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Doncaster Local Plan Topic Paper 1: Climate Change & The Local Plan March 2020 (Submission)

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Contents Introduction ..................................................................................................................................... 2

International Consideration ......................................................................................................... 2

The Climate Change Act 2008 ..................................................................................................... 3

The Planning and Compulsory Purchase Act ........................................................................ 3

National Planning Policy Framework (NPPF) ......................................................................... 3

National Planning Practice Guidance (NPPG) ........................................................................ 3

Progress in Preparing for Climate Change – 2019 Report to Parliament ....................... 4

Doncaster’s Inclusive Growth Strategy 2018-2021 ............................................................... 5

Doncaster Challenges and Issues ............................................................................................. 5

Air Quality (Emissions) and Climate Change ......................................................................... 6

Impacts of Climate Change on Wildlife Habitats and Species ........................................... 6

Doncaster’s Climate Change Emergency and Emerging Environment Strategy. ........ 7

Green Infrastructure Strategy ..................................................................................................... 8

Sheffield City Region (SCR) Energy Strategy ........................................................................ 8

Net Zero North - Delivering Decarbonisation Mission in the North of England ............ 8

Doncaster’s Publication Local Plan 2015-2035 (Publication Version) ............................. 9

Conclusion ....................................................................................................................................... 9

Appendix One: Climate Change Cross Reference – National Planning Policy and the

Doncaster Local Plan 2015 – 2035 (Publication Version) ........................................................... 10

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Introduction

1. The purpose of this document is to identify if the Local Plan sufficiently covers all the relevant climate change issues to ensure the delivery of a sound plan. It also identifies what other areas of the council are also dealing with in respect of addressing climate change.

2. Climate change is the greatest long-term challenge facing human development. It is acknowledged that spatial planning can make a major contribution to tackling climate change by shaping new and existing developments in ways that reduce carbon dioxide emissions and positively build community resilience to associated problems. Planning has the potential to deliver the right development in the right place in a fair and sustainable way.

International Consideration

3. Climate change is a global issue requiring a global response that requires consideration at an international, national, local and personal level. The United Nations Climate Change Conference 2015 (The UN Climate Change Conference in November 2018 confirmed to put the Paris accord in to practice)

4. The United Nations Climate Change Conference in Paris December 2015 Article 2 committed signatories to the following:

a) Holding the increase in the global average temperature to well below 2 °C

above preindustrial levels and to pursue efforts to limit the temperature

increase to 1.5 °C above pre-industrial levels, recognising that this would

significantly reduce the risks and impacts of climate change;

b) Increasing the ability to adapt to the adverse impacts of climate change and

foster climate resilience and low greenhouse gas emissions development,

in a manner that does not threaten food production;

c) Making finance flows consistent with a pathway towards low greenhouse

gas emissions and climate-resilient development.

5. The agreement recognises the role of non-party stakeholders in addressing climate change, including cities, other subnational authorities, civil society, the private sector and others, who are invited to;

scale up their efforts and support actions to reduce emissions;

build resilience and decrease vulnerability to the adverse effects of climate

change;

uphold and promote regional and international cooperation.

6. Subject to ratification this will be legally binding and subject to 5 yearly review with parties preparing and maintaining nationally determined contributions that it intends to achieve. Parties shall pursue domestic mitigation measures with the aim of achieving the objectives (article 4).

7. 183 nations including the European Union (and the UK) have ratified the agreement, as such it has it has implications for national policy making. These changes will be taken into account through any future plan review process at a

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national, regional and local level.

The Climate Change Act 2008

8. The original Climate Change Act 2008 established a legally binding target to reduce the UK’s greenhouse gas emissions by at least 80% below the 1990 levels by 2050. To drive progress and set the UK on a pathway towards this target, the Act introduced a system of carbon budgets including a target that the annual equivalent of the carbon budget for the period including 2020 is at least 34% lower than 1990. In June 2019 the government announced it will commit to a net zero 2050 target and carbon neutrality has become a mainstream goal. The Climate Change Act was subsequently amended substituting the 80% target for the 100%. The Clean Growth Strategy, the UK’s plan for emissions reduction, provides a solid foundation for the action needed to meet a net-zero ‘greenhouse’ gas target.

The Planning and Compulsory Purchase Act

9. Local planning authorities are bound by the legal duty in Section 19 of the 2004 Planning and Compulsory Purchase Act, as amended by the 2008 Planning Act, to ensure that, taken as a whole, plan policy contributes to the mitigation of and adaptation to climate change. This outcome-focused duty on local planning clearly signals the priority to be given to climate change in plan making. The built and natural environment, the quality of design, the minimisation of waste, the use of energy and the generation of energy all have a planning element that can be positively influenced by good policy making.

National Planning Policy Framework (NPPF)

10. Chapter 14 of the NPPF refers directly to meeting the challenges of climate change, flooding and coastal change. It states the planning system is required to support the transition to a low carbon future and take account of climate change and coastal erosion (where relevant). Plans should shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.

11. The table (Climate Change Cross Reference - Publication Local Plan Policy_2019) in appendix one looks at the relevant sections in the NPPF (and NPPG) and identifies how the publication local plan addresses the requirements.

National Planning Practice Guidance (NPPG)

12. The NPPG gives practical examples of how to mitigate against climate change through the reduction of emissions by:

Reducing the need to travel and providing for sustainable transport

Providing opportunities for renewable and low carbon energy technologies

Providing opportunities for decentralised energy and heating

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Promoting low carbon design approaches to reduce energy consumption in

buildings, such as passive solar design

13. The NPPG also gives examples of how best to adapt to a changing climate:

Considering future climate risks when allocating development sites to

ensure risks are understood over the development’s lifetime

Considering the impact of and promoting design responses to flood risk and

coastal change.

Considering availability of water and water infrastructure for the lifetime of

the development and design responses to promote water efficiency and

protect water quality.

Promoting adaptation approaches in design policies for developments and

the public realm.

14. When preparing local plans and taking planning decisions local planning authorities should pay particular attention to integrating adaptation and mitigation approaches and looking for ‘win-win’ solutions that will support sustainable development. This could be achieved in a variety of ways…

by maximising summer cooling through natural ventilation in buildings and

avoiding solar gain;

through district heating networks that include tri-generation (combined

cooling, heat and power); or

through the provision of multi-functional green infrastructure, which can

reduce urban heat islands, manage flooding and help species adapt to

climate change – as well as contributing to a pleasant environment which

encourages people to walk and cycle.

Progress in Preparing for Climate Change – 2019 Report to Parliament

15. The report sets out the Climate Change Adaptation Committee’s latest assessment of progress in preparing for climate change in England, and provides a first evaluation of the Government’s second National Adaptation Programme. The key findings of the report are shown below

The priority given to adaptation, including through the institutional and

support framework in England, has been eroded over the past ten years.

England is still not prepared for even a 2°C rise in global temperature, let

alone more extreme levels of warming. Only a handful of sectors have

plans that consider a minimum of 2°C global warming – water supply, road

and rail, flood defences and flood risk planning for infrastructure.

Many national plans and policies still lack a basic acknowledgement of

long-term climate change, or make a passing mention but have no

associated actions to reduce risk. This includes aspects of agriculture, the

natural environment, health, other infrastructure sectors and business.

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None of the sectors assessed have yet been given top scores for reducing

the risks from climate change through appropriate action.

The UK Government must raise the profile, and strengthen the governance,

of preparations for the impacts of climate change. It should ramp up

resources and action on all of the urgent risks set out in the UK Climate

Change Risk Assessment, continue to take appropriate action for those

classed as less urgent (but still important), and monitor the effects on

climate risk over the next five year period.

Doncaster’s Inclusive Growth Strategy 2018-2021

16. Doncaster’s Inclusive Growth Strategy aspires to deliver economic growth that benefits all people, places and businesses is a core priority in the Doncaster Growing Together Plan. It identifies the need to move to cleaner economic growth, through low carbon technologies and the efficient use of resources, presents a significant economic opportunity, which Doncaster will seek to exploit.

17. The Strategy also identifies that poor environmental quality affects economic growth and well-being, for example by lowering the quantity and quality of resources or affecting people’s health through poor air quality. The document identifies that climate change through increases in CO2 levels also presents a significant global threat to economic growth and well-being. The aspiration of the growth strategy is to grow the economy (with the emphasis is on low carbon growth) and bring with it the associated benefits for people, place, education, skills and jobs.

Doncaster Challenges and Issues

18. The Local Climate Impact Profile (LCLIP) is a local authority tool that identifies the main weather events, which have affected the borough, and shows the climate trends such as temperature and rainfall. The LCLIP tool has been developed for local authorities to enable a better understanding of the impact and consequences of extreme weather on local authority services, the environment and communities.

19. The aim of the LCLIP is to raise awareness of the council’s approach and response to such extreme events and to identify what additional support may be needed and establish what other actions may need to be undertaken to ensure service delivery in the future.

20. A long term study as well as interviews with key partners and council officers from various service areas has found that in Doncaster:

the climate is changing faster now than it has at any time over the past 100

years

the annual average temperature now stands at 10.5°C. It has increased by

1°C since 1985 - fluctuation in the previous 75 years was limited to +/-

0.2°C

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summer temperatures are increasing at a faster rate than winter

temperatures; however, both are getting warmer. Since 1985 we have

experienced an increase in the number of annual sunshine hours.

According to the LCIP that trend will continue with summer temperatures

regularly reaching 30°C and we can expect more dry spells for longer

periods

rainfall has also increased significantly since 1990. This fact, coupled with

the development of land on flood plains, blocked drainage and the ‘run-off’

of water, poses a significant future flood risk to the borough

Doncaster’s ten-year weather timeline shows that ‘extreme events’ have

more than doubled from 2006 onwards.

21. Weather extremes include wetter winters, drier summers, storms and gales. Drier, hotter1 summers also bring additional problems of heat stress and worsening air pollution.

Air Quality (Emissions) and Climate Change

22. Monitoring air pollution sits with the Local Authority ‘Pollution Control Team’. Air pollution often originates from the same activities that contribute to climate change (notably transport and electricity generation, but also to a lesser degree industrial activity). The air pollutants of greatest concern in the UK now are particulate matter (PM), Oxides of Nitrogen (NOX), ozone (O3) and Ammonia (NH3). Traffic is the major reason for episodes of raised pollution levels in the town centre. The air pollutants identified above are all identified in the Kyoto international agreement and the Climate Change Act 2008 as ‘greenhouse gases’ (GHGs) which exacerbate climate change.

23. There are seven ‘Air Quality Management Area’s’ (AQMAs) in Doncaster each with its own monitoring station which measures nitrogen dioxide2 (NO2) and particulate matter (PM10). The council is upgrading the AQMA monitoring stations within the next five years to include monitoring of PM2.5s. The council also has access to other indicative monitoring information across the borough, but does not directly monitor other greenhouse gas emissions, as there is currently no direct requirement to do so.

Impacts of Climate Change on Wildlife Habitats and Species

24. The weather extremes significantly affect birds, mammals, invertebrate populations and migrant species. The more long-term effects of higher ambient temperatures and lower precipitation will also have long term impacts on a variety of vulnerable wildlife habitats that exist within Doncaster such as the internationally important Thorne and Hatfield Moors.

1 higher average temperatures

2 nitrogen oxides, have an indirect effect on climate change through their influence on the concentrations of the greenhouse gases methane and ozone (source: Air Quality and Climate Change: A UK Perspective)

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Doncaster’s Climate Change Emergency and Emerging Environment

Strategy.

25. The Mayor of Doncaster (Ros Jones) declared a climate change and biodiversity emergency at the September 2020 full council. As a direct result of this Doncaster’s Climate and Biodiversity Commission was created in conjunction with Team Doncaster Strategic Partnership3. The Commission has

resolved to put sustainability, biodiversity and carbon reduction at the heart of its agenda and support communities, businesses and individuals to make more sustainable choices.

26. To support this declaration, the Commission will advise on strategies and best practices to:

Promote leadership in the borough on climate change

Establish the borough’s carbon reduction target and road map to delivery

Advise on the assessment of climate-related risks and adaptation opportunities in the borough

Bring together major organisations and key groups in Doncaster to collaborate on projects that result in measurable contributions towards carbon reduction targets

Make the economic case for innovation and investment in low carbon and climate resilient projects

Promote best practice in public engagement on climate change and its impacts

Consult and advise regional and national bodies on issues impacting the effectiveness of local climate action.

27. The Commission will be considering information from the following key topics to

develop practical recommendations to address the Crisis:

Land Use and Nature Recovery

Energy production

Green Business, Economy and Technology

Waste and Sustainable Consumption

Sustainable Transport

Housing and Buildings

28. The Doncaster Nature Alliance complements the Climate and Biodiversity Commission by bringing together local nature-based organisations, communities, and public services to promote nature recovery in Doncaster, community engagement in natural climate solutions, and the enjoyment of the natural environment. Nature recovery and regeneration is an essential part of any climate change strategy and the partnership will promote natural solutions to climate change. Healthy habitats and diverse ecosystems are essential to ‘draw down’ greenhouse gases and store them trees, plants, peat and soil.

29. The council is also working on a new Environment Strategy; this overarching

3 Team Doncaster is formally recognised as the strategic partnership of organisations and individuals that spans

the public, private, voluntary and community sectors

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document will set out the priorities addressing climate change locally. It will bring together key priorities from supporting plans, strategies and policies for service areas, which contribute to maintaining and improving the environment and ensuring future sustainability. The strategy will identify areas of focus, activity and targets to address a range of issues relating to the environment, such as; sustainable energy and energy efficiency, recycling, land and water management, green and innovative growth and development.

Green Infrastructure Strategy

30. This 2014 Green Infrastructure (GI) Strategy sets out our overall approach for delivering an integrated network of high quality green spaces, habitats, and landscapes across the borough. The Strategy underpins and identifies a number of other strategies, such as a Green Space Strategy and Tree Strategy, into a single overarching framework for the Borough’s green infrastructure provision. The strategy forms part of the evidence identifying the hierarchy of green infrastructure corridors in figure 8 of the Local Plan. The 2013 Green Space Audit provides information on the location, coverage and provision of green spaces in Doncaster. The Biodiversity Action Plan outlines wildlife conservation priorities and provides guidance on how we can protect and enhance biodiversity. Both of these documents inform the GI Strategy.

Sheffield City Region (SCR) Energy Strategy

31. The Sheffield City Region Energy Strategy is timetabled to be presented to the Mayoral Combined Authority Board in March 2020 and, if adopted, will be published in Spring 2020. The strategy focuses on; business and industrial energy efficiency and sector opportunities; increasing renewable energy capacity and energy resilience; the built environment including the decarbonisation of heating; and low/zero emission transport. The document will also include a carbon budget of 44.7MtCO2 for South Yorkshire with the aim to reach net-zero by 2040 – ten years before the UK as a whole. The priorities of the Energy Strategy will be reflected in both the new Strategic Economic Plan and the Climate Emergency Response Framework, which are also in development.

Net Zero North - Delivering Decarbonisation Mission in the North of

England

32. This document prepared by the Institute if Public Policy Research, identifies the north’s economy is carbon intensive. Energy intensive northern industries contributed 30% of the total UKGVA in 2015. The north of England industry is taking advantage of low carbon technology opportunities though and the region accounted for 35% of all jobs in low carbon goods and services in 2013. Analysis identifies three areas where the north has strong potential to develop underutilised skills and knowledge such as, hydrogen, domestic energy efficiency and mobility. The paper also identifies two key areas with strong potential for reducing carbon emissions, lowering costs and increasing competitiveness in the region; industrial carbon capture and storage and industrial waste heat recovery.

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Doncaster’s Publication Local Plan 2015-2035 (Publication Version)

33. The policies that run through the Local Plan document cover the wide range of issues related to climate change. The table in appendix one identifies the national policy and guidance alongside policies in the Local Plan that will address the issues identified above and meet with the national requirement to address climate change locally. The ‘theme’ of climate change runs through the Local Plan and is highlighted in chapter 14, which identifies and addresses the issues relating to flood risk, low carbon and renewable development in detail.

34. Throughout the document though there are also policies relating to the provision of sustainable transport, green infrastructure, landscaping and low carbon provision in new developments, pollution mitigation and good urban and non-residential design. Ecological networks, local wildlife and geological sites, trees woodlands and hedgerows are also comprehensively covered too. The conclusion of this document therefore is that the Local Plan more than adequately addresses the issue of climate change at a local level.

Conclusion

35. The council as a whole is tackling the challenge of climate change head on. The declaration of the climate change emergency in 2019 and the establishment Climate and Biodiversity Commission is reflective of the authority’s drive to address the issue. The Sheffield City Region is also developing a decarbonisation strategy with the aim to achieve net zero in advance of the UK target.

36. This document identifies the national considerations in relation to climate change and planning and identifies how the Local Plan addresses the requirements of the NPPF and the NPPG. The detail can be found in appendix one. The Local Plan sets strategic priorities in the borough and provides the policies to help achieve the vision. The policies throughout the plan address climate change mitigation and adaptation, and conservation and enhancement of the natural and built environment as well as new allocations (homes and employment), infrastructure, minerals, energy, historic environment, retail and town centres, design, health, community infrastructure and spatial proposals. The plan acknowledges the need to transform in response to technology, economy, lifestyles and climate change and recognises the need to increase climate change resilience and energy efficiency of buildings and spaces. The plan also acknowledges the need to adapt to challenges include mitigating the effects of climate change from extreme weather events and flooding.

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Appendix One: Climate Change Cross Reference – National Planning Policy and the Doncaster Local Plan 2015 – 2035 (Publication Version)

Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

NPPF

Paragraph 15 - The planning system should be genuinely plan-led. Succinct and up-to-date plans should provide a positive vision for the future of each area; a framework for addressing housing needs and other economic, social and environmental priorities…

The Local Plan sets strategic priorities in the borough and provides the policies to help achieve the vision. Policies address climate change mitigation and adaptation, and conservation and enhancement of the natural and built environment as well as new allocations (homes and employment), infrastructure, minerals, energy, historic environment, retail and town centres, design, health, community infrastructure and spatial proposals. The plan acknowledges the need to transform in response to technology, economy, lifestyles and climate change and recognises the need to increase climate change resilience and energy efficiency of buildings and spaces. The challenges include adapting to and mitigating the effects of climate change such as extreme weather events, flood risk and water scarcity. The vision states Doncaster will be ‘A thriving place to learn, work, live and care” and we will attract new businesses to the area and encourage a low carbon economy to combat climate change. There a two specific objectives relating directly to climate change… ‘Climate change (flood risk) and energy: 17. reduce dependency on fossil fuels to reduce locally produced greenhouse gas emissions and minimise the impacts of climate change and in line with the Sheffield City Region and encourage the transition to a low carbon Borough. 18. ensure that Doncaster adapts to the effects of climate change through careful planning and design of developments, avoiding more vulnerable development in flood risk areas and managing the

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

risk of flooding from all sources, including through appropriate mitigation of development where avoidance is not possible.’ Paragraph 4.17 (Flood Risk) states ‘decision-taking (including implementation of the Plan’s Spatial Strategy and Settlement Hierarchy) should be based on a sequential risk based approach to avoid areas of flood risk through application of the sequential and, where necessary, exception tests. Where possible, development should be directed away from medium-high flood risk areas. Where this is not possible, the residual risks must be managed. Land should be safeguarded from development that is required for current and future flood management. Opportunities’ and ‘…Where climate change is expected to increase flood risk to existing development, making it unsustainable in the long-term, opportunities to facilitate its relocation to more sustainable locations should be explored…’ Local Plan supporting chapters and policies include: Policy 1: Presumption in favour of sustainable development (Strategic Policy) and provides for Doncaster’s strategic approach being based on a desire to deliver sustainable growth Policy 4 Employment allocations body text (para. 4.55) states there is support for low carbon economy to help combat climate change. Policy 13: Strategic Transport Networks, identifies locations for improvements to road and rail infrastructure plus improvements to bus transport Policy 17: Cycling in Doncaster. Seeks to provide for new and improved cycling routes in Doncaster Policy 18: Walking in Doncaster. States walking will be promoted as a means of active travel as well as for recreation. Improvements will be sought to walking connectivity throughout the Borough Chapter 10: Green Infrastructure is required for aiding resilience to climate change.

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Policy 27: Green Infrastructure (A. 9 and 10 specifically) states major development proposals will be supported that help people and wildlife adapt to the impacts of climate change by including naturalised forms of flood storage and/or incorporating additional tree planting within developments and provide for long term protection and climate change resilience through smart developments, management and maintenance. Policy 30: Ecological Networks, which states, Proposals will only be supported which deliver a net gain for biodiversity and protect, create, maintain and enhance the Borough's ecological networks Policy 31: Valuing Biodiversity and Geodiversity (Strategic Policy) which states internationally, nationally, and locally important habitats, sites and species that will be protected. Policy 33: Woodlands, Trees and Hedgerows and Policy, which states, proposals will be supported where it can be demonstrated that woodlands, trees and hedgerows have been adequately considered during the design process, so that a significant adverse impact upon public amenity or ecological interest has been avoided. There will be presumption against development that results in the loss or deterioration of ancient woodland and/or veteran trees. Policy 34: Landscape (Strategic Policy) which states proposals will be supported that take account of the quality, local distinctiveness and the sensitivity to change of distinctive landscape character areas and individual landscape features, in particular Thorne and Hatfield Moors. Policy 43: Good Urban Design (B.11) states high quality development that reflects the principles of good urban design will be supported that… reduce carbon emissions, adapt to climate change and make efficient use of natural resources during construction and operation through measures such as orientation, layout, inclusion of technology and material selection…

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Policy 45: Residential Design (Strategic Policy) states New housing, extensions, alterations and changes of use to housing will be supported where (B.11) …flood resistance and resilience measures with an allowance for climate change are incorporated if located in, or adjacent to, flood risk areas... Policy 47: Design of Non-Residential, Commercial and Employment Developments (Strategic Policy) states, all non-residential and commercial developments, including extensions and alterations to existing properties, must be designed to be high quality, attractive, and make a positive contribution to the area and New major non-domestic applications (1000m2 floor space or more, or a site of 1 hectare or above) must meet the BREEAM rating of at least ‘Very Good’, or any agreed equivalent standard, and secure at least 10% of their regulated energy from renewable sources (or equivalent carbon emission reductions) Chapter 14 Climate Change, Minerals, Resources & Energy The policies in chapter 14 and the Local Plan as a whole set out how the Local Plan will ensure that we:

address and adapt to climate change

follow a risk-based approach to the location of development to avoid flood risk where possible,

where development is necessary in areas at risk from flooding ensure the residual risks to people and property are properly managed

increase the supply of low carbon and renewable energy;

protect best and most versatile agricultural land

make the best use of our mineral resources. Policy 57: Drainage. Developments will need to provide for adequate drainage and appropriately manage flood risk to existing communities.

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Policy 58: Flood Risk Management (Strategic Policy) All development proposals will be considered against the NPPF, including application of the sequential test Policy 59: Low carbon and renewable energy (Strategic Policy) states we aim to increase the supply of low carbon and renewable energy, which is essential to meet commitments to reducing carbon emissions and combatting the effects of climate change. Policy 60: Wind energy developments (Strategic Policy), seeks to provide appropriate locations for renewable wind energy. Policy 61: Protecting and enhancing Doncaster’s soil and water resources, the policy protects the best and most versatile agricultural land and ensures developments should not impact on water quality or harm aquifers and identifies the need for flood storage. Policy 64: Reclamation of Mineral Sites ensures that mineral extraction sites in biodiversity opportunity areas will direct reclamation towards the UK Biodiversity Action Plan priority habitats indicated in Policy 30 as a priority for that area.

Paragraph 148. The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.

Chapter 10: Green Infrastructure (and aiding resilience to climate change), Policy 27: Green Infrastructure (A. 9 and 10 specifically). Policy 30: Ecological Networks, Policy 31: Ecological Networks, Policy 32: Local Wildlife and Geological Sites, Policy 33: Woodlands, Trees and Hedgerows and Policy 34: Landscape (Strategic Policy) Policy 43 encourages developments to reduce carbon emissions, adapt to climate change and make efficient use of natural resources during construction and operation through measures such as orientation, layout, inclusion of technology and material selection (B.11) Policy 45: Residential Design (Strategic Policy) states New housing, extensions, alterations and changes of use to housing will be

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

supported where (B.11) …flood resistance and resilience measures with an allowance for climate change are incorporated if located in, or adjacent to, flood risk areas See also chapter 14 and policies 57 to 61 (see section 1 above)

Paragraph 149. Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change4, water

supply, biodiversity and landscapes, and the risk of overheating from rising temperatures5. Policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.

Chapter 10: Green Infrastructure (and aiding resilience to climate change) Policies 27 to 34 (see above) Chapter 14 Climate Change, Minerals, Resources & Energy and policies 57 to 61 (see above)

Sufficiently covered – Yes

Paragraph 150. New development should be planned for in ways that:

a) avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure; and

b) can help to reduce greenhouse gas emissions, such as through its location, orientation and design. Any local requirements for the sustainability of buildings

Application of policies 57 and 58 will address the issue of areas vulnerable to flooding and provide for appropriate adaption and mitigation measures. Policies in chapter 10 Green Infrastructure, recognises the role of green infrastructure in supporting healthy communities, cultural value, a buoyant economy and aiding resilience to climate change. Policy 27 states ‘ We will protect, maintain, enhance and, where possible, extend Doncaster’s green infrastructure, including landscapes, natural environment, open spaces, public rights of way, geodiversity, biodiversity, navigable river and waterway assets…’ See chapter 12 Design and the Built Environment policies 43, 45, 47 (see above)

Sufficiently covered – Yes

4 Not relevant to Doncaster

5 In line with the objectives and provisions of the Climate Change Act 2008.

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Paragraph 151. To help increase the use and supply of renewable and low carbon energy and heat, plans should:

a) provide a positive strategy for energy from these sources, that maximises the potential for suitable development, while ensuring that adverse impacts are addressed satisfactorily (including cumulative landscape and visual impacts);

b) consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development; and

c) identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.

Policy 59 Low Carbon and Renewable Energy (Strategic Policy) (parts A and B) aims to increase the supply of low carbon and renewable energy generated in the borough and part C of the policy provides a positive strategy for increasing supply which includes decentralised heat and power networks. Policy 60 identifies suitable locations for wind energy developments

Sufficiently covered – Yes

Paragraph 152. Local planning authorities should support community-led initiatives for renewable and low carbon energy, including developments outside areas identified in local plans or other strategic policies that are being taken forward through neighbourhood planning.

No neighbourhood plans have yet incorporated renewable or low carbon community-led initiatives in to their plans. However, policies 59 and 60 of the local plan aims to increase the supply of low carbon and renewable energy generated in the borough and provide a framework for Neighbourhood Plans to develop specific policies if desirable. Bawtry NP has a policy on reducing carbon emissions and improving sustainable design

Sufficiently covered – Yes

Flood Risk… Paragraph 155. Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at

Application of policies 57 and 58 will address the issue of areas vulnerable to flooding and provide for appropriate adaption and mitigation measures.

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

highest risk (whether existing or future). Where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere. 156. Strategic policies should be informed by a strategic flood risk assessment, and should manage flood risk from all sources. They should consider cumulative impacts in, or affecting, local areas susceptible to flooding, and take account of advice from the Environment Agency and other relevant flood risk management authorities, such as lead local flood authorities and internal drainage boards.

Policy 45 requires flood resistance and resilience measures with an allowance for climate change are incorporated if located in, or adjacent to, flood risk areas. Evidence base provided by EA ‘Strategic Flood Risk Assessment (Level 1) 2015’ and ‘Strategic Flood Risk Assessment (Level 2) 2016’

Paragraph 157. All plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of climate change – so as to avoid, where possible, flood risk to people and property. They should do this, and manage any residual risk, by: a) applying the sequential test and then, if necessary, the exception test as set out below; b) safeguarding land from development that is required, or likely to be required, for current or future flood management; c) using opportunities provided by new development to reduce the causes and impacts of flooding (where appropriate through the use of natural flood management techniques); and d) where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to relocate development, including housing, to more sustainable locations.

Policies 58 flood risk management and application of NPPF criteria. Policy 58 states ‘All development proposals will be considered against the NPPF, including application of the sequential test and, if necessary, the exception test…’ Paragraph 4.17 Flood Risk

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

NPPG

Why is it important for planning to consider climate change? In addition to supporting the delivery of appropriately sited green energy, effective spatial planning is an important part of a successful response to climate change as it can influence the emission of greenhouse gases. In doing so, local planning authorities should ensure that protecting the local environment is properly considered alongside the broader issues of protecting the global environment. Planning can also help increase resilience to climate change impact through the location, mix and design of development. Addressing climate change is one of the core land use planning principles, which the National Planning Policy Framework expects to underpin both plan-making and decision-taking. To be found sound, Local Plans will need to reflect this principle and enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework. These include the requirements for local authorities to adopt proactive strategies to mitigate and adapt to climate change in line with the provisions and objectives of the Climate Change Act 2008, and co-operate to deliver strategic priorities which include climate change. In addition to the statutory requirement to take the Framework into account in the preparation

Various policies within the plan help increase resilience to climate change (see section 1 and comments on associated policies). Allocations are to be provided in the most sustainable locations in line with assessment work and provide a mix of development. Policy 59 identifies support for low carbon and renewable energy proposals and locations for ‘Heat Opportunity Areas’ and policy 60 identifies suitable locations for wind energy developments. The Local Plan reflects the principle of sustainable development in accordance with the NPPF (see comments section 1 above) Following on from the production of the evidence base document ‘Doncaster Renewable and Local Carbon Energy_2003’ the council will need to produce and adopt a proactive strategy to mitigate and adapt to climate change in line with the objectives of the Climate change Act 2008

Sufficiently covered – Yes Sufficiently covered – Yes subject to the Council developing and producing an updated Environment Strategy and a climate change adaption and mitigation strategy. (Alan Wiltshire) Emailed colleagues (06/08/19) in Strategy & Performance Unit with regard to the need to provide for a strategy to mitigate and adapt to climate change in line with climate change legislation

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

of Local Plans, there is a statutory duty on local planning authorities to include policies in their Local Plan designed to tackle climate change and its impacts. This complements the sustainable development duty on plan-makers and the expectation that neighbourhood plans will contribute to the achievement of sustainable development. The National Planning Policy Framework emphasises that responding to climate change is central to the economic, social and environmental dimensions of sustainable development. Paragraph: 001 Reference ID: 6-001-20140306 Revision date: 06 03 2014

See response in respect of NPPF paragraph 15 (row ) (and references to policies 1, 4, 27 to 34, 43, 45, 57 to 61)

What climate change legislation should planners be aware of? Section 19(1A) of the Planning and Compulsory Purchase Act 2004 requires local planning authorities to include in their Local Plans “policies designed to secure that the development and use of land in the local planning authority’s area contribute to the mitigation of, and adaptation to, climate change”. This will be a consideration when a Local Plan is examined. The Climate Change Act 2008 establishes a legally binding target to reduce the UK’s greenhouse gas emissions by at least 80% in 2050 from 1990 levels. To drive progress and set the UK on a pathway towards this target, the Act introduced a system of carbon budgets including a target that the annual equivalent of the carbon budget for the period including 2020 is at least 34% lower than 1990.

We believe the policies in the plan secure sustainable development and contribute to the mitigation of, and adaptation to, climate change. See comments in section one above. Sheffield City Region are in the process of identifying the regions carbon budget and this will be available in the new year. Doncaster is as yet to comment on this information.

Sufficiently covered – Yes In progress. The Sheffield City Region Energy Strategy will be presented to the Mayoral Combined Authority Board in March 2020 and, if adopted, will be published in Spring 2020

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

The Climate Change Act 2008 also requires the government:

to assess regularly the risks to the UK of the current and predicted impact of climate change;

to set out its climate change adaptation objectives; and

to set out its proposals and policies for meeting these objectives.

These requirements are fulfilled by the UK climate change risk assessment and the National adaptation programme report respectively, which may provide helpful information for plan-making. Paragraph: 002 Reference ID: 6-002-20140306 Revision date: 06 03 2014

How can the challenges of climate change be addressed through the Local Plan? There are many opportunities to integrate climate change mitigation and adaptation objectives into the Local Plan. Sustainability appraisal can be used to help shape appropriate strategies in line with the statutory duty on climate change and ambition in the Climate Change Act 2008. Examples of mitigating climate change by reducing emissions:

Reducing the need to travel and providing for sustainable transport

Providing opportunities for renewable and low carbon energy technologies

Providing opportunities for decentralised energy and heating

See response to paragraph 15 section one (and references to policies 1, 4, 27 to 34, 43, 45, 57 to 61) See Policies 13, 14, 17 and 18 (strategic transport network, promoting sustainable transport in new developments, cycling and walking in Doncaster) See policies 59 and 60, low carbon and renewable energy and evidence base Doncaster Renewable and Low Carbon Study highlights the key opportunities for different forms of renewable energy in the Borough. The Landscape Character and Capacity

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Promoting low carbon design approaches to reduce energy consumption in buildings, such as passive solar design

Examples of adapting to a changing climate:

Considering future climate risks when allocating development sites to ensure risks are understood over the development’s lifetime

Considering the impact of and promoting design responses to flood risk and coastal change for the lifetime of the development

Considering availability of water and water infrastructure for the lifetime of the development and design responses to promote water efficiency and protect water quality

Promoting adaptation approaches in design policies for developments and the public realm

Engaging with appropriate partners, including utility providers, communities, health authorities, regulators and emergency planners, statutory environmental bodies, Local Nature Partnerships, Local Resilience Forums, and climate change partnerships will help to identify relevant local approaches. Paragraph: 003 Reference ID: 6-003-20140612 Revision date: 12 06 2014 See previous version

Study also assesses the potential of the landscape to accommodate wind energy developments and biomass / woodland crops Sites have been allocated that avoid flood risk areas where possible or appropriate mitigation can be achieved. Policy 61: Protecting and enhancing Doncaster’s soil and water resources, ensuring developments should not impact on water quantity or harm aquifers and identifying the need for flood storage. See Statement of Community Involvement which identifies partners, utility providers, statutory environmental bodies, local nature partnerships… so on

How can adaptation and mitigation approaches be integrated?

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

When preparing Local Plans and taking planning decisions local planning authorities should pay particular attention to integrating adaptation and mitigation approaches and looking for ‘win-win’ solutions that will support sustainable development. This could be achieved in a variety of ways, for example:

by maximising summer cooling through natural ventilation in buildings and avoiding solar gain;

through district heating networks that include tri-generation (combined cooling, heat and power); or

through the provision of multi-functional green infrastructure, which can reduce urban heat islands, manage flooding and help species adapt to climate change – as well as contributing to a pleasant environment which encourages people to walk and cycle.

Local planning authorities should be aware of and avoid the risk of maladaptation (adaptation that could become more harmful than helpful). For example, designing buildings to maximise solar gain in winter without thinking through the implications for overheating in summer. Sustainability appraisal and, where required, Environmental Impact Assessment, can be useful for testing the integration of mitigation and adaptation measures and the long term implications of decisions. Paragraph: 004 Reference ID: 6-004-20140612 Revision date: 12 06 2014 See previous version

The theme of climate change runs throughout the Local Plan, with policies identifying specific requirements in specific policies. See response to paragraph 15 in section one. Chapter 12 Design and the Built Environment policies 43, 45, 47 (see above) The use of current building regulations Policy 59: Low Carbon and Renewable Energy (Strategic Policy) Chapter 10 and associated policies in this chapter Carried out by independent consultants. The Local Plan has been subject to Sustainability Appraisal throughout its preparation to assist in achieving the preservation, protection and improvement of the environmental, social and economic state of the Borough. The appraisal has met the requirements of Strategic Environmental Assessment (SEA). The SA Report sets out issues that impact on sustainability, sets out the effects of “reasonable” alternatives to the Plan’s strategy and

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

proposals, the reasons for discounting alternatives, and the likely significant effects of the Plan’s preferred sites and policies. The Report outlines mitigation which has been incorporated into the Plan to avoid, minimise and compensate for negative effects and maximise positive effects. It also proposes monitoring so that the effects of the Plan can be tracked and any unforeseen effects addressed.

How can planning deal with the uncertainty of climate risks when promoting adaptation in particular developments? The impact of climate change needs to be taken into account in a realistic way. In doing so, local planning authorities will want to consider:

identifying no or low cost responses to climate risks that also deliver other benefits, such as green infrastructure that improves adaptation, biodiversity and amenity

building in flexibility to allow future adaptation if it is needed, such as setting back new development from rivers so that it does not make it harder to improve flood defences in future

the potential vulnerability of a development to climate change risk over its whole lifetime

Paragraph: 005 Reference ID: 6-005-20140306 Revision date: 06 03 2014

Audit and Strategy evidence base to be developed but the council’s Strategy and Performance Unit

Sufficiently covered – Yes

What evidence of risks arising from climate change is available to support local plan-making? Climate change risk assessments can support the production of Local Plans by informing the Sustainability appraisal.

Carried out by independent consultants. The Local Plan has been subject to Sustainability Appraisal throughout its preparation to

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Local risk assessments can be used to identify those climate risks, including those arising from severe weather events, the planning system can address. Risk assessments could consider the implications for the built environment and development, infrastructure, services and biodiversity, and their subsequent implications for vulnerable groups and community cohesion. Identifying those impacts which pose most potential risk or disruption to the provision of local services will enable vulnerability to be assessed and areas suitable for development to be identified and adaptation responses to be put in place. Other parts of a Local Plan’s evidence base will also include information on climate change risks, such as the Strategic Flood Risk Assessment and Water Resource Management Plan and water cycle studies. Infrastructure providers hold information on the extent of supply and network constraints and their existing plans to reinforce those networks and capacity. Other service providers may also have carried out risk assessments that have implications for planning, such as health and social service providers. Local studies can also be undertaken to provide a more detailed assessment of local vulnerability to climate impacts and the effects of extreme weather events. Paragraph: 006 Reference ID: 6-006-20140306 Revision date: 16 11 2016 See previous version

assist in achieving the preservation, protection and improvement of the environmental, social and economic state of the Borough. The appraisal has met the requirements of Strategic Environmental Assessment (SEA). Evidence base provided by EA ‘Strategic Flood Risk Assessment (Level 1) 2015’ and ‘Strategic Flood Risk Assessment (Level 2) 2016’. Water resource management plans are produced by the Water Authorities (Yorkshire Water, Trent Water and Anglian Water (who have a very small resource management area in Doncaster)

How can local planning authorities identify appropriate mitigation measures in plan-making?

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Every area will have different challenges and opportunities for reducing carbon emissions from new development such as homes, businesses, energy, transport and agricultural related development.

Robust evaluation of future emissions will require consideration of different emission sources, likely trends taking into account requirements set in national legislation, and a range of development scenarios.

Information on carbon emissions at local authority level has been published by the government for 2005 onwards, and can be drawn on to inform emission reduction options. Information is also available on GOV.UK on how emissions are reported against the national target to reduce the UK’s greenhouse gas emissions by at least 80% (from the 1990 baseline) by 2050.

The distribution and design of new development and the potential for servicing sites through sustainable transport solutions, are particularly important considerations that affect transport emissions. Sustainability appraisal should be used to test different spatial options in plans on emissions.

Different sectors may have different options for mitigation. For example, measures for reducing emissions in agricultural related development include anaerobic digestion, improved slurry and manure storage and improvements to buildings. In more energy intensive sectors, energy efficiency and generation

Appropriate mitigation measures are identified throughout the local plan. The level of mitigation will be determined by the carbon budget once set by the authority.

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

of renewable energy can make a significant contribution to emissions reduction.

Paragraph: 007 Reference ID: 6-007-20140306 Revision date: 06 03 2014

What are government’s national standards for a building’s sustainability and for zero carbon buildings? The National Planning Policy Framework expects local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy and adopt nationally described standards. Local requirements should form part of a Local Plan following engagement with appropriate partners, and will need to be based on robust and credible evidence and pay careful attention to viability. In this respect, planning authorities will need to take account of government decisions on the Housing Standards Review when considering a local requirement relating to new homes. If considering policies on local requirements for the sustainability of other buildings, local planning authorities will wish to consider if there are nationally described standards and the impact on viability of development. Further guidance can be found under Viability. Paragraph: 009 Reference ID: 6-009-20150327 Revision date: 27 03 2015 See previous version

Chapter 12 Design and the Built Environment policies 43, 45, 47 (see above) Policy 46: Housing Design Standards is based upon the evidence set out in the Housing Standards evidence document and the findings of the viability assessment which demonstrates the need for the standards in policy 46 and the findings of the viability assessment evidence base indicate the requirements will not make development unviable.

Sufficiently covered – Yes

Can a local planning authority set higher energy performance standards than the building regulations in their local plan?

Sufficiently covered – Yes

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Different rules apply to residential and non-residential premises. In their development plan policies, local planning authorities:

Can set energy performance standards for new housing or the adaptation of buildings to provide dwellings, that are higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes.

Are not restricted or limited in setting energy performance standards above the building regulations for non-housing developments.

The Planning and Energy Act 2008 allows local planning authorities to set energy efficiency standards in their development plan policies that exceed the energy efficiency requirements of the building regulations. Such policies must not be inconsistent with relevant national policies for England. Section 43 of the Deregulation Act 2015 would amend this provision, but is not yet in force. The Written Ministerial Statement on Plan Making dated 25 March 2015 clarified the use of plan policies and conditions on energy performance standards for new housing developments. The statement sets out the government’s expectation that such policies should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes (this is approximately 20% above current Building Regulations across the build mix).

Policy 47 states new major non-domestic applications (1000m2 floor space or more, or a site of 1 hectare or above) must meet the BREEAM rating of at least ‘Very Good’, or any agreed equivalent standard, and secure at least 10% of their regulated energy from renewable sources (or equivalent carbon emission reductions)- part B of policy. The Planning Authority is not currently proposing to set energy efficiency standards or renewable energy requirements above those identified in building regulations for housing as this should be set at a national level through building regulations, as is the Government’s favoured approach.

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Climate Change Issue / Topic Area Publication Local Plan and draft policy Assumption

Provisions in the Planning and Energy Act 2008 also allow development plan policies to impose reasonable requirements for a proportion of energy used in development in their area to be energy from renewable sources and/or to be low carbon energy from sources in the locality of the development. Paragraph: 012 Reference ID: 6-012-20190315 Revision date: 15 03 2019 Published 12 June 2014 Last updated 15 March 2019 + show all updates

Policy 47: Design of Non-Residential, Commercial and Employment Developments (Strategic Policy), Part B requires non-domestic proposals to secure at least 10% of their regulated energy from renewable sources (or equivalent carbon emission reductions).

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References:

Air Quality and Climate Change: A UK Perspective - https://uk-air.defra.gov.uk/assets/documents/reports/aqeg/fullreport.pdf

Net -Zero North – Delivering the Decarbonisation Mission in the North of England December 2017: Institute of Public Policy Research; Laurie

Laybourn-Langton, Joshua Emden, Darren Baxter, and Hywel Lloyd

Sheffield City Region Energy Strategy

Doncaster’s Inclusive Growth Strategy

Green Infrastructure Strategy

Progress in Preparing for Climate Change – 2019 Report to Parliament

National Planning Policy Framework

National Planning Practice Guidance – Climate Change

Planning and Compulsory Purchase Act

Climate Change Act 2008 (2019 update)

United Nations Climate Change Conference 2015

Progress in preparing for climate change – 2019 Progress Report to Parliament