Advearse have provided comments to Dorset Council on their draft Climate and Ecological Emergency Strategy. We have raised many concerns about the strategy and in particular it’s lack of urgency
The Dorset Climate and Ecological Emergency Strategy consultation document is detailed and wide ranging.
There is much to comment positively on, but for brevity we focus on those aspects where we consider the emphasis is wrong and where mitigation options are not considered or included in the strategy.
The approach adopted in the consultation document shows a lack of urgency.
The stated preference is to do the investigation and information gathering first before setting out the Dorset Council strategy. In normal circumstances this might be a sensible approach but given that the consensus view of climate scientists is that the Climate Emergency presents an existential threat to mankind a greater sense of urgency and action is essential.
In May 2019, Parliament declared a ‘climate change emergency’ and has a commitment to reduce greenhouse gas emissions by the United Kingdom (based on 1990 levels) by 50% by 2025 and by 100% by 2050. Strategies and action plans are being established to achieve these goals. At a local level many councils have followed this approach by setting challenging targets in keeping with the crisis and UK Government targets and then working out how to achieve them.
By setting targets now Dorset Council can quickly move to developing strategies/actions to achieve the targets within clear timeframes. The current approach is likely to involve continuous rounds of consultation, debates, updates and no doubt more consultation before even getting to set formal targets and start taking action. This process lends itself to “kicking the can down the road” and not facing up to the tough actions that will need to be taken now.
We believe that Dorset Council should:
- Set challenging targets in each of the areas set out in the consultation. A good start is to accept the overall target mentioned below. So for Dorset that would be a formal target of halving carbon emissions by 2030.
- These targets should cover areas where the council have direct control and also where the council can use their authority to make other stakeholders deliver on combating climate change. A good example is ensuring that developers provide housing to high eco standards for all housing covering all current and future outline and detailed planning applications.
The Introduction notes:
Recent reports note that we must act swiftly to cut emissions if we are to avoid the worst impacts of climate change, caused by global temperatures rising above 1.5 degree.
What is not said is the consensus view of climate scientists that:
to stay below a 1.5°C increase in global temperature by the end of the century means that carbon emissions will need to be halved by the end of this decade and in practical terms that means a reduction of 7.6 % every year throughout this decade.
Knowing that this goal is essential – the Dorset Council strategy should just accept it and then focus on how it can be delivered for Dorset.
The Climate Emergency
The brief summary of Climate Emergency correctly notes that we have only 8-10 years at the current rate, within which serious action is required to avert this crisis and avoid the worst impacts. This reinforces the importance of setting targets now and then striving to achieve them. Procrastination is the enemy of success.
The summary of impacts provided includes a number of understatements.
Sea level – It notes that sea level rise may be in the range 27 – 115 mm by 2100. However, in November 2019 a report from the Institution of Mechanical Engineers advised government to prepare for a 3m rise by 2100. Also in 2015 an eminent group of climate scientists advised that a 3m rise could occur as soon as 2050.
Clearly these predictions would make the impacts on the six key areas that are identified far more severe.
The first key area noted is – FLOODING & COASTAL CHANGE RISKS TO COM-MUNITIES, BUSINESSES, & INFRASTRUCTURE
Flooding has been an issue for many parts of Dorset for many years with increasing concern at the continued building of large housing developments in known flood plains.
The IPCC 5th Assessment Report Summary for Policymakers (p20) notes:
The UK is set to see about a 10 per cent rise in annual average rainfall by 2100 compared to the period 1985-2005
It’s not just the total amount of rainfall that scientists expect to increase. The IPCC report also predicts Europe and the UK is “very likely” to see more heavy rainfall events by the end of the century. A lot of rain falling in a short space of time raises flood risk, and there’s already evidence heavy rainfall events are getting more frequent in the UK due to climate change, as a report recently released from the Met Office explains.
The risk of rising sea levels and increased major flooding events need to be fully acknowledged in the Strategy Report. This should spur the need for serious actions to avoid and mitigate these risks.
A straight forward and sensible action that Dorset Council can take is to decline all building and housing developments in flood plains and areas at risk of flooding in the future. If DC continues to permit building in flood plains then they should not rely solely on surveys conducted by third parties for developers.
Dorset’s coastline is, and has been for centuries, under attack from the sea, even without a rise in sea-level. Recent years show that quite soon major changes will be seen in the local coastline of Chesil Bank. We understand that Dorset did ask a firm to conduct surveys of Chesil Bank and the effects of tide, winds etc on the shingle.
It is important for DC to share with the public these and similar reports on coastal erosion and the expert recommendations made. This will help to build public confidence that these issues are being taken seriously by DC and the appropriate actions being taken to minimise coastal erosion.
Action Against Climate Change
The Paris Agreement is misquoted. The consultation document states that the agreement was to keep global warming below 2°Cwhereas Article 2(a)actually said:
Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change.
This might seem like a small point but again it suggests a failure to acknowledge the sheer scale of the climate change challenge.
Areas for Action
This document explains how the eight areas for action were identified. A task force was set up for each area and each is reported in subsequent sections of the consultation, including summary action sheets.
There is a lot of detail and on page 22 refers to ‘Dorset Council’s Carbon Budget’ which includes the statement “We have chosen to set an earlier target by achieving a carbon neutral Council by 2040”. Given this is only 19 years away it is vital that DC move into action this year to have any chance of achieving that goal.
Unfortunately this goal only covers Council operations and as “Dorset Council only has control over the carbon emissions produced from its operations and this will be a key focus of our initial programme”.
The report refers to under the greenest scenario energy demand in the Dorset Council area will be around 4 billion kWh/yr (4,000GWh/yr) and for Dorset Council alone it would be 60 MW/yr. So that means that Dorset Council represents just 0.0015% of what is needed for Dorset.
So the Direct action plan will not address 99.9985% of the carbon reduction required. Whilst there are some Indirect (I) and Influence & Partnership (P) actions mentioned these are vague and limited.
In reality to address the climate emergency Dorset Council have to focus on the 99.9985% and take concrete actions to address as much of this as possible. Spending a lot of time and effort on the tiny fraction of energy consumption that their operations represent will be seen as virtue signalling and avoiding facing up to the real challenge.
There are many areas where Dorset Council (and the town/parish councils) has considerable influence and control. What is required is some imagination and determination.
For example encourage the use of electric vehicles by using nudge tactics: waive car parking charges and taxi driver fees for EVs, have EV priority parking spaces and taxi ranks. There are many other actions we have noted in this document, which although potentially politically difficult for DC to take, would make a big contribution to achieving the necessary climate change goals.
The action plan includes as an objective: Establish a positive planning policy frame-work and toolkit for maximising the use of renewable energy within development.
It is unclear what developments are included. Does it cover both commercial and residential development? Also are there any targets that define “maximise”?
Lobbying is identified as requires action to ensure new building, including residential, are carbon neutral.
The proposals for solar farms or on-shore wind turbines are sensible and should also cover off-shore wind energy. Actions are needed to encourage schemes to provide for these renewable energy projects.
Current planning legislation
We note that the National Planning Policy Framework (2019) [NPPF] states in paragraph 148:
“The planning system should support the transition to a low carbon future in a changing climate… It should shape places in ways that contribute to radical reductions in greenhouse gas emissions…. in line with the objectives and provisions of the Climate Change Act 2008”.
It is striking to note that the Strategy Document states that current planning legislation prevents setting zero-carbon standards for new builds.
So it seems that the planning system will have no real part to play in setting the new energy efficiency standards. Instead, they will be implemented through the Future Homes Standard proposed in October 2019, whereby the standards in Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings will be tightened from 2025. New homes built to comply with the Future Homes Standard will be expected to produce 75-80% lower CO2 emissions compared to current levels and will be zero carbon ready.
Clearly the 2025 date set by this standard is totally unacceptable and Dorset Council should lobby on this issue to ensure that the date is bought forward to 2021. Whatever date is set for these new standards Dorset Council should ensure that internal resources are applied to the monitoring and enforcement of these and existing carbon efficiency building regulations.
DC should also actively lobby for eco friendly changes to new build regulations including: installation of solar panels, heat pumps, electric vehicle charging points.
DC should give much more attention to public and domestic applications incorporating Heat Pumps that are efficient in generating energy far greater than the energy they use.
Zero carbon houses in Dorset
The action plan rightly includes an objective to ensure new buildings in Dorset are zero-carbon. It is noted that that 18,000 houses will be built in the next 10 years and that these will need to be zero-carbon.
The actions to achieve this are listed as I (indirect) and do not include lobbying government to alter planning rules to allow zero-carbon to be required. This lobbying action should be included. Also the timescales for developing planning policies are far too long and lack any sense of urgency. It should not take 2 to 3 years to develop policies and strategies.
Despite the accepted limitation of the current planning laws there is a need for more direct Dorset Council actions to meet their goal of zero-carbon houses. Projects such as the Watton eco-Village in Bridport envisage zero-carbon housing.
It is strange that Dorset Council have shown no support for the Watton Village project. Particularly, given the eco and zero-carbon goals built-into that project. Surely these goals and the approach of Watton eco-Village are necessary for all major developments in Dorset.
A suitable action would be for all projects from Spring 2021, either approved in Outline or detailed planning permission to have, as part of the approval, targets for improvement of water use and recycling, insulation, heat conservation and re-cycling.
An eco first approach to housing development projects should be encouraged and nurtured by the Council. The Council have a responsibility to meet the Government set housing targets but that does not mean that they should just accept the traditional housing developer/landowner led projects that fail to put zero-carbon as a priority and focus instead on profitability.
By encouraging projects with a zero carbon focus the Council will have options to give these schemes priority over the standard housing developer led projects without breaking the current planning laws. Surplus Council owned land can be earmarked for affordable zero-carbon housing schemes.
Second home ownership in Dorset continues to grow with 20% of houses purchased in 2018 were second homes. With the Covid pandemic in 2020 this trend has continued. Second homes add to the climate change emergency due to the cost of heating etc. Also there is the cost of building houses for only part time occupation with the impact on the availability and pricing of houses for local people.
An action to address this is to require all new major housing developments to not permit second/multiple house ownership in perpetuity.
The Council tax for second owned houses should be increased each year in excess off the normal tax increase. The extra funds obtained can then be ear marked for actions to combat climate change.
Existing householders should be encouraged to make their homes more energy efficient. Discounts on the council tax can be offered where proven energy efficient and carbon reduction steps have been taken.
DC should also lobby government to increase SDLT (Stamp Duty Land Tax) on second homes with the extra tax raised ear marked to fund social housing. DC can also give priority to planning applications for land used for static caravans which make perfectly good second/holiday homes and have a low carbon footprint and occupy a smaller plot than a house would.
A final point is that the meaning of zero carbon houses should be clearly defined as this will help in ensuring appropriate targets are set and actions identified.
- Does it apply, as per building regulations, only to ‘regulated energy’ – those fixed and integral services and fittings in the home such as the space heating, hot water, ventilation and lighting – or also to ‘unregulated energy’ including things a developer can’t as easily control such as those used through plug-in appliances and cooking?
- Does it relate to just a home’s day-to-day operational energy use or to life-cycle carbon emissions, including that embedded in its construction?
The technical paper indicates that there is an opportunity for increased tree planting and that guidance should be developed to ensure community tree planting initiatives are ecologically robust and sensitive to the local landscape.
However, the action plan is restricted to developing guidance on suitable tree planting and does not commit to any planting on Dorset Council land. This commitment should be strengthened.
The requirement for an increase in tree planting on new housing developments should be a further action.
This will show that DC is taking more notice of the huge contribution to improvement of the air we breathe from planting trees. Each large development should be the subject of a Survey and Report by the Council’s Environmental team particularly addressing the need for trees with recommendations of the extent and type of planting needed. These documents should be made public.
It is stated that transport alone is responsible for an estimated 765 kilotons of CO2e each year, making it the single biggest contributor to the county’s footprint.
A significant shift will be needed to make active travel and public transport the first transport mode of choice.
Two of the areas of action noted are:
(a) to ensure access to sustainable transport is considered in planning applications and
(b) improve quality & availability of public transport to make services more at tractive to the travelling public.
It is recognised that the rural nature of the county generally makes the private car the transport mode of choice for most in the rural areas simply because it is the only option.
However, for many areas this will always be the situation as it will be uneconomic to provide public transport suitable for commuting throughout the villages in the county. Measures are outlined to make public transport more attractive to use, but where public transport is not a realistic option the three main ways of reducing car mileage are:
- removing the need to commute by encouraging home working
- preventing additional journeys
- encouraging cycling
The action plan does mention home working and stated that it will work with Digital Dorset to promote the use of ICT to individuals and businesses. It must be noted that this is only committing to produce promotional materials in a one year timescale, which is disappointingly slow.
However, no mention is made of increasing the provision of high speed fibre broadband to rural locations. Lobbying for this should be included in the actions as a priority as costs are low and benefits could be considerable.
Preventing new, unnecessarily long private car journeys is noted in two actions. To improve low carbon transport access to sustainable transport will be considered in planning applications.
This is to be welcomed, but it is difficult to comprehend why the target date for this is the end of 2023, when it could be included in planning assessments with immediate effect.
Secondly, it states that Through the Local Plan ensure (as far as possible) developments are located in sustainable locations close to key services & the need to travel by car is reduced.
Again this is welcomed. It is noted that the target is to have policies developed and agreed by 2023. This is the date that the Local Plan is due to be published, but for this to happen it is essential that the Local Plan Options Consultation must include this commitment.
We agree with Dorset Council effort to move on the climate change emergency. The Dorset Climate and Ecological Emergency Strategy consultation document is detailed and wide ranging.
Although this seems in the main to have been prompted as a response to climate change protests in May 2019 when the council declared a climate change emergency.
Given that it is nearly 2 years since this declaration the pace of movement is far too slow.
The approach adopted in the consultation document continues to show a lack of urgency.
Our main criticism is that there are many actions that the council can take now and do not have to wait on consultations etc. Some actions may be politically difficult (eg increase council tax on second homes, only accept major housing schemes that carbon neutral etc). But they are essential and it is down to the council’s moral leadership to grasp them and get on with doing what they promised when they declared a climate change emergency.