This response was sent to the Leicester City Council's planning office in response to their call for views on future planning policy.
Dear Officers,
Please find my response to the draft local plan below.
I appreciate this plan is not strictly dedicated to outlining how the city will respond to the climate emergency, however, I am sure officers would agree with the importance of looking at any future planning policies from the lens of climate change. The time frame of this plan (2020 - 2036) is particularly important because it is being set in the context of existing national climate commitments which this plan requires to demonstrate its contribution towards.
I have highlighted some (and certainly not all) of the key commitments here to show where we will be once the time period of the draft plan comes to an end in 2036:
The sale of new petrol and diesel vehicles in the UK will already have been banned 6 years ago (in 2030)
We will be 14 years away from the legally binding commitment of the UK being a net zero country by 2050.
We will be 24 years away from our aspiration of having 12% woodland coverage in England by 2060.
We will be 6 years away from our target to eliminate avoidable plastic waste by 2042 and 14 years away from the target of zero available waste by 2050.
With that context in mind and also considering there is a real possibility that these targets are reviewed and become even more aggressive, please find my response to the draft plan below. I have tried to be specific and target key policy areas in the plan which I believe require more thinking and substance.
Policy CCFR01: Sustainable design and construction for new developments:
Response: I support the intent of the policy, with the requirement for property developers to demonstrate how they will minimise energy demand, reduce waste and reduce carbon emissions. There are also good suggestions for the hierarchy of measures that should be considered. However, this policy is missing any specific targets and mandatory requirements for the developers and there is a lack of clarity on what will be enforced. For example, will developments be stopped if they have not minimised energy demand or have not been designed to allow future opportunities for on-site solar generation? Also, what exactly constitutes as "minimising energy demand"? Is this going to be left to the developers to determine? I believe this policy needs to provide clarity on the standards that developers are expected to follow on sustainable design and what would be the implications if these standards are not met.
Policy CCFR02. Delivering renewable and low carbon energy projects
Response: Although it is encouraging to see the support for new low carbon and renewable projects being explicitly mentioned in the plan, it is unclear how such projects will be actively encouraged. In its current form, this policy only seems to provide criteria for what the council will consider before approving new projects, but with no additional provisions to actively encourage such projects.
I would like the city council to be more ambitious and set out more proactive plans to encourage innovation into renewable and low carbon projects rather than following a passive policy which is doing the bare minimum. For example, could the council allocate greenfield or brownfield land specifically for solar and wind generation or even make council owned buildings available for solar generation? Not only would something like this allow the city to use more power from distributed generation but it could also provide a further source of revenue to the taxpayer.
Policy T01: Sustainable Transport Network & Policy & T03: Accessibility and Development
Response: When it comes to cycling, I appreciate there is already a Cycle City Action Plan in place and this draft city plan does explicitly commit to “develop an infrastructure network of high quality, continuous cycle tracks along main road routes”. I am also glad that the draft plan recognises that cycling links in and around the city remain “unattractive/weak”.
However, we need to see more details and specific policies on how cycling tracks will be extended and made safer in order to attract more people onto their bikes. Once again, I would like to see more ambition from the council to set our city centre up to be on par with other progressive cycling cities like Lancaster, Exeter, Oxford and Cambridge. For example, reallocating road and pedestrian space for cycling and other forms of light mobility within the city centre. The cycle lane on Newark Street is a good example of such safe and dedicated space being allocated to cyclists.
Policy T08: Supporting Low Emissions Vehicles
Response: This is a particularly disappointing policy and I believe a real missed opportunity if not revisited. I am aware that there is currently a climate emergency consultation underway which is perhaps why the ambitions are understated in this policy, but I will highlight key concerns nevertheless.
The plan recognises the emergence of smart transport with driverless cars, shared mobility services and the emergence of smart electric charging. However, this recognition is then met by an underwhelming commitment to only install charging points “in at least 5% of all parking spaces” and states that only 25% of parking spaces will be future proofed to install future charge points through “additional ducting and cabling”. Considering the council currently provides 12,000 public parking spaces in the city centre, 5% represents a 600 charging points by 2036. This is simply not good enough. By 2036 the UK will already have banned the sale of new petrol and diesel cars for 6 years. The government’s own ‘Electric Vehicle and Infrastructure’ briefing paper predicts we will have 36 million electric vehicles on our roads by 2036.
This policy needs to do more to support and encourage the take up of low emission vehicles and the council could even replicate approaches that have worked in other cities. These include:
Committing to electrifying the city councils’ fleet of vehicles and implementing smart charging points at those relevant depots.
ULEV only driving lanes to give priority to clean modes of private transport.
Publishing the number of charging points the council aspires to install in the city. The current commitment of 5% is not transparent enough. For example, Nottingham has committed to installing 400 new charge points in 2019/2020 alone.
I have also highlighted two other areas which range across a few different policy areas which I wanted to call out.
Tree planting.
Response: There are insufficient provisions in this plan to protect our existing stock of trees and there is lack of ambition to plant more.
Policy DQP04: Landscape Design mentioned that new developments should retain landscape features such as trees in new developments but does not mandate it.
Policy HE01: The Historical Environment only provides a mandate to protect trees within conservation areas.
Policy NE04. Ancient woodland and Veteran Trees is the most concerning to me. The policy stipulates that the loss of ancient woodland and trees will only be permitted where benefits to the public outweighs the loss of habitat or where a suitable compensation strategy is in place with the council. This language seems to leave this policy open to interpretation since it does not explicitly protect our ancient woodlands from any damaging scenarios. How does one define a "public benefit that outweighs the harm or loss to the habitat" and what is a "suitable compensation strategy"? Does this mean a new private nursing home would be allowed to be built on an ancient woodland because there is public benefit? Or if a developer is willing to pay enough "compensation" in the form of an allocation of affordable housing in a new luxury house development - would this be permitted? This policy needs to be more explicit.
Overall, the three key policies across the draft plan which mention trees and woodlands only go as far as attempting to protect our current stock. I could not see any provisions being made to expand woodlands or allocating land specifically for tree planting. It is therefore not clear to me how this draft plan contributes to the UK government target of 12% woodland coverage in England by 2060?
Developing on Greenfield land.
Response: The draft plan outlines that greenfield land will be made available for development and in particular for the development of new housing. With a housing shortage in this country, I do understand the need for this. However, the plan should also recognise that building on greenfield sites encourages urban sprawls into our countryside which also increases carbon emissions with people needing to drive into the city from further away. My concern is that there is no mention of any special requirements on developers that are building on this land. Since greenfield space is allocated by the council, this provides a unique opportunity to ensure the highest environmental planning and standards are in place. For example, I would like to see mandatory requirements in place to mitigate the environmental impact through measures such as:
Mandatory installation of electric vehicle charging points.
All developments to meet the highest standards for energy efficiency.
Solar generation on individual properties.
In conclusion, although there are several positive provisions in place in this draft plan and a clear intent to ensure that future development is sustainable, there are several policy areas where the council must go further. There is a lack of ambition and clearly defined safeguards in place to ensure that future development in the city is indeed contributing significantly enough to the reductions of Leicester’s carbon footprint and helping us move towards some of the UK government climate targets that I listed at the beginning of this letter.
Thank you for the opportunity to provide this input into the draft plan.
Hersh Thaker