STSD - Somerset Trust for Sustainable Development

Planning

Planning is a central area of work for long term strategic influence to encourage sustainable construction

In particular Councils have to recognise that now is probably a critical time in the local plan timetable if they are to ensure that over the whole lifetime of the Plan it will be able to encourage rather than hinder sustainable construction

In this sense the Local Plan offers a real opportunity to encourage more sustainable forms of development and construction. However, in planning for sustainable construction (and sustainable development) it is important to be clear to distinguish between:

Activities that the planning system can control;
Activities that the planning system can influence.

It is primarily the areas of influence rather than control that the planning system can use to create positive effects that help the wider process of encouraging and enabling sustainable construction.

There are elements of PPG1 (General Principles) and PPG3 (Housing) that offer a route for paying greater attention to sustainable construction in the local planning system. Also local plan policies are required to ‘take environmental considerations into account comprehensively and consistently’ (PPG12, Para. 4.4).

Therefore key issues for planning are:

Take advantage of references in national and regional planning guidance ( PPG1, PPG3) to introduce sustainable construction issues within a three-stranded approach to ‘planning for sustainable development and construction’;
Whether specifically stated in national guidance on not, by implication logic dictates that:
- Both in theory and in practice‘Good Design in the 21st century’ has to take account of 21st century sustainability considerations - otherwise it is not good design because it is ignoring very important current and future issues;
- The planning system has a primary objective of making development more sustainable; development as a whole cannot be sustainable without its constituent elements being sustainable; construction is a major constituent of the development process; therefore, if development is to be sustainable, then construction has to be sustainable. Thus the planning system has to determine how it can best help influence construction to be more sustainable;
- The planning system exists ‘to control the development and use of land in the public interest’. Perhaps more than anything else,sustainability issues are public interest issues. Controlling the development and use of land so that it is significantly more ecologically, socially and economically sustainable in the short and long term is therefore absolutely in line with the legal basis of the planning system.
For South Somerset, or any other district addressing these issues, a three stranded approach will achieve maximum effect in encouraging sustainable construction - this must be based on:
- Sustainable construction integrated into Fundamental Principles of Key Site Development Briefs;
- More clearly defined policies and supporting statements included in deposit Local Plan that encourage sustainable construction, with such policies argued as being an important route to achieving objectives identified in PPG3:
  - ‘good design’ (para.54, PPG3),
  - significant improvements in quality of life’ (para.1, PPG3),
  - ‘taking account of public health’ (para. 56, PPG3),
  - promoting energy efficiency of new housing where possible’ (para.56, PPG3) and
  - creating ‘more choice of type of housing and lifestyle’ and high quality living environments’ (para. 2, PPG3), etc.;
- Supplementary Guidance on Sustainable Construction, referred to in Key Site Briefs and Local Plan as a key district wide reference
Strengthening sustainability within Key Site Development Briefs is essential if the SC project is to be significant rather than superficial, because the Key Sites represent 56% of all the housing left to be built in the Local Plan period, and 83% of the housing to be built on allocated sites identified in the Local Plan. Working with ‘Best Level Partner’ housing associations to gain high sustainability standards within social housing will help ensure that key sites include a considerable element of good practise.
‘If the energy efficiency of new housing built as a result of local plan allocations is not significantly improved all the gains in energy efficiency and CO2 reductions achieved through HECA will be wiped out.’

David Pickles OBE, Director, Newark & Sherwood Energy Agency.
The planning dept. should aim to create a logical definition of ‘Good Design in the 21st Century’ and apply this comprehensively with in all its work. The concept should be defined as implicitly needing to address all of the following three items:

Good urban design, layout for sustainable transport systems and aesthetics - for best use of land and more sustainable transport patterns;
Good landscape design including sustainable drainage systems - for wildlife, biodiversity, improved quality of life and sustainable drainage;
Sustainable construction - for efficient, healthy and high quality living environments: consisting of

Energy and water efficiency with sustainable supply systems where practical;
Design for healthy housing, including maximum use of non-toxic materials and natural light and ventilation;
Maximising local and regional materials and products;
Waste minimisation;

Both a) more well defined local plan policies and b) supplementary guidance on sustainable construction will help support the drive for sustainable construction and lifetime affordability to be the norm for social housing via partner Housing Associations;
Research is needed on innovative policies included in other local authorities’ local plans, adopted and on deposit, and to derive relevant policies for SSDC deposit local plan;
A forward looking and innovating attitude is needed in planning that recognises that if the opportunity to introduce sustainable construction into the Local Plan and the South Somerset Design Guide is missed, that will have a significantly detrimental effect on a) other work to encourage sustainable construction, and b) on work to ensure that the planning system encourages rather than hinders sustainable development in general.

Given the Local Plan status and timetable, and current work programmes, the key question for any council is:

How can the Council and the Planning Department ensure that effective action is taken to integrate sustainable construction considerations into the planning system sooner rather than later?

A three stranded approach is the major planning recommendation - it is for councils themselves to determine if, how and when it implements this.

Conclusions and recommendations as to what needs to be done are identified here; if politicians and officers agree with these priorities, it is for the council to determine how, when and by whom.

Recommended Targets for 2001:

Secure justified additions to the local plan that address sustainable construction
SPG on Sustainable Construction published, either within or separate from the Design Guide;
Key Site Development Briefs published that establish local benchmarks for ‘good design’ of new development, and incorporating sustainable construction considerations on an integrated basis, not as a special issue;
Implementation of effective and ongoing training for planners on ‘planning for sustainable development and sustainable construction’.

Expected timetable of sustainable construction effects to be achieved via planning:

November 2000: completion of Development Brief for Lufton Key Site to go out to consultation incorporating statements that incorporate sustainable construction within concepts of ‘good design’, and with a detailed appendix on sustainable construction for guidance.
2001: work on other Key Site Development Briefs based on Lufton: Wincanton, Yeovil, Chard, Crewkerne - this will establish a benchmark for sustainable construction aspirations for new build development across the district.
2001-2002: Supplementary Planning Guidance on sustainable construction, either within South Somerset Design Guide, or as a separate document
2004: final adoption of Local Plan, incorporating policies and statements of intent on sustainable construction.
2004: development of Lufton key site, to standards established by the adopted Development Brief

Conclusions

The key point for is that this report identifies the key issues and what needs to be done, with a broad indication of how it might be done; it is for the council and the Planning Department in particular to determine how specifically it is to be achieved, when and by whom.
Most councils face similar issues in planning policy and practice; the issues that are identified here would probably apply to the vast majority of local authority planning teams, which all face the challenge of addressing a weighty, bureaucratic and essentially negatively oriented planning system. However, if the local authority wants to be an innovator it will also most certainly need to consciously seek out and implement an approach that makes its planning team a little more unusual and innovative in comparison with typical policy and practice

Recommendations

In line with references in PPG advice, it is recommended that Supplementary Guidance and work that introduces sustainable construction to Key Site Briefs, is supported by policy additions or additions of statements of intent to the deposit local plan. It is recommended that the following issues should be considered for such additions to the plan:

1. Re-incorporating the statement of intent on environmental concerns in buildings alongside the policy on energy efficient design that replaced it in January 1999.
2.
- Adding a policy that relates sustainable construction to public health issues and energy efficiency (as referred to in PPG3 para. 56), as well as the Environmental Considerations for Development Plans (referred to in PPG12 para. 4.4). In particular it can be argued that incorporating policies and statements on sustainable construction is a key way for the development plan ‘to be drawn up in such a way as to take environmental considerations comprehensively and consistently into account’ (PPG12 4.4).
- A policy or statement of intent that accompanies 2 (a) above which calls for best practice standards of sustainable construction (efficiency and healthy housing) for all social and affordable housing in the district, to achieve life-time affordability (affordable energy and water) and for reduced health costs for those most in need.
- A local plan statement of intent accompanying the above which generally encourages best practice examples of a sustainable housing (or mixed use) development within the district for the specified purpose of establishing local benchmark standards for good design (see 3. below). This can be backed up by the same arguments as 2 (a) above, with a statement that this will help ‘promote good design in new housing developments in order to create attractive, high-quality living environments’ and more choice and a better mix in the … type … of housing than is currently available’ (PPG3 para. 2) and contribute to ‘improving the quality of life’ (PPG3 para.1 - government policy on sustainable development regularly describing SD as improving the quality of life). Paragraph 3.13 of PPG12 states that local authorities should learn from the experience of other local plans, therefore this statement of intent can also borrow (directly or by adapting) from other innovating Councils such as LB Sutton. In Sutton such a statement in the Deposit Plan led directly to the ZED exemplar project at Beddington.

3. A simple policy or statement that defines what 'Good Design for the 21st century' means - and indicate what represents ‘poor design’ (as PPG3 gives Councils the power to turn down such applications). 'Good Design' is expected to reflect 'Good Practice' locally and nationally, taking advantage of the increasing use of the 'benchmarking' concept within the construction industry. The Egan Report makes clear that ‘normal practice’ in the construction industry usually is not ‘good practice’. Defining good design will support work on the Key Site Briefs, etc. as well influencing other development applications. It is recommended that Good Design is defined as involving three elements:
- Aesthetic, layout, transport and urban design concerns;
- Landscape and ecology;
- Sustainable construction: incorporating design for 21st century performance (energy, water efficiency and liveability), and design for local and healthy, non-toxic materials to address public health issues, pollution and energy use (both associated transport energy and embodied energy) and to create healthy, efficient buildings.

4. A policy or statement of intent relating to or, if possible, requiring an expert assessment of Combined Heat and Power (CHP) / local community energy schemes for all development projects above a certain scale (e.g. via a feasibility study funded by Energy Savings Trust), in particular in relation to all Key Sites (RPG and PPGs, as well as DETR’s Planning for Sustainable Development: Towards Better Practice).

5. A broad policy that addresses PPG1 para.19 should be included, stating that an outstanding scheme, that demonstrates ‘responsible innovation, originality or initiative’ may ‘exceptionally justify departing from them’ [other policies]. This would be valuable based on recognising that whilst in the short term the policy addresses current DETR interpretations of ‘good design’ (which in itself is sufficient to warrant such a policy), given current trends in policy on sustainability, over the period of the plan DETR interpretations of ‘good design’ may evolve to incorporate sustainable construction more explicitly.

All three elements of a 3-stranded planning approach (Plan + Briefs + SPG) are needed to provide a policy and SPG framework that takes environmental and sustainability considerations comprehensively and consistently into account (PPG12 para. 4.4.) . Such an approach is needed for Development Control purposes. This is an opportunity to translate stated political will into policy so that DC planners and those writing Planning Briefs, etc. feel supported by fully adopted policy - rather than them potentially seeing Sustainable Construction as a somewhat fashionable policy initiative that may pass in due course.

Undertake more research on best practice in planning for sustainable development is needed, and there is a need to seek and adopt a more consciously innovating approach, both on planning for sustainable development (e.g. incorporation of policies on CHP) and planning for sustainable construction.
Develop with STSD and other partners an appropriate programme of training and professional development on planning for sustainable development and sustainable construction