LOBBYING: Response to the New Southwark Plan Main Modifications consultation

The New Southwark Plan (NSP) contains a new borough-wide planning and regeneration strategy for Southwark up to at least 2036. Not only will it set out planning policies to guide development, but it will also explain how development will be delivered and may inform future decisions about investment in infrastructure. It therefore has incredibe significance for Southwark’s climate change adaptation and mitigation during a crucial decade for the climate crisis. Once finalised and adopted, it will replace the current local plan from 2011. 

The council submitted the NSP to the Secretary of State in January 2020, which kicked off the ‘Examination in Public’ process – the last stage of the plan’s finalisation. XRS participated in the public hearings which took place in February 2021, explaining how the original plan barely acknowledged the climate emergency, let alone responded to it in a meaningful way. The next step (we know, it’s convoluted): the national inspectors recommended ‘main modifications’  (changes that materially affect the policies) to make the submitted plan sound and legally compliant, and then invited commentary on those main modifications.

XRS’s overarching response to the Main Modifications on the New Southwark Plan can be found here, and our detailed commentary here. It should be read in conjunction with our January 2020 consultation response and our statements ahead of the examination hearings for Matters 1, 2, 5 and 7. The key aspects of our overarching response are as follows…

Legal Compliance

At the outset, we emphasise that the comments in our initial consultation response to the January 2021 consultation still stand in that the New Southwark plan does not meet the legal requirements for decarbonisation.

However, some of the context has changed. Since April 2021 the UK has enshrined the sixth carbon budget into law with a commitment to reduce emissions by 78% by 2035 compared to 1990 levels. The sixth budget, imposed by the Carbon Budget Order 2021 (23 June 2021), covers the years 2033-2037. It sets the budget at 965 million tonnes of carbon dioxide equivalent.

The New Southwark Plan, which will be the Borough’s local plan until at least 2036, does not meet the requirement for reducing carbon emissions by 78%. We have assessed this considering the following:

Lack of baseline data

There is still a lack of baseline data of the current position in Southwark, even to the January/February 2020 and the start of the examination period.

Since our last consultation response and the examination hearing of the New Southwark Plan, Southwark Council have published their Climate Strategy which includes an Appendix with carbon analytics provided by Antithesis, however they did not update the existing baseline data. In the Anthesis report, the data is divided into three categories of emissions – Scope 1 includes emissions from assets that are directly under council ownership. Scope 2 stem from the purchase of services, mainly electricity, in council-owned buildings. Scope 3 include council procurement activities, buildings such as emissions associated with the supply of natural gas and the distribution of grid electricity. Scope 3 accounts for at least 83% of carbon emissions. It details that the dominant contributor, and the council’s carbon footprint as a whole, is procurement. In this category, the second major procurement the council seeks after services is for construction.

Policies for bringing down carbon emissions by encouraging procurement of more sustainable companies could be directly addressed in the New Southwark Plan, but currently they are not. We raised the suggestion of a policy for an updated requirement for Sustainability, Design and Construction statements (or something similar) which could be required of planning applications to show that options for limiting carbon emissions have been adequately explored and reported on, including at all stages of the procurement process. This would directly be able to address the manufacturing and construction side of carbon emissions in the whole-life cycle of building.

We have also asked for the following:

  • As well as baseline data on the level of emissions in 1990, robust evidence base on the level of emissions at the start of the plan period in 2021, we have asked for a clear evaluation of future emissions including consideration of different emission sources, likely trends considering requirements set in national legislation, and a range of development scenarios;
  • A climate change risk assessment to inform policies designed to mitigate these risks and meet Southwark Council’s climate emergency declaration of net-zero carbon emissions by 2030;
  • Main modifications to the New Southwark Plan so it is aligned with the London Plan and Southwark Council’s Climate Strategy in ambition, implementation and monitoring to address the climate emergency declaration and extends the London Plan policies to non-referrable Major Developments in Southwark;
  • A requirement to report back on set indicators that support the mitigation of climate change such as carbon emissions reduction, renewable and low-carbon energy infrastructure and developments, use of reused and renewable materials in buildings and the progress to carbon neutrality, sustainability in building design and construction, increase in sustainable transport availability and usage, amongst other agreed indicators, and
  • Transparency in respect of the carbon off-setting fund and a plan to reduce the practice of carbon off-setting.

None of these comments have been directly and adequately reflected in the Main Modifications to the New Southwark Plan.

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