Inspector Runs Rule on High Carbon Plans

As a Green Party councillor on Norfolk County Council, I am in a constant dilemma of how to spend my time. Do I focus on building a better future or opposing what’s preventing it? Joanna Macy has written that both are part of a whole: we need both the transition type work of creating a life-sustaining civilization and the resistance actions that slow down the high carbon “industrial growth” society.

The last three weeks I have spent considerable time, doing the latter, speaking out against the high carbon growth plans in the Local Development Framework (LDF) for the Norwich area. To get the acronyms over with, our local LDF is actually called a Joint Core Strategy (JCS) – “joint” because it’s been developed by four councils (Norfolk County Council, Norwich City Council, Broadland and South Norfolk) in partnership. The partnership organisation is the Greater Norwich Development Partnership (GNDP).

The forum for resistance was the Examination in Public (EiP) of the JCS a three week marathon during which a Planning Inspector looks at every aspect of the plans for their ‘soundness’.

Whilst governments grapple at Cancun to find an international agreement for decisive action on climate change, we know that we can make changes from the personal to the global. I went into local politics five years ago because I saw a need to promote low carbon development within local Government. I hoped that the processes such as writing LDFs would enable local government to take a serious, publically accountable, evidence based approach to climate, which takes me to the first theme … carbon doesn’t count and isn’t counted.

This is where I start: any plan now has to balance how more people can come into the Norwich area, live and work, whilst we overall cut emissions across the whole area year-on-year. Squeezing carbon out of the system is not easy and therefore carbon reduction must be the number 1 planning objective. More than that, the JCS needs to set out targets for carbon reduction across the plan area and then work out how new housing, people and jobs can be accommodated. To be ‘sound’, the JCS needs a carbon accounting mechanism so progress against targets could be checked.

The JCS does the opposite. It builds growth around a high carbon infrastructure, and does not attempt to even consider carbon targets or any carbon accounting. Yet in the bizarre ‘Alice in Wonderland’ world of modern planning, amazingly, Policy 1 of the JCS is ‘Addressing climate change and protecting environmental assets’.

Without apparent embarrassment, the GNDP proclaim this Policy 1, despite the fact that the ‘most critical’ piece of infrastructure for the JCS is the proposed Northern Distributor Road (NDR). This is modelled by the Council themselves to produce 25,000 tonnes of CO2 per year in addition to current levels – equivalent to 6% of Norwich’s current transport emissions. There couldn’t be a clearer carbon disbenefit working against Policy 1.

A key component for LDFs is the Sustainability Appraisal (SA), but the JCS SA does not mention carbon reduction targets or accounting, nor seek to use any quantifiable data on emissions within its appraisal methodology. Nor, at any point, does the SA mention the emissions associated with the NDR. As I said in my evidence:

“This is not only a major omission, but in this author’s view a profound methodological flaw, in appraising sustainability at this time, when this country has had a Climate Change Act already on the statute for 2 years, and Carbon Budgets established up to 2023.”

Through my evidence, I kept trying to make the point that unless there is a genuine carbon-centric strategy to start with, Policy 1 and other ‘climate aspirations’ are just bound to fail. It’s not rocket science, but if GNDP started to think carbon-centrically, the NDR would just drop out of the options. Other more interesting options would come in too like bringing back empty properties into use, creating communities where people can live and work locally, building more such communities in existing areas, ensuring good and supply for local food growing and initiatives such as community support agriculture (CSA).

You might ask how did all this happen? How did a plan so out of kilter on carbon change come in being? Theme two: secrecy and public exclusion …

During the first day of the EiP, on the overall theme of ‘legitimacy’ of the JCS, several representations were made by community stakeholders on the very major concerns about lack of public transparency, democratic process, political inclusion and fair political representation, in other words the secrecy that has dogged the development of the JCS. My own evidence to the EiP gives 4 pages of detailed representation on this alone.

The key point is that the GNDP has developed its plan behind closed doors, at meetings closed to the public and the majority of locally elected councillors. It has refused calls to open its meetings to the public and for agendas and minutes of its meetings to be placed in the public domain. All of this is in contravention to the UNECE Aarhus Convention that is based on the principle that sustainable development can be achieved only through the involvement of all stakeholders.

Theme three biodiversity ... A notion that was flying around the EiP was that biodiversity can be increased by building houses. I couldn’t help the word ‘greenwash’ reverberating around my head each time this was mentioned. Looking into it, it’s actually enshrined in the Planning Policy for Eco-towns which states that "Eco-towns should demonstrate a net gain in local biodiversity". The Biodiversity Design Guidance for the Ecotown proposed for NE Norwich demonstrates how this would be achieved through building in ‘green infrastructure’ – hedges, ponds, orchards, gardens etc.

Now, there are good things about this: it does increase some species, will tend create a nice liveable environment, and helps to protect areas that have special biodiversity features. At least, the GNDP are thinking about it and have worked with the likes of Natural England and Norfolk Wildlife Trust on a Biodiversity Working Group (unlike Climate Change where they do not appear to have even thought about it).

Question – which photo has more biodiversity? which photo has more nature?

Above: Current arable at Rackheath (from http://www.snubcampaign.org/)

Below: proposed Rackheath eco-town (from http://www.rackheatheco-community.com/)

However, I found the zeal for it worrying. Isn’t there a hidden level of suggested meaning, that one can replace nature and somehow land up with something more natural? This rankles. It’s a sort of charter to build on green belt despite common sense is that you can’t build an artificial environment, basically a small town even if an ‘eco’ one, and make it more natural than the natural landscape that was there before. It makes no consideration of the wider impacts of development: using a reductionist approach, it essentially says let’s add up the bits of biodiversity that we can measure and value in a certain way, and see if we can get a bigger number after than before. However, there’s no similar calculus given for natural value: space, sense of space, light, noise etc. It doesn’t look at wider impacts – for example, what will be the impact of thousands of new houses close to the Broads be on the Broads themselves?

I raise this as a flag. We need to be careful of terms like ‘green infrastructure’ and ‘net biodiversity gain’, and remember that more holistic experiences of landscape, nature and space are also crucial elements of our environment.

So after 3 weeks where did all this get to? During the last week, the Inspector ran the rule over the JCS and indicated that he wanted to explore a Plan B without an NDR. This is on the basis of the ‘planning technicality’ that the road may not get adequate funding from Government, not on whether it is a good idea or not. Even so, this is huge breakthrough against the fixed position of the GNDP of only Plan A being possible. He asked the GNDP to consider a Plan B and there will be a further day of Hearings on December 9^th around the NDR and Norwich North East.

Once again, the four council leaders of the GNDP will make their response behind closed doors. However, what ever happens we can continue to tell the GNDP that it is no longer acceptable for decisions on how the Norwich area grows over the next twenty five years to be made by a handful of people behind closed doors, and that we demand that all councillors and the public are involved in further developments. And, that carbon reduction must now be built in as a main plank of the plans. Andrew Boswell