Minutes:
The Board welcomed Laura Howard, Dan Knowles and Benjamin Moyes from the Planning Policy Team.
A Supplementary Planning Document (SPD) provided guidance and was not policy. The last Climate Change SPD was adopted in 2020 and it was due for a refresh. The draft SPD had been submitted to the council’s internal Local Plan Panel for consideration and officers now sought the comments of the CCB prior to launching a period of public consultation commencing mid-June for a period of four weeks. A final draft would be presented to the Executive for adoption in either September or October dependent upon the time it took to process the response.
The council began the review of the Climate Change SPD after the Local Plan Development Management Policies (LPDMP), (part 2 of the Local Plan) was adopted on 22 March 2023. It was anticipated that the SPD guidance would improve the quality of planning applications submitted. Since 2020, there had been changes to the National Planning Policy Framework (NPPF) and regulations along with changes to emissions calculations and general construction practice. There were also changes in the DMP that needed to be reflected in the guidance.
The general design of the document had been improved and the question format changed to encourage respondents to provide more in-depth answers.
The Board made the following observations:
· Training would be undertaken with planning officers to ensure that they were familiar with the updated guidance. It was likely that training would also be provided to the agent’s forum to improve the quality of submissions.
· Certain areas had been expanded upon which was welcomed i.e., adaptation, biodiversity, demolition costs, flexibility for alternative uses and also heritage which was useful.
· There was no end date to the existing Local Plan, legislatively Local Plans were open ended. However, Local Plans were reviewed every five years to understand if an update was required. The council had reviewed the Local Plan Strategy and Sites (LPSS) which was now 5 years old and had found it did need updating. It was considered the LPDMP, which had only been adopted relatively recently and part 1 were consistent with the current NPPF, albeit the existing LPSS had been adopted under a different NPPF. Officers went on to confirm that the existing Local Plan would continue to be relevant until a new Local Plan was adopted in the future. The requirements of the current Government for new Local Plans were currently unconfirmed, under a new Government the requirements were also unknown. The Climate Change SPD would provide supplementary up to date guidance to those Plans until a new Plan was in place and may need to be updated as many times as necessary during that period to reflect any changes in the NPPF and building regulations.
· It was suggested the SPD might be prefaced by a statement of the council’s ambition to reach net-zero by 2030 and of the council’s commitment to go further than the minimum requirements with the backing of the CCB. However, the document itself was a statutory tool not adopted policy which made it unsuitable for political assertions.
· Cooling streets and buildings as part of development was raised and it was noted that the SPD did also cover the landscape generally.
· Government was currently consulting on Future Home standards. In the meantime, the council was pushing existing building standards further in the SPD than was currently set out in regulations. It was expected that the SPD would already be largely in compliance with the new standards by the time they were published.
· One area where the council was always highly scored was its Climate Change planning policies.
· The SPD supported the internal aims of the University. The summaries were described as particularly useful.
· The use of words such as ‘adequate’ and ‘proportionate’ was queried as their meaning. There was a risk the document could become subjective unless these were defined, particularly section 3.2. In response, it was explained that the meaning of such words was set out in the LPSS.
· The use of Passivhaus[1] standard and BREEAM[2] in the document was welcomed. Albeit the SPD could be clearer that such accreditation was awarded following a postconstruction review and applicants would need to properly demonstrate their intention to reach such standards at the Planning stage to have permission awarded.
· Comments in paragraph 6 about the council having declared a climate emergency could be repeated in the introduction.
· Thought should be given to the users of the document. Large scale developers would be used to accessing documents such as this but smaller scale builders and householders may not. It should be accessible to all and possibly accessed earlier in the process at design stage. The document could make more reference to design.
· The link to the guidance on the website was currently not working and should be fixed.
· There should be active reference to sustainable materials and the layout of sites above a certain size in the questionnaire.
· Ultra-low carbon impact development should also be acceptable along with zero/negative impact.
· The ‘Very special circumstances’ test was not defined and was appraised on a case by case basis. It was a high bar and was not confined to carbon emissions.
· Planning officers asked for members of the Board to submit any further comments via email and would be most appreciative if those comments could be submitted prior to the public consultation so that the SPD could be updated accordingly.