Object

Representation ID: 10344

Received: 29/07/2022

Respondent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In terms of the Plan’s strategic policies, Policy DS1(S) Resources and Climate Change states that development must support a move to carbon neutrality. It then sets out a detailed series of points under the following headings:
(A) Minimising carbon emissions;
(B) Maximising carbon storage and sequestration;
(C) Mitigating and adapting to the impacts of climate change;
(D) Responding to the economic and policy changes that are likely to accompany climate change;
(E) “New development will be required to demonstrate through Sustainability and Energy Statements how it will take account of embedded carbon and contribute to mitigating and adapting to climate change and to meeting targets to reduce carbon dioxide emissions having regard to the above”.
2.9 The Trust corporate objectives support the national agenda and objective of achieving net zero carbon and is underpinned by an Estate Strategy and Net Zero Carbon plan, both of which inform the Trust’s Site Master Plan. The Trust’s Estate Strategy includes significant infrastructure development to deliver this approach on their estate, and this will likely include new sub-stations, an energy centre, new efficient buildings and green space. We therefore support the Council’s aspirations and strategic approach towards addressing climate change and minimising environmental impacts. However, we are concerned that setting out a broad and extensive policy – as in Policy DS1(S) – could result in an overly onerous policy context. For example, point (E) refers to Sustainability and Energy Statements as a requirement for new development. However, this is not qualified in terms of which developments would be expected to provide such statements. This requirement would be excessive for many minor developments and could create a barrier to appropriate and sustainable development.
2.10 Most environmental and performance standards associated with new development are managed through Building Regulations, and it is important that planning policies do not seek to replicate these. There is the risk that policies will quickly become outdated and inconsistent when Building Regulations are revised and updated. This causes confusion and, as mentioned, can create a context which negatively impacts on new development coming forward.
2.11 We suggest that Policy DS1(S) is clearly identified as a strategic policy – setting out the Council’s aspiration and objective regarding resources and climate change.