DENBIGHSHIRE UNITARY DEVELOPMENT PLAN EXPLANATION OF EVIDENCE - DENBIGHSHIRE TO 10,001 Flintshire Green Party Integration of All Aspects of Sustainable Development Psalm 104:10-18: Three thousand years ago, King David, as he looked around the land, noting that wildlife, food growing and the meeting of other human needs, were integrated into a single harmonious system designed and upheld by God. This psalm illustrates the three main points of the concerning land in Denbighshire: # The land is needed for farming and food production. # The land is important for wildlife. # The land is important to provide human quality of life. Together with human morale, historical heritage and economics, these are essential ingredients of sustainable development. True wealth creation is not possible without such integration of all aspects (see evidence from PPG 7 - 'The countryside - environmental quality and economic and social development'). PPG 7 (1.4) emphasises the need to "maintain or enhance the character of the countryside and conserver its natural resources, including safeguarding the distinctiveness of its landscapes, its beauty, the diversity of its wildlife." Likewise the submitted article on EC Communication on Industrial Competitiveness concludes that "a qualitative improvement in the degree of integration of environment and industrial policies in order to derive positive benefits for both policies" and "constructive dialogue with industry to improve the effectiveness of environmental policy." The proposed Plan would break both of these by promoting industry at the expense of environment, and ultimately to the detriment even of industrial competitiveness. Yet again, the UNED-UK Annual Conference on Sustainable Human Development, submitted as evidence, emphasises the need for integration of diverse aspects. A sound theoretical foundation for interdisciplinary approaches to sustainability in planning is outlined in the paper 'Towards a Multi-Modal Framework for understanding sustainability in planning and tbe built environment' by Basden and Lombardi submitted as evidence; this provides a mechanism for taking into account the economics with the biological, the social with the psychological, the juridical with the physical, the quantitative with the ethical, the aesthetic with the spiritual elements that together compose true sustainability. Sustainable Development and Biodiversity There is much confusion about the meaning of sustainable development and of biodiversity, and the link between them. Evidence has been included that should dispel some of this confusion. According to 'Sustainable Wales' evidence: "Sustainable development is about striking a better, more creative balance between economic development, environmental protection and social change, about finding ways of meeting our needs without jeopardising the ability of our children to meet theirs." It continues: "Development that is more balanced should be more enduring, and offer a better change of long-term prosperity." Evidence from Prof. Dr. Klaus Topfer points out that limits expand ... "as we find ways to ensure economic growth without strain for natural resources and eco-systems." Evidence 'Caring for the Earth - A strategy for sustainable living' from the IUCN, UNEP and WWF, points out that development must be "conservation-based", and in particular should be designed such that it: # conserves life-support systems # conserves biodiversity # ensures that the use of renewable resources is sustainable. That this should occur not only at the global level but also the local level is emphasised by LA21 Vision (Local Agenda 21). In the evidence presented there is a list of factors that are involved in this, which includes "local work in a strong local economy" and "reducing our impact upon the environment" and "using green space effectively for humans and wildlife", amongst others. The Shell Better Britain Campaign has recently (April and July 2000) provided useful background discussions of both Sustainable Development and Biodiversity; these have been included in the evidence. Another recent definition of 'biodiversity' is provided in the submitted evidence: an article 'Biodiversity - What is it?' by the City and County of Cardiff. A fuller discussion of what sustainable development is and its links with biodiversity is contained in the paper 'Biodiversity and Sustainable Development - A Perspective' by Cllr. K. Armstrong-Braun (1996) submitted as evidence. The Green Party Industrial Policy paper submitted as evidence contains arguments and evidence that the traditional approach to industry and industrial investment is counter- productive even in economic terms and cannot help but cause environmental damage, even when it attempts to ameliorate this by so-called mitigation. Environmental Law The UNEP's New Way Forward stresses the importance of more closely linking environmental law with trade law and human rights law. National and international Law is moving ever towards such integration. Proposed development in Denbighshire would sever such links; this means that if the proposal were to be allowed, there is every possibility that it would soon become illegal, with the necessity of huge expenditure to remedy the situation. The Green Party MEP, Dr. Caroline Lucas (evidence 'The Greens in the European Parliament') concerns the possibility that "millions of pounds of EU aid could be delayed unless the UK speedily complies with nature conservation directives." Land for Food Production This integration is vital for land in Denbighshire. Farming and farmland has not changed in its importance since those times, in spite of attempts in the late twentieth century to believe otherwise. As we enter the 21st century, the European Commission is turning away from all forms of intensive farming, and has withdrawn subsidies for it and providing them for less intensive and organic farming methods. (Evidence: Paper by Maureen Usher.) Evidence newly acquired: We have only recently been made aware of the announcement by Iceland plc that it intends to convert all its products to organic, and that it has signed up 25% of the world's organic production in order to achieve this. The vast majority of this comes from outside the U.K. U.K. farmers and communities are missing a huge economic and jobs opportunity in this. Organic farming is more labour intensive and would be an excellent provider of jobs in Wales. But organic farming is more extensive in terms of land, and so every acre of high grade agricultural land is important for the future - for the growth and maturing in the future of a sustainable and robust organic sector in Denbighshire. This means that farming will require all the high grade land that is available (grades I, II, III). These grades of land are becoming scarce in Wales, like the birds that live on them. Therefore they should be protected from any form of development that would diminish their use for food growing and wildlife. PPG 7 emphasises "protecting the best agricultural land" and the importance of maintaining "food production and a competitive agricultural industry" (1.7). Farming methods of lower intensiveness are labour intensive and will generate more jobs. Relative to jobs offered by modern industrial and commercial enterprises, these jobs: # will use local skills # will help the local economy # are more permanent # are more health-giving, in that they involve human exercise as a fundamental component. The paper UNED-UK Annual Conference on Sustainable Human Development estimates that if even ten per cent of UK food production was converted to organic methods, this would result in up to 18,000 extra jobs within 10 to 15 years. Land for Wildlife The Communication of the European Commission on Biodiversity Strategy points out that all parties should "integrate as far as possible and as appropriate the conservation and sustainable use of biological diversity into relevant sectoral or cross-sectoral plans, programmes and policies." This includes decisions at the local level such as here at in Denbighshire County. Much proposed land allocation for development flies in the face of such requirements. The proposed Plan would cause the decline of UK priority species of birds that are subject to European protection. The proposed Plan includes, in policy ENV 5, an allowing of 'mitigating measure'. These are frequently thought to involve re-landscaping and re-planting. While this might seem admirable, it is in fact counter-productive, because it would displace the rare and uncommon species and replace them with common species, because of the change of habitat. It takes decades, or even longer, for a habitat to mature to the point where it sustains viable populations of the less common species. Land for Quality of Life 'Naturopa' Spring 1991 emphasises the value of nature. It points out that "most people get most enjoyment from everyday birds, not rare ones, but the dashing lapwings, the skylarks, the brightly coloured yellowhammers, and linnets. A countryside without them is like food without seasoning. Many of them live in our gardens, but have roots in the woods and on farmland. Changes in the countryside affect the numbers of birds we watch from our armchairs." The populations of all the birds mentioned above, and more, would be severely depleted in Denbighshire if the Unitary Plan were to be passed in its present form, with the resultant loss of quality of life of many of its residents. Quality of life is one of the major criteria of the Government planning policy. A major issue is to place a 'value' upon wildlife that can be used in comparisons with more traditional economic indicators. There is a number of ways of doing this, one of which is contained in the evidence headed 'On the Meaning of Economics', esp. on its page 3 of 9. Inward Investment and Jobs (Summary of argument: 1. The global market for environmental products and services is huge. 2. Such jobs are best provided by small rather than large firms, and in the local community. 3. Therefore inward investment should not be given the priority it has been in the strategy, and the startup and expansion of locally owned firms should be given priority.) It has come to our attention since the evidence was submitted that, on 24th October 2000, the Prime Minister addressed the CBI/Green Alliance Conference on the Environment. The new evidence submitted is the text of his speech, entitled 'Richer and Greener'. The main thrust of this is that a sound environment and a sound economy go hand in hand, and cannot be divorced from each other, as had been assumed in the past. He cites a number of principles, of which the one that is relevant to this section is: "We should see protecting the environment as a business opportunity. There is a growing market for environmental goods and services - currently worth an amazing US$ 335 billion - as large as the world market for pharmaceuticals or aerospace. We should exploit them and develop them where they are. Otherwise history shows us the environment risks being the loser." Denbighshire could become a leader in this market. But to become so requires a shift of emphasis because a large proportion of environmentally friendly jobs are labour rather than capital intensive and better provided by local and small firms than by attracting inward investment. In section 10.3.2 the proposed Plan puts attracting inward investment as the highest priority, whereas expansion of local firms comes second and encouraging the startup of local firms is not in the list at all. Inward investment should not have this priority, because it carries many penalties and generates severe problems, often of a longer term and indirect nature, resulting in the local economy and community being handicapped in the long term. Fifteen of these problems are outlined in the paper entitled 'Investment Industry in Wales' by the House of Commons Welsh Affairs Committee Inquiry into Investment in Industry in Wales Report (1997-8) which went to the House of Commons for debate. The route to permanent jobs that suit the local community is by expanding locally managed and owned SMEs (see Forward Wales 2000 KPMG report) and also organic and low intensity farming, as discussed above, rather than by inward investment. Denbighshire should be developing and training its own qualified engineers (see recent Comment from 'Engineering Technology', Institution of Incorporated Engineers) rather than merely providing an easy entry for engineers from outside. A recent Press Release by Green/EFA (unfortunately omitted) underlines the problem that is increasing in Wales, of jobs being occupied by highly skilled incomers and effectively excluded to local people. This is also highlighted in the Meridien Report on the Deesside Development Zone, 20th June 2000, in neighbouring Flintshire, and also in the PURE Report, 18th February 2000. One root of this problem is a misunderstanding of what Economics is. The true meaning of economics, especially as linked to Quality of Life, is discussed in the paper 'Economics for a Sustainable Future' submitted as evidence, and also in the Paper 'The Real Meaning of Economics' by Dr. A. Basden. The submitted article by Rathbones entitled 'The Ethical View - Urban Regeneration' emphasises the need to integrate ethical thinking with economic. Therefore the whole strategy of job provision should be reconsidered. First, the top two portions of the strategy in 10.3.2 should be # encouraging startup of locally owned and managed firms # expansion of locally owned and managed firms. and inward investment should come much further down the list. The small, local firms have greater loyalty to the area, and greater sensitivity to local needs, both social and environmental and community needs. Reinstate Small Employment Sites. (Summary of argument: 1. Because local firms should be given priority land allocation should be such as to be attractive local firms and relatively unattractive to incoming firms. 2. Therefore the smaller sites should be reinstated into the plan.) In section 10.5, under the heading 'Employment Land Strategy - 1. Amount of Employment Land', it is stated that some smaller sites have been deleted because they "are small, disjointed, unattractive or are unlikely to be taken up, e.g. Y Morfa (Prestatyn) Marsh Road (Rhyl) and Station Road (Rhuddloan)." While these sites might be 'unattractive' to inward investors, they are not so for local firms. This means that the provision of such smaller sites would be effective in restoring the balance towards encouraging local firms rather than incomers. This would meet the Government's criteria of regeneration of the urban built environment and meets the aims of sustainable development. We ask, therefore, that these smaller sites be resinstated in the Plan. These will make up towards the loss of land allocated at Rhyl and Prestatyn that we have asked to be deleted. (These two large areas at Rhyl and Prestatyn are of immense wildlife importance and have been proposed to the Welsh Assembly as Special Areas of Conservation, which, if granted, would mean exclusion from development.) (Note that, now that it is being proposed that the site be split into smaller units, then any companies of this size that wish to come into the area could easily be accommodated in brown-field sites in the travel-to-work areas of Cheshire and North Wales.) Housing The evidence by TCPA on 'PPG3 (Housing) - Putting empty property first' shows a useful method of avoiding the use of greenfield sites and thus reducing the need to allocate land for housing. It makes the use of empty property the core of the sustainability agenda and "explains how filling empty properties can meet planning policy objectives and how PPG3, along with other corporate issues, can be implemented. Its advice comes from the experience of almost 200 council officers from around the country who have been involved with implementing Empty Property Strategies. Their experience unfortunately suggests that planners have rarely been involved, developers are largely uninterested, and there is much more than can be done." We include this because the reuse of empty properties and the development of Empty Property Strategies is not only an urban issue but is highly relevant to Denbighshire. It points out that such strategies have an important part to play in housing provision, revitalising our high streets, supporting local transport networks and creating areas where people want to live (in Green Party terminology 'living towns'). Denbighshire should fund and recruit an Empty Homes Officer to meet the above strategy. The Hastings Borough Council Agenda Item 'Directors Group 16th August 1999' provides relevant evidence of this requirement. High density housing can be very attractive. We have argued that Denbighshire can have higher dwelling density in existing urban areas and even if necessary in newly allocated land, that meets people's aspirations for living space, in a more sustainable manner. The article by the Peabody Trust is submitted as evidence. It describes the BedZED project in London, which "when built will be the most coherent of sustainable development in the country and will foster a local identity and community pride" (Sutton Council Leader, Mike Cooper). Another such project is underway in Birmingham. Such developments are not only efficient in space but also meet people's community expectations, and follow ecological principles in a way that we believe would be highly attractive to people of North Wales, given their historic propensity for strong community living, identify and responsibility. It can moreover provide high quality accommodation for people on low incomes. Tourism The Plan's tourism strategy and policies are disastrous. They say nothing about the local community. It is now widely accepted among discerning policy makers that tourism brings huge problems to the local community and economy. It is time for North Wales, and Denbighshire in particular, to recognise this and cease to see tourism as an easy source of income, forgetting the huge intangible and externalised costs that must be met by the local communities. The submitted paper 'Tourism Workshop' by Richard Tapper to the UNED-UK 1997 Conference outlines some of these problems. While some are specific to developing countries, many apply to North Wales, especially in the light of Wales having become a low-wage economy. However, Tapper does not suggest banning all tourism. Wise tourism policy can bring real benefits, but a change in direction is needed in Denbighshire to achieve this. Tapper suggests some measures that could be taken. But the Green Party Tourism Policy document, included as evidence, works out many of the principles in actual policy, and these could be used as templates for a revision the Tourism section of the Plan. The organization, Tourism Concern, has played an important part in the formulation of these policies. Redesigning the Unitary Plan according to Principles of Sustainability We ask for a complete redesign of the Unitary Plan according to the principles of sustainability. Is this completely unrealistic and unreasonable of us? No! The London Borough of Sutton has accepted the challenge of doing just this, and has based their whole plan on the LA21 Vision and principles. They have found ways of incorporating the nine goals of LA21 even within the constraints of current national planning guidance. Therefore we are bold to ask that Denbighshire Unitary Authority should do likewise. Even if it is not thought feasible to rewrite the whole Plan, a start should be made right now, and the next Plan should be designed around principles of sustainability. Cllr. K. Armstrong-Braun, Flintshire Green Party, 27 November 2000.