Tuesday, 3 February 2015

Surely the NPPF must have something to say on unsustainable proposals like AI's?

It's a claim Aggregate Industries keeps wheeling out. Perhaps if it says it enough it might act like it too...

And not push million-mile HGV proposals onto local communities and European-protected sites. It's one thing ruining a perfectly viable farm and risking water supplies for 100 people, but it’s another thing continuing to blight the East Devon Pebblebed Heaths.

It is staggering that AI is still kicking around this ridiculous, unsustainable and polluting plan - to transport Straitgate material all the way to Woodbury Common for processing - when it owns an alternative site just 1/4 of the distance away at Rockbeare; an industrial site already sitting empty; a site that would save more than 750,000 HGV miles on Devon roads over 5 years; a site 0.5 miles from the strategic road network, for sales distribution, not 6 miles as at Blackhill; a site that’s apparently good enough for AI's improbable 'Stage 2' plans for Straitgate, and that therefore must be good enough for 'Stage 1' too.

How many other sand and gravel operations can there be in the UK, where 8 miles separate quarry and processing plant? We haven’t come across one yet. The reason being that transport costs normally limit the economic supply radius of low margin aggregate to 30 miles or so; AI's plans reduce that by 16 miles.

If AI can't do the right thing, what does the NPPF say on the subject - could anyone pretend that digging out Straitgate and transporting the spoil 1,000,000 miles for processing is sustainable development? Yes, if they could demonstrate that the economic benefits outweigh the social and environmental harm - but the issues page clearly shows that won't be easy. But what exactly is sustainable development? We have written about this before, but it comes back to what’s written on page 2 of the NPPF:
Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs. The UK Sustainable Development Strategy Securing the Future set out five ‘guiding principles’ of sustainable development: living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly.
The NPPF states that "to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system" [8], but of course the NPPF is open to interpretation, particularly because "the policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development in England means in practice", which is why many argue that it has done nothing to protect us from unsustainable development. But election time is coming, and different noises are coming out of the Government:
the Government are committed to doing far more to publicise those recent cases widely, to provide reassurance that unsustainable development should be resisted
that the Government remove from the NPPF the statement that the policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development means in practice. The definition on page 2 of the NPPF needs to stand on its own. [13]
In the meantime, let's highlight two very salient parts of the NPPF that are relevant here:

Firstly, on the issue of Meeting the challenge of climate change, flooding and coastal change, the NPPF says: "Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions... This is central to the economic, social and environmental dimensions of sustainable development [93]. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change... in line with the objectives and provisions of the Climate Change Act 2008" [94].

In other words, planning must be in accordance with the Climate Change Act, whereby "it is the duty of the Secretary of State to ensure that the net UK carbon account for the year 2050 is at least 80% lower than the 1990 baseline", and that’s not going to happen by allowing proposals like AI’s.

The Committee on Climate Change was tasked by the Government to provide advice on How local authorities can reduce emissions and manage climate risk. One of the key messages is: "It is particularly important that local authorities use their plan making and development management control functions to... reduce transport emissions...".

Secondly, on the issue of Promoting sustainable transport, the NPPF says: "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion [30]. Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised..." [34]. The NPPF has more on this, but the Campaign for Better Transport has scrutinised the document far better than we ever could, and produced the very relevant Sustainable transport and the NPPF - a guide for local councils and communities.

Looking beyond the NPPF, there’s also the moral issue in all this, because continued processing on Woodbury Common is so demonstrably wrong, on so many fronts. If AI can’t be trusted to do the right thing now - to minimise the impact on local people, the East Devon Pebblebed Heaths, or the planet - how could it be trusted to do the right things if it were to actually win permission for Straitgate?