Response by South Gloucestershire Friends of the Earth to the draft South West Regional environment strategy document Our Environment: Our Future.

We appreciate the opportunity to respond to the draft South West Regional environment strategy document Our Environment: Our Future. General approach of the strategy

We broadly agree with and support the aims and the key environmental issues, with the reservations listed below. However we would have some general comments about the approach of the draft strategy:-

• The environment strategy would benefit from full integration with the economic, planning and transport strategies. The region has aspirations to be sustainable, and the key to sustainability is to develop single coherent economic, social and environmental strategy rather than to try to bolt on an environment strategy. For example, the regional economic and transport strategies are, to some extent, contributing to the environmental problems. The economic strategy promoted development at all costs and in the wrong places in order to be 'competitive'. The SWARMMS study promoted road improvements that will increase traffic.

• The focus of the strategy should be on the areas where there are serious environmental problems rather than on the rural areas and on conserving pretty places. While the pretty places are important, and the region is predominately rural, the environment of the urban poor has become a major and neglected problem. We see the main environmental problems of the region as:
  • the run-down urban areas,
  • the recent sprawl of housing and industrial estates,
  • the traffic, especially round the Bristol conurbation.

We suggest below some changes to the objectives on page 5. On page 8 paragraph 2, we disagree with the implication that environmental pressure from development is inevitable. A determined effort by the region's planning authorities could bring about good quality, land-efficient development focussed on the run-down, resource-poor areas where redevelopment is desirable.

On page 8 paragraph 3, we agree that transport is a major challenge, but the challenge is to halt the destructive and economically damaging growth of road and air traffic. There is no evidence that economic prosperity depends of transport, while studies have shown that the growth of road traffic has led to a steady decline in quality of life over the last thirty years.

We would add the following:

• Pressure to allow low-density car-based developments on green-field sites.
• Opportunity to divert development resources into environment-friendly, car-free redevelopment in the run-down inner urban areas.
• Pressure to encourage car and lorry miles by building and 'improving' roads.
• Opportunity to provide facilities and services for compact communities within walking distance to reduce the need for driving.
• Opportunity to switch from a 'competitive' transport-based economy to a local economy that celebrates local products for local people.

We strongly support the first two objectives. The meaning of the third objective is not clear to us. The two environmental issues for food, farming and forestry are

• promoting localness rather than centralised distribution to reduce food miles
• promoting organic and wildlife-friendly methods to reduce the destruction of wildlife and habitats.

In the fifth objective, the key to environment-friendly development is to direct development resources into compact, car-free redevelopment of run-down areas. Large scale low-density car-based green field development is of benefit only to the profits of developers, producing a traffic crisis as well as destroying large areas of the countryside. In the last objective, we need to reverse the damaging growth of traffic throughout the region. The increase in traffic is damaging the economy and destroying the quality of life in the region.

On page 21 we strongly agree that all regional strategies should consider their impact on the environment. For this reason this strategy should look beyond accepting current economic, planning and transport strategies and set down how such strategies could improve their environmental effects. We also urge that the region puts pressure on government where government policies are seen as damaging to the region's environment.

This section could cross-refer to transport and development, which are major users of fossil fuels and therefore causes of climate change. In particular, the very rapid growth in air traffic could mean that this sector will in a few years outstrip all other sectors as generator of climate change.

This section could also cross-refer to transport and development, which are major users of natural resources.

The two environmental issues for food, farming and forestry are

• promoting localness rather than centralised distribution to reduce food miles
• promoting organic and wildlife-friendly methods to reduce the destruction of wildlife and habitats.

At the moment much of the food grown in the region is transported hundreds of miles to central processing and distribution sites. This generates a significant proportion of the region's lorry traffic. A change in focus to grow the crops needed for local markets, process locally and sell to local people would create jobs and make the local economy more robust and self-sustaining as well as reducing the environmental damage. Organic methods create jobs and reduce the need to import expensive agricultural chemicals. A policy to promote organics would therefore also benefit the economy.

Tourism is a mixed blessing for the region's economy and environment. It causes heavy traffic flows at peak times, and places highly seasonal pressure on local services such as water supply. Tourism is highly fickle and seasonal, so is not reliable enough to be the mainstay of the local economy. The west of the region has become over-reliant on tourism. The region should be wary of encouraging tourism at the expense of reforming the economy to promote local goods and services for local people, plus the potential job-creating industries of renewable energy, recycling and organic foods.

The main environmental problems caused by poor development are:

• The generation of traffic;
• The destruction of open space;
• The consumption of natural resources and energy;
• Waste disposal.

More emphasis needs to be given to these issues. All of these can be reduced substantially by better planning and building practices. Nevertheless, it makes no sense to encourage development to come to the South West from the South East while there are other regions in the UK desperate for jobs and development resources. In many cases, those other regions have housing and brownfield sites in abundance, yet they are being depopulated as jobs concentrate in the south.

Development resources need to be focused on those areas where there is decay and unemployment, such as in the west of the region and in the inner urban areas. However the bulk of development is occurring on green field sites in the east of the region, causing overheating which is generating a traffic crisis.

Low density developments are impossible to service by public transport and will not support local shops and other services. The inhabitants are therefore forced to use cars and drive farther to access shops and services. Compact car-free developments, like older city areas, support local shops and services and discourage car use. Planners need to be more determined that such developments will become the norm.

We disagree with the implication in the fifth paragraph of section 3.6 that focussing growth in urban areas means building on urban green spaces. While that is the easy option for developers, it can be easily resisted because most urban areas include a high proportion of under-used land such as derelict land, former industrial sites, low density developments and car parks.

The construction industry is a major consumer of energy and other natural resources and a major generator of waste. The energy needed to construct a brick and concrete house is comparable to the energy consumed during its use. Better design should include more environment-friendly construction methods, such as timber frames and the use of recycled materials. The sustainable construction charter Future Foundations has not been promoted sufficiently.

Traffic is a major environmental issue for the region, and needs to be addressed at all levels. It generates pollution and noise and consumes precious natural resources. Travel times are increasing, which is a growing cost to the economy. Busy roads cause stress and are barriers to the movement of pedestrians, with the consequent loss of quality of life.

The current economic strategy encourages traffic growth by pursuing a strategy of improving competitiveness and encouraging tourism rather than promoting local products for local markets. The second strategic road route to the South West from London recommended by SWARMMS would increase traffic in the South West and discourage local produce. Current planning policies permit development that is much too low density and includes too much car parking and road provision. If these policies were reversed then there would be much less pressure for traffic to increase.

Air transport is highly damaging to the environment. The pollution of the upper atmosphere with greenhouse gases and water vapour is increasing at an alarming rate. Encouraging regional airports will simply encourage air travel by making it more convenient and accessible. Regional airports will not significantly reduce the traffic on the ground, and the pollution from increased air miles will greatly exceed any pollution saved from surface traffic. The regional air strategy should therefore be to restrain airport growth.

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