Issue and Options 2023
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Q-C3.1 A carbon off-setting approach to new developments could be supported in principle, if it was demonstrated that it is not possible to achieve net carbon zero requirements on a particular site. Further information is required on this subject and presumably this will be included in subsequent consultations.
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Q-C4.1 We consider that there is no requirement to have a specific policy covering the energy efficiency standards of new development. This would be a duplication of Building Regulations which are being updated regularly to reflect the national desire to reduce carbon dioxide emissions from previous standards. The frequency of changes to Building Regulations will probably mean that plans adopted to align with current standards will soon be out of date.
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Issue C7: Adapting to higher Temperatures C7b: We do not believe that a policy requiring new developments to incorporate measures to adapt to higher temperatures are necessary, particularly within Part 1 of the Plan. We consider that such measures are most likely to occur through the market in time, if required. If it were to become part of a policy requirement, we would expect that viability would be taken into account. Such measures should be carefully considered to ensure that they do not stifle the provision of much needed dwellings across the District. Issue C8: Adapting to flood and drought events Option C8b: We consider that there is no requirement to have a specific policy to incorporate measures to adapt to flood and drought events. This would be a duplication of Building Regulations which are being updated regularly to manage flood risk and water consumption. The frequency of changes to Building Regulations will probably mean that plans adopted to align with current standards will soon be out of date. Issue C9: Mitigating Biodiversity Loss Q-C91a. The Environment Act 2021 requires all planning permissions in England to deliver at least 10% biodiversity net gain (date yet to be confirmed) but expected to be November 2023. The NPPF already encourages BNG and most developers accept that their proposals will need to take account of it. Most new local plans are including specific policies dealing with biodiversity loss and gain. Any policy should be consistent with national policy and subject to thorough evidence testing and consulted upon as the Plan progresses, in particular if the target is for greater than 10% BNG.
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Q-C10.2. Further information/ evidence testing and further consultation is required in relation to the need for new development to undertake a Climate Change Risk Assessment. At present, based on the information available it could be viewed as duplication of other proposed policies (such as adapting to higher temperatures, carbon emission etc).
Issue C11: Water Management QC11b. The quality of water is important and this issue is often dealt with in Part 1 of a local plan. We consider option b to be the most appropriate option which would prioritises water quality as a strategic issue, and develop a new policy based upon up-to-date evidence. This should be tested through evidence and consulted on as the Plan progresses. Issue C12: Flood Risk We are content with the approach proposed to flood risk which is consistent with the requirements of the NPPF in both national and local terms. The Strategic Flood Risk assessment undertaken for Part 1 together with the Water Cycle Study which will follow will inform emerging future policy which should take account of updates to the PPG in August 2022 following the government’s review of policy for development in areas of flood risk and bring it in line with recent changes to the NPPF.
