Windfarm Proposals could cost Mont St Michel World Heritage Site Status

From the Telegraph

Unesco has called on France to suspend all plans to build a series of vast wind farms within sight of one the country’s top landmarks, Mont St Michel, saying they will spoil the unique sea view….

At Unesco’s annual meeting in Paris, which ended last week, the heritage site committee unanimously agreed to ask for wind farm projects to be suspended until a report on their pact on the view is completed – probably by next year.

The body called on France to suspend all projects, planned or approved, and recommended it “put in place a plan to manage the view around the Mount” excluding all construction of wind farms “visible when one looks at the site” and “visible from the site”.

To illustrate the issue iv added the map below from the World Heritage Site management plan, showing the viewshed where you can see the Mont and be seen from it.  Since the map was published several offshore turbines have been permitted.

More info in French here Many of the photo montages look quite innocuous by uk standards, but the views at the moent are almost completely unspoiled and give an illusion of being unchanged since medieval times.

Yje prefect of Ille-et-Vilaine refused permission for three wind power projects along the Bay of Mont-Saint-Michel in Feb. He said that the projects are “in the field of co-visibility of Mont Saint-Michel” and “part of a symbolic landscape of great interest listed in the UNESCO World Heritage”.

National Planning Policy Framework Forensics#46 The Coast

This would replace PPG2o Coastal Planning, being one of the oldest PPGs from 1992, and PPS25 Supplment from 2010 Development and Coastal Change, as well as to some extent the never to be completed most likely PPS10 (2010) which would have replaced it.

The PPG is so old the government seems to have forgotten all about almost nothing from it is carried over, only from the supplement. Apart from two bullet points on pages 46 and 47

  • maintain the natural character of the undeveloped coast, protecting and enhancing its distinctive landscapes, particularly in areas defined as Heritage Coast, and improve public access to and enjoyment of the coast;
  • in coastal areas, take account of marine plans and apply Integrated Coastal Zone Management33 across local planning authority and land/sea boundaries;

It would have been much better if all coastal issues had been kept in one integrated section.

There are though in these residual section key changes to policies from PPG22.

Ill highlight the key policies from PPG20

The coastal zone extends seaward and landward of the coastline. Its limits are determined by the geographical extent of coastal natural processes and human activities related to the coast. For planning purposes, however, as a general rule the limit of the coastal zone in the seaward direction is mean low water mark. It could include areas affected by off-shore and near-shore natural processes, such as areas of potential tidal flooding and erosion; enclosed tidal waters, suchas estuaries and surrounding areas of land; and areas which are directly visible from the coast. The inland limit of the zone will depend on the extent of direct maritime influences and coast-related activities. (paras 1.5-1.7)

This is useful.

in the coastal zone, development plan policies should normally not provide for development which does not require a coastal location. Therefore, whilst realistic provision should be made in development plans for the foreseeable development needs of an area, the coast, particularly the undeveloped parts, will seldom be the most appropriate location. Few developments require a coastal location. Given both the physical and policy constraints in most parts of the undeveloped coast, it should not be expected to accommodate new development that could be located inland or in existing developed areas.

Which can simply be reduced to:

In the coastal zone, for land which is undeveloped, only development requiring a coastal location will be acceptable.

This includes
– predominantly open tourism (tourist caravan sites should be located away from the undeveloped coast where possible, it is for local plans to determine the acceptable new uses for former caravan sites))
– recreation;
– developments, including ports, boatyards,  marinas and industries importing bulky raw materials, that depend on access to the sea;
– mineral extraction;
– coastal defences;
– coastguard stations
– aquaculture;
– nature conservation;
– energy generation; and
– desalination plants, waste water and sewage treatment and disposal.

I’ve updated this list from PPG22 to include desalination plants, coastal defences, nature conservation, coastguard, boatyards and aquaculture and to tighten policy on caravan sites which currently is unacceptably lax.

Without this it would be a major watering down of policy.  The suggested replacement only protects the ‘natural character’ of the coast, from draft PPS10.  So would underground dwellings ith green roofs be acceptable then?

The importance of regeneration of rundown coastal towns and ports; and restoration of stretches of the despoiled coastline, should be mentioned (para 2.23)

The following based on para 4.5 can also be usefully carried over:

development plans should cooperate should define:
– the coastal zone and any coastal zone management areas within the coastal zone;
– those parts of the coast where either opportunities exist for development for purposes which require a coastal location or for increased levels of recreation and other coast-related activities;
– those parts of the coast where physical constraints and/or risks from coastal change either make development inappropriate or require the imposition of special conditions on planning consents; and – those parts of the coast which need enhancement or regeneration, particularly areas damaged by past development.

Now PPG22 was from the days of integrated coastal zone management.  The key innovation in coastal zone planning in the last 20 years, together with the formation of the Marine Management Organisation which controls the planning of the area below the MHWM under the Marine and Coastal Areas Act 2009.

In January 2009 the UK’s Department for Environment, Food and Rural Affairs (Defra) launched ‘A strategy for promoting an integrated approach to the management of coastal areas in England’. Defra’s definition of ICZM is:

‘Integrated Coastal Zone Management means adopting a joined-up approach towards the many different interests in coastal areas – both on the land and at sea. It is the process of harmonising the different policies and decision-making structures, and bringing together coastal stakeholders to take concerted action towards achieving common goals. Integrating the many different interests effectively means we can look at the coast in a holistic way.’

Why is there not a reference to this document and inclusion of the definition and aim of ICZM, and the need to work with the MMO, at the very beginning of the section? The definition in footnote 33 is just a tautology.

The policy on development management of the coastal zone management area is the same as the PPS25 supplement, but includes reference to policy for the national coastal path, carried over from the 2009 coastal act and the national coastal strategy.

National Planning Policy Framework Forensics#45 Flood Risk

This section compares PPS25 March 2010 with the practitioners draft of the NPPF.

This is one of the most up to date and one of the most technical PPSs.  So transposing policy in a simple but adequate form is going to be very difficult, have they succeeded?

The key policy tests are taken from paras 6. and 8. of PPS 25 and are the same apart from the following additional wording (underlined):

‘the benefits of the development outweigh the risks from flooding and it will be safe for its lifetime;’  

This comes from para. 22 in the context of site level FRAs.  It is unclear if site level FRAs can be required.  If they can this should be mentioned.

The section from the bottom of para 6 of PPS25 on meaures to reduce flood risk, e.g. restoring functional flood plains, should be included in edited form.

The key problem though is that the tests on page 44 of the NPPF mention both the sequential test and the exception test but dont explain what the sequential test is.

The NPPF is supposed to be a self contained document.  A box is required in the text transposing edited versions of para 16 and 17 of PPS25 and the tables D.1-3 from Annex D, this can be done in an appendix to the PPS.  This can be shorted as only the topline definition and appropriate uses of each flood risk area are needed as policy.  FRA requirements etc can be contained in revised and expanded good practice guidance issued by the EA) .  This should take no more than a page and a half.  The first part of para D15 should also be carried over.  The requirements for FRAs for changes of use and domestric extensions should also be reviwed as these are excesively onorous at the moment.

The following essential text from para G.2 should also be carried over:

Following application of the Sequential Test and Exception Test …development should not normally be permitted where flood defences, properly maintained and in combination with agreed warning and evacuation arrangements, would not provide
an acceptable standard of safety taking into account climate change.

As should the following text from para 19

The Exception Test is only appropriate for use when there are large areas in Flood Zones 2 and 3, where the Sequential Test alone cannot deliver acceptable sites, but where some continuing development is necessary for wider sustainable development reasons, taking into account the need to avoid social or economic blight and the need for essential civil infrastructure to remain operational during floods. It may also be appropriate to use it where restrictive national designations… prevent the availability of unconstrained sites in lower risk areas

and finally the following edited text taken from para D.9

For the Exception Test to be passed it must be demonstrated that the development is on prevously-developed land or, if it is not on previously developed land, that there are no reasonable alternative sites on developable previously-developed land; and a FRA must demonstrate that the development will be safe, without increasing floodrisk elsewhere, and, where possible, will reduce flood risk overall.

This shows that it is possible to cut down a complex PPS, if the cutting down is not excessive. 100 pages should be ok.

CPRE – Lying with Maps

The CPRE today put out a press release and map on threats to AONB across the country

Unfortunately the map is ridiculous.

One of the schemes highlighted is Lydd airport, not in an AONB, not even near AONB, nearly 10 miles away.

The black line shows the village of Newbridge 5 miles north of Lydd Airport, the Red splodge is over 20 miles away.  You might as well say Heathrow is in the Chilterns.

The CPRE should withdraw the map and apologise.

Policy threats the countryside have never been so severe and so in order to retain their credibility the CPRE needs to show at least some basic accuracy.

Even Recently Adopted Plans will need NPPF Conformity Certificates

Interesting peice by Micheal Donnelly at Planning Blogs

I got an email from a contact last week telling me that, speaking at a National Planning Forum event, the Department for Communities and Local Government’s chief planner Steve Quartermain had tacitly acknowledged that any local authority with an existing adopted Core Strategy would have to go through a reassessment process by the Planning Inspectorate for conformity with the upcoming NPPF (which is due anytime now). Those that fail will have to be rewritten and re-examined, after effectively being found unsound, his comments suggested.

…a leaked draft of the NPPF appears to suggest that existing adopted Core Strategies will need to be reassessed for conformity with the framework. The leaked document says: “It will be open to local authorities to seek a certificate of conformity with the framework, or to prepare a new or revised plan.”

It reminds me of the ‘rescrutinisation’ process after the Planning and Compensation Act – what a nightmare.

At the moment not a single core strategy in the country will comply, the policy shifts are so abrupt.

Chipperfield: Waterloo Elizabeth House Proposals Unveiled

Davis Chipperfield has unveild his new plans for Elizabeth House next to Waterloo Station.  The Three Sisters Scheme by Allies and Morrison was refused last year for its impact on the Houses of Parliament World Heritage Site

Chipperfield’s scheme is more restrained and sensibly connects with Waterloo International and Lower Marsh, through creating a new shopping street, making a restruction of not being able to build load bearing structures over a tube line to advantage.  I suggested this concept of a ‘cross river high street’ connecting through to the Hungerford Bridge a number of years ago when working at Lambeth.

The design sums up more than any other the turn to the simple low risk boxy forms that the market has now been demanding and the likes of Ken Shuttleworth has been converted too. Im unconvinced though by the views from the west (below), the most important in the local townscape, and from the other side of the river.   It looks like a building with the upper storeys treatment sawn off.   The problem isnt the in your facenecess of the previous proposal rather that it just doesn’t grab you as rising to the occasion.  No visitor to London would want to take a picture of it.

Wheras the earlier conceptual schemes (below) seems bolder and better

Belarus bans applause – clapping demos as country on edge of economic collapse

The country most likely to default first in 2011 is not Greece but Bealrus.  With debts of over $30 billion, a hard-line president refusing to reform and fix ing lections, and Russia even temporarily cutting of the gas after its bills weren’t paid last week.  In this climate demos are banned so, as Moscow News reports:

Minsk has hit back by banning applause in public.

With the country due to celebrate Independence Day on July 3, it means that clapping on the streets could see people clapped in metaphorical irons.

But there is a serious side to the government’s proposals: opposition groups have been staging slogan-free demonstrations where participants merely stand and cheer, rather than yelling their demands.

The police promise to allow applause on the street at July 3 celebrations, but only if it is directed at acting servicemen and veterans, deputy head of Minsk police Igor Yevseyev said at a press conference.

“If it is applause for our veterans or servicemen – then of course, it is allowed,” he is quoted by Interfax.

Yevseyev was asked how the police will react if there is applause on Oktyabrskaya Ploshchad on July, 3rd, Belarus Independence Day.

That day there will be two events in Minsk – a parade to celebrate 20th anniversary of independence, and other celebrations.

Following numerous arrests of protestors, they had to come up with new tactics. The latest includes no chants or posters. The participants of “Revolution through social networks” just go to the streets every Wednesday, stay silent, and occasionally applaud.

But that has still incurred official wrath: thousands gathered on June 22, and there were dozens of arrests.

The opposition, however, is staging a “March of the millions” event, where it plans to protest against president Alexander Lukashenko.


‘China now has an Oversupply of Homes’ Report

From China Daily

The country’s property market now has an oversupply of homes, according to Wang Jinbin, a leading economist at Renmin University of China.

“The total stock of commercial homes in the first three months among the 136 listed property companies will perhaps require two years or even more to digest,” he said, citing statistics in the report.

…And for many home developers, fund shortages are becoming more of an issue, Wang added.

Some analysts and organizations are also starting to forecast declines in home prices, with a growing expectation that the government will not relax its policy stance before the end of the year.

According to a report by the National Institute of Property Finance and Beijing Beta Consulting Center, China’s first-tier cities will probably see a 30-percent fall in property prices. Second-tier cities could see drops of 10 to 20 percent.

“An obvious price drop in the property market is expected to appear in the second quarter of next year when a large amount of government-subsidized houses will pour onto the market,” said Li Chang’an, a public policy professor at the Beijing-based University of International Business and Economics.