West Berkshire Council (WBC) have launched the consultation on its draft Environment Strategy (DES).
Local residents are invited to have their say on the DES by Friday 21 February.
This is a very complex topic in which science, politics, technology, altruism and self-interest collide like never before. The draft West Berkshire has produced is not perfect or final – no consultation document is – but we must stress that fact that it has happened at all is a good thing. Many of the longer-serving councillors and officers would never have imagined that they would be involved in formulating such a policy so it’s a learning process for everybody. Some more recent councillors were, of course, elected with exactly that end in view and this has certainly helped to push the matter to the top of the agenda. The consultation process is a vital one and all residents are urged to make their views known.
We’ve read through it, as have some scientist friends of ours from outside the area. We’ve also thought back to the Climate Conference we attended in October (click here for a report on this) and heard some opinions from others from within West Berkshire. What follows is a result of these reflections and suggestions. You may not agree with the points we’ve made but the intention is merely to suggest some things to bear in mind when responding to the consultation.
If you have any comments on this, please contact Brian on firstname.lastname@example.org or post a comment (see panel below) so this post can evolve over the coming weeks.
The political dimension
We’d better get this out of the way first. I have said before that I think that the matter being decided by the Environmental Board (composed of members of the ruling party and officers) is wrong, as is the fact that the deliberations of the cross-party Advisory Group are not allowed to be published. I’m aware that WBC’s constitution demands the former (I’m less sure about the latter) but constitutions can be changed. This has immediately created a political dimension to a debate that doesn’t need it.
Partly as a result, the two opposition parties on the council also have their own views on the consultation. The response from the Lib Dems can be seen here: the Green Party is finalising its response in the next few days and a link will be added when we have it.
Planning and buildings
As about 17% of greenhouse gasses in the UK are produced by buildings, it seems strange to me that WBC did not see fit to include a dedicated section to this in its strategy. The references to ‘homes’ and ‘buildings’ are pretty scarce in this document and are generally to be found in lists of aspirations rather than in concrete proposals. This is one area where the council not only has the powers, through the Merton Rule, to demand higher standards (which, as the Western Area Planning Committee meeting on 27 November 2019 proved) it has not adopted or enforced as fully as it might: also, that the technology now exists for all new-build homes to be carbon-neutral, something that cannot be said for industry, transport or cows.
On page 15, reference is made to using the planning system to ensure all commercial developments meet a minimum environmental standard. I don’t understand why this was not extended to new domestic dwellings, of which are huge number are planned to be built over then next decade or so.
Comparison with other consultations
One could pick several: but I’ve been sent the one from Cambridge City Council, an area vastly smaller in area but with only a slightly smaller population. Obviously Cambridge is not a normal city, and its council may also have access to a higher quality of scientific advice. This looks like a final policy (CCC declared its climate emergency in February 2019, WBC in July). It’s about the same length as WBC’s but seems to have fewer aspirational statements and more hard policies. This is, perhaps, a standard by which we might judge WBC’s final document. You response to the consultation will be influential in accomplishing this.
Terminology, statistics and sources
One comment I’ve received is: ‘It isn’t very well structured and it should include a glossary of terms to make things clear for the public/lay reader, but it does make sense. I think the weakest side is that they don’t make the reasons for presenting the evidence they use clear (ie, what does this data mean?): they do, however, provide sources, albeit mainly secondary ones.’ This isn’t always the case: the link between climate change and flooding lacks any reference, for example. Terms such as ‘carbon neutrality’ and ‘1.5 degrees’ are used slightly too freely and assume that everyone reading accepts and understands the these in the same way.
There also seem to be places where data from other sources has been cut and pasted in with only a passing reference to West Berkshire. One example is on p10 where the text, the table and its notes make no obvious sense in combination: does this all mean that West Berkshire is able to control about 30% or about 70% of its carbon emissions? Lower down the table, Bracknell appears to be able to control either all or none of its own, neither of which seems possible. Whatever the figures mean, WBC is at the top or the bottom of the ranking: yet there is no reference to this position in the text, which leaves one wondering what the point of the chart was and what inferences should be drawn from it.
This confusion spreads into other graphics, such as the horrible chart 2. Aside from being almost unreadable, I’m again confused as what point it’s making. The headline figures don’t accord with anything on chart 1 on the following page so – even if I were sure what this meant – I remain unsure how the two relate to each other.
The people compiling this had the document dominating their minds for some weeks. This can lead to assumptions the the logic flows, that the explanations provided for the information are clear and mutually consistent and that nothing requires prior knowledge on the part of the reader. Was the document reviewed by people, perhaps outside the council, who had no involvement in its creation? There are enough slightly jerky changes of stylistic gear and intrusion of data which overwhelms rather than informs to suggest that it wasn’t.
Discussion of the issues
Picking up on this last theme, the document tends to waver between extracts from third-party sources with little local context (see section above) and rather vague aspirational statements. I appreciate that this has been produced at short notice and that it is at draft stage but the document is weak on why some measures or policies have been preferred over others and how outcomes are going to be measured. (See Cambridge’s one, referenced above, for an example of how this might be done.)
I’m also unsure that some of the matters covered properly belong in this document at all. Sections 5.3 (Healthy Communities) and 6.1.4 (Waste and Resource Efficiency) are both laudable aims but don’t seems to be directly relevant to the matter in hand and don’t seem to merit 10% of the document being devoted to them.
There are a number of welcome initiatives, one of which concerns tree planting, a simple and effective way to capture carbon. One purpose of the consultation is to ensure how much prominence each of these receives so this is your chance to influence this.
For a council to take such a measure is commendable and is in part the result of the Brexit-inspired lack of leadership on this matter from Whitehall. As the document makes clear on several occasions, this is not a goal it can accomplish on its own (though there are, I suggest, a number of things it can do and are already within its competence, such as deciding how it spends the rest of its investment portfolio, how it allocates grants for environmental initiatives and how it makes its planning standards as effective as possible). There is talk about needing to take the population with it but, as mentioned above, it’s not clear to me if it’s even at present got there full council behind it. Given this admission of relative weakness one would therefore expect to see plenty of robust references to working with other councils and lobbying government.
I can’t see very many. Given that the targets are national and the problem global, this should perhaps feature more strongly. This would include matters such as the Future Homes Standard, the expansion of the national grid to cope with extra electricity demands and the need to recognise the role played by other pollutants aside from CO2 (though concentrating on that isn’t unreasonable). The more widespread use of electric cars, for instance, is stated as an objective, but this is to ignore other polluting or climate-changing results resulting from their manufacture or disposal which this report doesn’t concern itself with. Different goals – for example, home-insulation grants and the provision of EV charging points – need to be weighed against each other so that it’s possible to judge the respective benefits. This isn’t simple: but in declaring a climate emergency, any council needs to think globally an act locally to an extent that this document doesn’t yet quite accomplish. The scale and nature of the problem is certainly unprecedented and its solution involves numerous considerations.
It is a draft, however, and one open to consultation. WBC has taken this step, as a result of both external and internal pressures, has hosted a conference and produced a consultation document. It isn’t perfect, but neither are any of the solutions that it proposes, even if it had the power to introduce them overnight. That’s where we all come in: to add our own knowledge and opinions (and perhaps to lobby that these be more formally represented) and to influence WBC’s decision-making in the way that the document in so many places admits that it requires help, support and engagement.
Currently, my suggestions are that WBC should:
- Ensure that the inclusivity of debate (which the draft several times states as an aspiration) starts with its own internal processes and builds from there.
- Clarify some of the conclusions which it has reached, including explaining more clearly the connection between some the statements made or statistics quoted and the aim of addressing the climate emergency.
- Demonstrate ways by which it is working with specified experts and other councils and how it proposes to lobby national and perhaps international bodies to help accomplish the ambitious and laudable targets it has set itself.
- Arrange for future documents on the subject to be reviewed before publication to ensure a greater level of stylistic consistency and explanation of key issues than is the case here.
- Provide clear actions and outcomes: some may be aspirational or unquantifiable but the majority should be empirically measurable against standards set by other councils or industry experts.
If you agree, disagree or have any other points to add, please do so by commenting below.