Issue and Options 2023
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Issue C4: New Buildings Any policy relating to minimising emissions generated from new development should reflect national standards or, preferably, be left to building regulation requirements (Option C4.1a). This would mean there is a consistent approach applied that reflects the sector, technical feasibility and viability considerations. If a Council-based policy is considered necessary, any policy must be sufficiently flexible to respond to particular site or project specific circumstances, allowing a case-by-case consideration. Issue C5 – Existing Buildings Hermes does not consider that it would be appropriate to include a policy that requires net zero carbon requirements for all building proposals that require planning permission – including conversions, changes of use, and householder residential applications (Option C5a). While this ambition would be desirable, this could affect the viability of developments. Option C5b would be preferable, encouraging the retrofit of climate change measures into existing buildings, within certain parameters.
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Issue C8: Adapting to flood and drought events Hermes’ preference is that the Local Plan should not include a policy that goes beyond existing building regulations requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events (option C8b). Any policy should reflect national standards/minimum requirements, which would ensure that there is a consistent approach applied.
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Issue C10 – Climate Change Risk Assessments Climate Change Risk Assessments (or Checklists) should not be required for all new build development and changes to existing buildings (option C10.1c). Such a requirement is likely to be unduly onerous and disproportionate in many cases, particularly where planning applications are submitted for minor developments or works to existing buildings.
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Issue W2: Health Impact Assessments for major development Hermes considers there is insufficient justification to include a policy requirement for Health Impact Assessments (HIAs) for all major developments (option W2b). Flexibility should be built into any emerging policy such that the impacts of the proposed development are considered prior to the confirmation that a HIA is needed. Any HIAs that are subsequently required should be proportionate to the nature and scale of the proposed development.