Planning and Development

Response to Bristol City Council’s proposed Supplementary Planning Document 5

Supplementary Planning Document 5

SUSTAINABLE BUILDING DESIGN AND CONSTRUCTION

November 2005

A Response from Bristol Green Parties


1.  SUMMARY

As a statement of principle and a source of suggestions SPD5 is admirable, but we do need far stronger controls if the ambitions behind SPD5 are to be fulfilled.  We cannot leave a sustainable future to chance and to the market.  

If major improvements can’t be made now, we hope that a further consultation, very soon, will be about the high standards that will be a prerequisite for any new development, or major adaptation, that seeks planning permission.  One vital proposal (the Zero Net Carbon Standard) is included here.

We also hope that some land use designations can be relaxed where developers can show that they fully respect the spirit behind the designation – through ‘low visibility’ developments, car-free guarantees etc. that would have a negligible footprint.

2.  THE MYSTERIOUS LIMITS TO THIS CONSULTATION

We understand that SPD5 is in most respects simply an adjustment to planning structures to take account of changes that have been introduced by the Government, particularly the replacement of Local and Structure Plans with Local Development Framework, without making any substantive change to the way the City Council appraises new development proposals.

We do wonder why on earth policy improvements can’t be considered  right now.  In fact the Council’s own “Bristol Local Development Scheme”, which sets out the programme for the Local Plan’s metamorphosis into a Local Development Framework,  seems to suggest that this is the time for review:-

“All policies within the Bristol Local Plan (adopted 1977) will be saved for 3 years. During this period policies will be reviewed and, where appropriate, incorporated into future Local Development Documents”

If it can’t be done now, we hope that SPD5 will quickly be reinvented as planning requirement rather than as planning guidance – and that we’ll have the opportunity to suggest very specific improvements.  In fact one – because it should have been done yesterday – is detailed below.
 
3.  WHY  WE  NEED  HIGHER STANDARDS - NOW

Put simply, we are living so far beyond our means that we cannot sustain today’s patterns of resource use – and here, resource doesn’t just mean raw materials, it means the biosphere on which our quality of life, even life itself, depends.  Climate change is, of course, the obvious example.  So sustainable construction is not just an option, it’s a must.

The good news is that the world has woken up to this, and from the highest level of international government to the most local level of community and enterprise, there is a string of aspirational statements calling for change in the way we do things.

The bad news is that generally that’s all they are.  The city’s current ‘Bristol Sustainable Guide to Construction’, like the proposed SPD5, offers developers good advice and good arguments for better design, and explain why it’s needed – but developers main objectives are economic and most will prioritise the bottom line over and above any non-statutory sustainability wish-list.  The buildings going up today will be standing in twenty, forty, a hundred years time, and they’ll encourage a particular lifestyle:  as things stand, very few fit our picture of how the world should be by then – they’ll be part of the problem, not part of the solution.  

4.  REGULATION – OR PERSUASION?

 It is, of course, an accepted reality that any developer should be subject to particular obligations, (for instance the Building Regulations, or the prescriptive land use designations of the Local Plan)  and the planning system provides the main framework for making sure that happens.  What may be in question is the degree to which local, regional, and national governments should lay down the law about the detail.   We feel confident that the public interest must come first – and that includes the interests of the future generations whose environment is being moulded by the decisions that developers are taking now.  Therefore, we must have very strong planning requirements based on ‘meeting today’s needs without compromising future generations’.   We can’t leave that to the developers.

However, this does not imply that there’s any ‘perfect’ sustainable design to be laid down for any new development, and of course we wouldn’t want to see Bristol or any other authority going down that road.  We need high standards set for (for instance) energy efficiency; but we don’t have to be prescriptive about how it’s to be achieved.

5.  ONE VITAL  REQUIREMENT

If we could commend just one overarching requirement for development in the city, it would be the one developed by Friends of the Earth calling for a Zero net carbon standard.   It appears to meet the recommendations of the Local Governent Association, the Energy Saving Trust, and the Energy Efficiency Partnership for Homes:-

The Council is committed to addressing and reducing the causes of climate change.

To achieve this objective all new development, either new build or conversion, will be required to demonstrate that it does not add any net carbon dioxide emissions over the life-cycle of its operation. Developers may adopt a range of technological approaches to achieve this objective, including:
1)    A zero waste, zero carbon standard (based on the Z-squared approach) for any large scale housing development.
2)    A minimum of EcoHomes ‘Excellent’ or equivalent recognised standard for any housing development of one unit or more.
3)    A minimum of BREEAM ‘Excellent’ for any commercial development.
4)    The development of on-site renewable energy generation capacity.

It will be for the developer to decide which approach is the most appropriate to deliver a zero net carbon standard in their specific proposal. The applicant must demonstrate, through a development appraisal, if the adoption of such an approach results in an undue burden on the viability of the scheme.

In addition, there will be a presumption against any development which results in a significant net increase in carbon dioxide emissions.

It is arguable that such a policy should be included in the LDF’s Core Strategy rather than SPD5, as it impacts not only on Sustainable Construction, but on the ‘Residential Design Guide’ and the ‘Generic Development Control Policies’.   Certainly we would like to see it as a cornerstone of the LDF.

6. PRECEDENTS

Although Bristol has its fair share of initiatives with admirable ‘eco-design’ built in, the city does lack the means to make sure that all development approaches the standards set by the best of those initiatives.   

Some local authorities are currently well ahead of Bristol – for instance Merton, which has succeeded in warding off challenges to its policy of requiring a proportion of on-site renewable energy in significant developments.   North Devon wants to introduce a similar policy – and finds that the Inspector who might have challenged it has come down in favour of strengthening the policy further.  We note that N. Devon is introducing a series of new requirements for developers, over and above minimal standards laid down by government.   Calderdale is following a similar path, as probably many others are doing.   

We see no reason why Bristol shouldn’t  play a part in pushing the boundaries further – as a city that anticipates major growth without making too many compromises to attract it, it’s in a strong position to take a lead in setting very high standards.  That could bring further rewards, if the city can establish itself as a centre of excellence for progressive design.

7.  ONE CASE FOR DEREGULATION

Much of the foregoing suggests that the City Council needs to be more prescriptive if it's to secure improved standards of sustainability in new development.   However, we do feel that in many cases the opportunity for high quality design is being lost.  This is simply because market pressures and land scarcity squeeze out those who would build to a smaller 'community' scale, emphasising designs that consider the ecological impacts of the buildings and of the life-styles of those who occupy them.   

We wonder whether the council could consider relaxing some of the land use policies to permit development of this kind where 'ordinary' development would not be allowed, effectively opening up a market niche for such projects that would not otherwise be viable.   Of course there may be other ways to help achieve this, for instance by adopting policies that would justify sale of land to such 'green' developers at an affordable price, rather than the excessive prices that can be reached in this city because of land scarcity.

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Thanks to the Sustainable City Team for their considerable efforts in raising awareness of SPD5 and their invitation to comment.

For any follow-up, please contact
Peter Goodwin, Bristol Green Party, at
11 Lanesborough Rise, Stockwood, Bristol BS14 8AJ