure
In 6.15 and 6.23 the document refers to transport as being ‘a significant source of the District’s carbon emissions’ it is unclear whether it is referring to the emissions of the council’s own estate and operations, or emissions in South Staffordshire as a whole. The only mitigation that seems to be presented in the Local Plan Review in relation to emissions from transport is to install single EV charging points at all new build homes, and for only 20% of parking spaces at residential flats, institutional accommodation and commercial developments. Given that car ownership in South Staffordshire is 1.47 cars per household and that 3.7% of households own more than 4 cars or vans, installing only one EV charging point is insufficient. Whilst some prediction could be made that car ownership will fall, the public transport, cycling and walking infrastructure in South Staffordshire is currently far too weak to support alternative transport types.
The new Local Plan hopes that the transition to ULEVs will mitigate the huge impact on emissions of tens of thousands of new car journeys. However, ownership of ultra-low emission vehicles (ULEV) currently in Staffordshire varies between Local Authorities, although in all cases, ownership levels are under 1% of all licenced vehicles. In order to meet Net Zero transport emissions by 2050, the uptake of ULEVs will need to significantly increase (to c.45,000 vehicles across Staffordshire by 2025) beyond its current rate of adoption (which anticipates less than 5,000 vehicles by 2025). In South Staffordshire as of 2019 only 0.32% of total registered vehicles are classed as ULEVs.
In addition, a large-scale shift to the use of electric vehicles must also be accompanied by a significant modal shift towards walking, cycling, ridesharing, and an increase in the use of public transport.
The Staffordshire Local Cycling and Walking Infrastructure Plan unfortunately focuses on the networks in and immediately around the main towns in Staffordshire: Burton upon Trent, Cannock, Lichfield, Newcastle-under-Lyme, Stafford and Tamworth. There is nothing in the plan to deliver any cycling or walking infrastructure in South Staffordshire. Data in the LCWIP shows that South Staffordshire has the lowest level of walking and cycling for travel to work in the county. This strongly suggests that at present, these transport options are simply not feasible for residents. Development in the district therefore locks in car use for what could over the period of the plan amount to more than 18,000 new residents.
It is highly likely that the future residents will be moving from areas served by better public transport and with better cycling and walking opportunities to this site, where car use is the only viable transport option for most journeys. A strategy that causes people to have to travel less sustainably cannot be the best one.
From DFT Gear Change: A bold vision for cycling and walking:
The purpose of the planning system is to contribute to the achievement of sustainable development. We expect sustainable transport issues to be considered from the earliest stages of plan-making and development proposals, so that opportunities to promote cycling and walking are pursued. Planning policies should already provide for high quality cycling and walking networks, green spaces and green routes, and supporting facilities such as cycle parking (drawing on Local Cycling and Walking Infrastructure Plans).
Moreover:
Increasing cycling and walking can help tackle some of the most challenging issues we face as a society – improving air quality, combatting climate change, improving health and wellbeing, addressing inequalities and tackling congestion on our roads.
Without significant investment and planning of a comprehensive Zero Carbon transport network, most of the proposed sites in South Staffordshire are unsustainable in terms of transport infrastructure.
Population Growth
Whilst the projected population growth for South Staffordshire over the Local Plan period is generally in line with projected population growth for England as a whole over the plan period, adding the additional 4000 houses that have been put forward as a contribution to the GBHMA pushes the growth for South Staffordshire well over the national average. Population growth for England is projected at 5% between 2018 and 2028, and at 10.3% between 2018 and 2043. Based on the average household size in South Staffordshire at 2018, these housing numbers equate to an increase in population of 20,781 – an increase of 18.7%. We believe this level of population growth in South Staffordshire is unsustainable and the infrastructure to support that level of growth does not exist and, moreover, is not laid out in the Local Plan. How South Staffordshire can support and would attract a significantly higher rate of population growth than England as a whole is not acknowledged.
1 Energy Saving Trust: Zero Carbon New Build – nine principles to underpin building standards
2 Baseline Report Climate Change Adaptation & Mitigation Staffordshire County Council October 2020
3 RICS professional standards and guidance, UK Whole life carbon assessment for the built environment 1st edition, November, 2017
4 There’s No Place Like Old Homes: Re-use and Recycle to Reduce Carbon. Heritage Counts 2019
5 RICS professional standards and guidance, UK Whole life carbon assessment for the built environment 1st edition, November, 2017
6 Based on construction emissions of 80tonnes CO2e per two bed cottage.
7 MHCLG (2018) Independent Review of Building Regulations and Fire Safety: final report.
8 Data to the end of September 2018 for England and Wales. MHCLG (2018) Live tables on Energy Performance of Buildings Certificates
9 South Staffordshire Council: Climate Change Strategy 2020
10 Vacant dwellings by local authority district: England. Source: council tax base (CTB) – statistical release:
https://www.gov.uk/government/collections/council-taxbase-statistics
11 SA of SSDC Preferred Option Plan – Appendix B
12 Vacant Dwelllings by Local Authority. England. Source: council tax base (CTB) – statistical release:
https://www.gov.uk/government/collections/council-taxbase-statistics
13 There’s No Place Like Old Homes: Re-use and Recycle to Reduce Carbon. Heritage Counts 2019
14 IPPC Sixth Assessment Report. Headline Statements from the Summary for Policymakers 9 August 2021
15 IPPC AR6 Climate Change 2021: The Physical Science Basis Pub. August 2021
16 HC12 – Parking Standards South Staffordshire Council Local Plan Review – Preferred Options
17 RAC Foundation Car ownership rates per local authority in England and Wales Source: 2001 Census and 2011 Census Date: December 2012
18 Baseline Report Climate Change Adaptation & Mitigation Staffordshire County Council 16 October 2020
19 Table 3.1: DC7701EWla – Method of travel to work by distance travelled ONS Crown Copyright Reserved
20 ONS Statistical Bulletin; National population projections: 2018-based
21 South Staffordshire Council Locality Profile 2018