Draft Sustainability Appraisal Scoping Report

Ended on the 15th January 2010
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(2) 9 Climate change (mitigation and adaptation)

9.1 Introduction

9.1.1 Climate change has become a key issue. Lord Nicholas Stern has suggested that, worldwide, climate change could reduce GDP by 20% unless it is actively tackled now102. According to the 2009 UK Climate Projections103:

  • All areas of the UK will get warmer (with the warming greater in summer than in winter).

  • There is little change in the amount of precipitation (rain, hail, snow etc) that falls annually, but it is likely that more of it will fall in the winter, with drier summers, for much of the UK.

  • Sea levels rise (greater in the south of the UK than the north).

9.1.2 As a result, there will be permanent changes in the natural environment and increasingly, substantial challenges to national prosperity and social cohesion at the local level. The Government’s principal concern for sustainable development has now filtered down to local authorities and climate change mitigation is being encouraged through promoting measures to reduce greenhouse gas emissions.

9.1.3 Government guidance on flood risk emphasises that although flooding cannot be wholly prevented, its impacts can be avoided and reduced through good planning and management. As a consequence of climate change, the Pitt Review into the 2007 floods emphasised that flood risk is here to stay. Flooding from all sources is expected to increase with climate change.

(4) 9.2 What’s the policy context?

9.2.1 The Climate Change Act 2008104 sets targets for green house gas emission reductions through action in the UK and abroad of at least 80% by 2050, and reductions in CO2 emissions of at least 26% by 2020, against a 1990 baseline. The East of England Plan states that to help meet national targets for reducing climate change emissions DPDs should set ambitious proportions of the energy supply that new developments must secure through decentralised and renewable or low-carbon sources. Additionally, until these DPDs are set “new development of more than 10 dwellings or 1000m2 of non-residential floorspace should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless this is not feasible or viable." By 2010, 10% of the region’s energy and by 2020, 17% of the region’s energy should come from renewable sources. Essex has set a county-wide target of 11.8% reduction in CO2 emissions by 2001/12 from the 2005 figure of 6.7 CO2 tonnes per capita. This target is set under National Indicator (NI) 186, which is concerned with a per capita reduction in CO2 emissions within the local authority area and includes emissions from all domestic housing, business and public sectors, and road traffic with the exception of motorways. The County Council is also working to reduce the council’s carbon footprint, as an LAA target, through the Local Authority Carbon Management Programme. The County Council aims to reduce business miles by 10% and in so doing to annually cut carbon emissions by 3%. NI 185 is concerned with the reduction of CO2 emissions from local authority operations105.

9.2.2 PPS1 supplement on Planning and Climate Change106 requires local authorities to mitigate and adapt to climate change through appropriate location and patterns of development, promoting the reduction of the use of the car, conserving and enhancing biodiversity and ensuring that new development is resilient to the effects of climate change. PPS22 on Renewable Energy107 includes a requirement for local authorities to allocate specific sites for renewable energy and to encourage developers to provide on-site renewable energy generation as appropriate. The Code for Sustainable Homes108 sets out the national standard for sustainable design and construction of new homes. From April 2008, achieving Level 3 of the Code became mandatory for new social housing developments. From 2010 all new residential developments will have to meet the equivalent of Level 3 of the Code for Energy Use under the Building Regulations. The Building Regulations for energy use for new residential development will be progressively tightened requiring buildings to be effectively ‘carbon neutral’ from 2016 onwards, which is equivalent to Level 5/6 of the Code. In terms of carbon emissions Level 3 equals a 25% energy/carbon improvement relative to current 2006 standards in the Building Regulations. New housing developments will have to comply with Level 4 by 2013 (44% energy/carbon improvement relative to current 2006 standards in the Building Regulations) and Level 5 by 2016 (zero carbon). Harlow Council has set out a Sustainability Strategy High Level Action Plan109 with targets to accompany its Sustainability Strategy and Action Plan 2009/2010. Harlow’s Plan aims to address the priority indicators of the Government Strategy, including indicator 2 of 4 ‘climate change and energy’110. Harlow Council has also signed the Nottingham Declaration on Climate Change – a commitment to work in a way that counteracts climate change111.

9.2.3 The East of England has a target to produce 14% of its electricity needs from renewable sources by 2010. This target is set at 9% for Essex112.

9.2.4 Planning Policy Statement 25 (PPS25)113 sets out Government policy on development and flood risk. Its aims are to ensure that flood risk is taken into account at all stages in the planning process, to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas of highest risk. Where new development is, exceptionally, necessary in such areas, the policy aims to make it safe, without increasing flood risk elsewhere, and, where possible, reducing flood risk overall. PPS25 requires a Strategic Flood Risk Assessment (SFRA) to be carried out to inform the sustainability appraisal and preparation of the authority’s Local Development Documents (LDDs). Harlow is undertaking a joint SFRA with East Herts and Epping Forest local authorities. The aim of an SFRA is to provide a detailed and robust assessment of the extent and nature of the risk of flooding and its implications for land use planning. In addition, the SFRA sets the criteria with respect to flood risk for the submission of planning applications and for guiding subsequent development control decisions.

9.2.5 The East of England Plan114 includes policies which address both climate change mitigation and adaptation.

9.2.6 In terms of energy, one of the Plan’s objectives is “to reduce the region’s impact on, and exposure to, the effects of climate change by…maximising the energy efficiency of development and promoting the use of renewable and low carbon energy sources." Policy ENG1: Carbon Dioxide Emissions and Energy Performance highlights the roles played by both location and design to optimise carbon performance and Policy ENG2: Renewable Energy Targets supports the development of new facilities for renewable energy power generation.

9.2.7 Policy WAT 4: Flood Risk Management identifies the significant risk of coastal and river flooding in parts of the East of England and emphasises priorities to defend existing properties from flooding and locate new development where there is little or no risk of flooding. In addition, Policy ENV1: Green Infrastructure recognises the contributions of green infrastructure towards flood alleviation, including the Lea Valley Regional Park. Policy ENV3: Biodiversity and Earth Heritage promotes the restoration and re-establishment of habitats and wildlife corridors.

9.2.8 The East of England Regional Flood Risk Appraisal (RFRA)115 was commissioned in line with PPS25, to inform the preparation and sustainability appraisal of the East of England Plan. The RFRA provides policy guidance and technical information to include mapping of flood risk. The RFRA states that:

Climate change is likely to cause a combination of higher peak river flows and higher tide levels increasing the frequency and extent of flooding in the East of England. Approximately 40,000 properties and 86,000 people in the region are expected to be at risk from the future 1% AEP fluvial flood event."

9.2.9 The Thames Catchment Flood Management Plan (CFMP) provides a strategic overview of flood risk management issues for specific river catchments. It is a long-term plan for the next 50-100 years and provides the basis for Flood Risk Management investment plans. Harlow District falls within the Thames CFMP116. Approximately 5,200 properties are at risk of flooding from the 1% AEP fluvial event in the Thames CFMP area that is within the RFRA boundary.

9.2.10 As Harlow is a Key Centre for Development and Change (KCDC) identified to concentrate regional growth as identified in the East of England Plan, information on flood risk within each KCDC was used to outline flood risk and inform policies. Harlow has been assigned to CFMP policy 6; “take action with others to store water or manage run-off in locations that provide overall flood risk reduction or environmental benefits, locally or elsewhere in the catchment"117.

(1) 9.3 What are the key objectives and other decision-making criteria that we need to consider?

9.3.1 Many of the objectives set out in the Integrated Regional Sustainability Framework for the East of England – see Table 2 – are relevant in considering future impacts on Harlow’s town centre. Particularly relevant objectives include:

  • Promote sustainable growth within environmental limits

  • Reduce greenhouse gas emissions

  • Adapt to the impacts of climate change

  • Increase resource efficiency and reduce resource use and waste

  • Move goods and people sustainably

  • Provide decent, affordable and safe homes for all.

9.3.2 Harlow also has a number of key priorities for 2009/10 to 2012/13 as outlined in the Council’s Sustainability Strategy and approved in January 2009 by the Environment and Community Committee118: Relevant priorities include:

  • Promoting a clean, green, healthy and safe environment

  • Developing good citizenship.

(1) 9.4 What’s the situation now? (including any existing problems)

9.4.1 Harlow District does not generate any renewable energy towards the 9% county target and it is considered to be a poor location for wind-generated power. There is no target in Harlow for the incorporation of renewable energy within new developments, nor were there any applications during the period 2007-8, however; the Annual Monitoring Report (2007-8) states that “Local Plan Policy actively supports new developments incorporating renewable energy"119.

9.4.2 Harlow produced 597 kt of carbon dioxide in 2005 and again in 2006. This equates to per capita emissions of 7.65 t. The per capita figure is higher than the county average of 7 t and lower than the regional average of, respectively, 8.11 t and 8.09 t. Particularly noticeable for the District is that most (more than half) of the emissions in Harlow come from industry and commercial sources and much less from road transport120. (See Table 5). In 2005, the highest percentage of total CO2 emissions in the region by far came from Essex with 27% of the total121.

Table 5: CO2 emissions in 2006122

Area Industry and Commercial (kt CO2) 2006 Domestic (kt CO2) 2006 Road Transport (kt CO2) 2006 Total 2005/2006 Per capita emissions (tonnes of CO2) 2006
Harlow District 338 (57%) 178 (30%) 81 (14%) 597 7.65
Essex 3,168 (32%) 3,445 (35%) 3,184 (33%) 9,787 7
East of England 16,902 (37%) 13,912 (31%) 13,966 (31%) 45,372 8.09

Flood Risk

9.4.3 Figure 8 depicts areas of flood risk within Harlow.

Figure 8: Harlow flood risk

Figure 8

9.4.4 There is no SFRA for Harlow District. The district is located within the Thames River Basin District and, more specifically, within the Upper Lee Water Framework Directive Management Catchment area123 and the River Stort catchment area124 . Although information is not available for Harlow alone, the KCDC of Harlow is located across four policy units within the Thames CFMP: Middle Lee & Stort; Upper Roding, Lower Lee tribs and Lower Lee policy units. 89% of the KCDC area is in Flood Zone 1125.

9.4.5 The River Stort places the north of Harlow and, within the ward of Hare Street and Little Parndon, the area between the Pinnacles and Little Parndon / Hare Street (Cannons Brook); in an Environment Agency flood warning area126. (See Figure 9). This area corresponds to an area of Flood Risk Zone 3 (high risk of flooding).

Figure 9: Harlow Flood Warning Area127

Figure 9

9.4.6 The River Stort flows through Sawbridgeworth and along the north of Harlow before flowing into the River Lee at Hoddesdon. Harlow benefits from flood defences which offer a standard of protection of between 10% and 1% annual exceedance probability event (AEP). EERA states that, although the River Stort flood extents are fairly wide, “the majority of Harlow is south of current the floodplain". However: “In the future the area south of the river around Temple Fields will be within Flood Zone 3… A significantly larger proportion of this area [to the west of Harlow at the confluence of the River Stort and River Lee] will be at risk of flooding due to climate change as the flood extents become wider."128

Are there any evidence gaps?

9.4.7 Evidence gaps include:

  • A SFRA is yet to be carried out for Harlow District and for the surrounding Harlow area.

  • There is a lack of data on carbon emissions and both existing and potential renewables (other than wind power) within the District.

9.5 What will be the situation without the plan? (the ‘business-as-usual’ option)

9.5.1 The District already has limited existing renewable energy and needs to assess the potential for different forms of renewable energy. Lower carbon emissions and greater use of sustainable forms of energy could be driven by a Core Strategy, without which this may not take place and the District will continue to not contribute towards the county (and regional) target. Assuming that a renewables study is conducted, planning for the use of renewables within new developments and other forms of renewables (e.g. energy from waste) may be overlooked without the guidance of a plan. It may also be anticipated that CO2 emissions for the District will continue to rise and may not be abated or mitigated to the same extent as under a Core Strategy.

9.5.2 Climate change is anticipated to have a major effect on the extent and frequency of future flooding129. Indeed, the RFRA states that: “Demand for more housing is likely to put increased pressure on surface water and sewer drainage systems. The flooding situation will get worse as sewers reach the limits of their capacity and flood more frequently."130 Areas of Harlow District that are located within Flood Risk Zone 3 will be particularly at risk from flooding and, without the plan, the effects of climate change may be more severe and the District less well prepared through missed adaptation opportunities and unforeseen mitigation opportunities.

(1) 9.6 What issues should be a particular focus for the appraisal?

9.6.1 In light of the information above, key issues to take into account in the appraisal in relation to climate change and flood risk include:

  • The need to lower GHG emissions

  • The need to explore alternative ways to increase the amount of energy generated by decentralised or renewable sources and the use of renewable sources of energy by new development

  • The impact of development on surface water flooding

  • Development within the areas at risk of flooding, adaptation and the mitigation of flood risk, this includes taking into account SFRA findings.


102 Stern, N. (2006) Stern Review on the economics of climate change [online] available at:
www.hm-treasury.gov.uk/independent_reviews/stern_review_economics_climate_change/stern_review_report.cfm (accessed 23 June 2009).

103 Defra (2009) UK Climate Projections [online] available at:
http://ukcp09.defra.gov.uk/ (accessed 16 July 2009).

104 The Climate Change Act 2008 is available at:
www.defra.gov.uk/environment/climatechange/uk/legislation/ (accessed 17 July 2009).

105 EERA (2009) Report to the East of England Regional Assembly: Environment & Resources Panel - National Indicators 185 & 186, and Local Area Agreements [online] available at:
www.eera.gov.uk/GetAsset.aspx?id=fAAyADMAMgAwAHwAfABGAGEAbABzAGUAfAB8ADAAfAA1 (accessed14 August 2009).

106 Communities and Local Government (2007) Planning Policy Statement: Planning and Climate Change [online] available at: www.communities.gov.uk/documents/planningandbuilding/pdf/ppsclimatechange.pdf (accessed 16 June 2009).

107 ODPM (2004) Planning Policy Statement 22: Renewable Energy [online] available at:
www.communities.gov.uk/publications/planningandbuilding/pps22 (accessed 17 June 2009).

108 CLG (2008) The Code for Sustainable Homes: setting the standard in sustainability for new homes [online] available at:
www.communities.gov.uk/documents/planningandbuilding/pdf/codesustainhomesstandard.pdf (accessed 17 June 2009).

109 Harlow Council (2009) Sustainability Strategy High Level Action Plan [online] available at:
www.harlow.gov.uk/about_the_council/council_services/corporate_services/policy_and_performance/sustainability_strategy/achievements_so_far/high_level_action_plan.aspx (accessed14 August 2009).

110 Harlow Council (2009) Sustainability Strategy and Action Plan 2009/2010 [online] available at:
www.harlow.gov.uk/about_the_council/council_services/corporate_services/policy_and_performance/sustainability_strategy/introduction.aspx (accessed 14 August 2009).

111 Harlow Council (2009) Energy Efficiency [online] available at:
www.harlow.gov.uk/about_the_council/council_services/environment/enviromental_health/energy_efficiency.aspx (accessed 14 August 2009).

112 Hams, T. et al (2001) Making Renewable Energy a Reality – Setting a Challenging Target for the Eastern Region: A report to the East of England Sustainable Development Round Table [online] available at:
www.sustainabilityeast.org.uk/pdf/Renewables%20Report.pdf (accessed 14 August 2009).

113 Communities and Local Government (2006) Planning Policy Statement 25: Development and Flood Risk [online] available at:
www.communities.gov.uk/publications/planningandbuilding/pps25floodrisk (accessed 15 July 2009).

114 GOEE (2008) East of England Plan [online] available at:
www.gos.gov.uk/goeast/planning/regional_planning/ (accessed 14 August 2009).

115 Capita Symonds on behalf of EERA (2009) Regional Flood Risk Appraisal [online] available at:
www.eera.gov.uk/publications-and-resources/studies/topic-based-studies/environment-studies/regional-flood-risk-appraisal/ (accessed 14 August 2009).

116 Environment Agency (2008) Thames Region Catchment Flood Management Plan (CFMP) [online] available at:
www.environment-agency.gov.uk/research/planning/33592.aspx  (accessed 14 August 2009).

117 Capita Symonds on behalf of EERA (2009) Regional Flood Risk Appraisal [online] available at:
www.eera.gov.uk/publications-and-resources/studies/topic-based-studies/environment-studies/regional-flood-risk-appraisal/ (accessed 14 August 2009).

118 Harlow Council (2009) Harlow Sustainability Strategy [online] available at:
www.harlow.gov.uk/about_the_council/council_services/corporate_services/policy_and_performance/sustainability_strategy.aspx (accessed 13 August 2009).

119 Harlow Council (2008) Harlow District Council Annual Monitoring Report 2007-08 [online] available at:
www.harlow.gov.uk/pdf/Annual%20Monitoring%20Report%202007-2008.pdf (accessed 14 August 2009).

120 Defra (2008). Local government performance framework [online] available at:
www.defra.gov.uk/environment/statistics/globatmos/download/regionalrpt/local-regionalco2-ni186indicator.xls (accessed 4 August 2009).

121 Environment Agency (2009) State of the Environment - East of England: Climate Change [online] available at:
publications.environment-agency.gov.uk/pdf/GEAN0309BPUC-e-e.pdf (accessed 14 August 2009).

122 Adapted from: Defra (2006) Local Government Indicators (data) [online] available at:
www.defra.gov.uk/environment/statistics/globatmos/galocalghg.htm (accessed 13 August 2009). Note: LULUCF emissions form part of the total but are not recorded within this table.

123 Environment Agency (2008) Thames Region Catchment Flood Management Plan (CFMP) [online] available at:
www.environment-agency.gov.uk/research/planning/33592.aspx  (accessed 14 August 2009).

124 East Herts District Council (2008) Strategic Flood Risk Assessment [online] available at:
http://80.168.51.108/media/pdf/l/i/East_Herts_SFRA_16_10_08FINAL.pdf (accessed 13 August 2009).

125 Capita Symonds on behalf of EERA (2009) Regional Flood Risk Appraisal [online] available at:
www.eera.gov.uk/publications-and-resources/studies/topic-based-studies/environment-studies/regional-flood-risk-appraisal/ (accessed 14 August 2009).

126 Environment Agency (2009) Flood Warnings FWA Detail - The River Stort at Harlow including Roydon [online] available at:
www.environment-agency.gov.uk/homeandleisure/floods/34681.aspx?area=062FWF51Harlow (accessed 14 August 2009).

127 Source: Crown copyright. All rights reserved. Environment Agency, 100026380, 2008

128 Capita Symonds on behalf of EERA (2009) Regional Flood Risk Appraisal [online] available at:
www.eera.gov.uk/publications-and-resources/studies/topic-based-studies/environment-studies/regional-flood-risk-appraisal/ (accessed 14 August 2009).

129 Environment Agency (2008) Thames Region Catchment Flood Management Plan (CFMP) [online] available at:
www.environment-agency.gov.uk/research/planning/33592.aspx  (accessed 14 August 2009).

130 Capita Symonds on behalf of EERA (2009) Regional Flood Risk Appraisal [online] available at:
www.eera.gov.uk/publications-and-resources/studies/topic-based-studies/environment-studies/regional-flood-risk-appraisal/ (accessed 14 August 2009).

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