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Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Representation ID: 3766

Received: 05/02/2023

Respondent: Mr Joseph O'Sullivan

Representation Summary:

A climate emergency is real.

Full text:

A climate emergency is real

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Representation ID: 4975

Received: 17/03/2023

Respondent: Kingsbridge Estates Limited & Landlink Estates Limited

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Local Plan does not fully take opportunities to align with the government’s net zero commitments, as it fails to take opportunities to reduce greenhouse gas emissions through a positive approach to locating functional development within HDAs

Change suggested by respondent:

Reference to ‘ancillary’ with regard to the HDAs in relevant policies and supporting text should be modified to 'functionally linked' and include explanatory text clarifying that 'functionally linked' uses can include a range of activities including: food-related distribution; food manufacturing linked to the HDAs food preparation; on-site renewable energy to serve on-site activities; and R&D.

Full text:

The Council’s declaration of a climate emergency is welcomed, however there is an opportunity to better align this the Council’s economic strategy within the Local Plan.

Supporting the growth of the horticultural industry to include functionally linked uses, such as food processing/production and consolidated storage and distribution capabilities within the HDA, would allow for greater food production on site. This in turn would allow for greater home grown food production and export to the rest of the UK. Accordingly, there would be a reduction in food miles as home-grown food consumption would increase. This would lead to a reduction in greenhouse gas emissions.

Refer to Savills SREBR para 4.4.2 – effective storage and distribution hub at Runcton HDA would achieve reduction in food miles by 84000 per annum

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Representation ID: 5352

Received: 17/03/2023

Respondent: Landlink Estates Ltd

Agent: Jackson Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council position does not comply with Section 19(1A) of the PCPA 2004, which requires Local Plan policies to be designed to secure that the development and use of land in the LPA's area contribute to the mitigation of, and adaptation to, climate change.

The plan has failed to demonstrate a vision of how to achieve net zero by 2050,or decarbonise power systems by 2035 in line with the Climate Change Act 2008 and ongoing ambitions towards Net Zero.

The 2008 Climate Change Act sets a legally binding target to reduce net greenhouse gas emissions from their 1990 level by 100% by 2050. The plan does not demonstrate how this is achieved and is not legally compliant.

Change suggested by respondent:

Withdraw plan and rework to ensure priority given to climate change, especially in relation to land use implications and climate mitigations. Propose an additional strategic overarching policy to deliver Net Zero and secure sustainable development to make the Plan sound. Suggested wording as follows:

Additional Strategic Policy 01 - Delivering Net Zero.
The Council will support growth and change that delivers a more sustainable, low carbon future for Chichester District, reflecting the Government’s legal Net Zero targets and the Council’s declared climate emergency (July 2019). The ambition is to reduce levels of carbon emissions by X%* at the end of the plan period.

Climate change mitigation is required in all relevant policy areas, including sustainable travel, net zero buildings, energy and water efficiency, renewable energy production and energy storage, and also supporting the circular economy and green infrastructure through the protection of carbon sinks and opportunities for
carbon sequestration.

Development and change will be planned for and managed in accordance with the following principles of sustainable development:

1. All development will contribute to achieving net zero by 2050 as follows (demonstrated through an energy calculation):

• No on-site fossil fuel combustion;
• Energy use is minimised, demonstrated through space heating demand of less than 15kWh/m2 /year and operational energy use of less than 35kWh/m2 /year for dwellings; or demonstrated by using BREEAM Excellent level accreditation, with outstanding level for energy use (Credit Ene01) or equivalent for non-residential
development;
• On-site renewable generation is maximised, equivalent to at least the on-site energy demand.
• Where the above criteria cannot be met, due to exceptional circumstances set out in support of the development, the proposal must deliver equivalent carbon reductions through off-site
measures;

2. The effective use of land is made for development through optimising reuse of previously developed sites and buildings, therefore reducing the need for greenfield development and retaining embedded carbon where viable;

3. Supporting embedded and free-standing renewable energy development and de-carbonisation of the District as set out in policy NE1 and as defined in the site allocations DPD which will identify the necessary range of suitable sites for renewable energy to meet the legal climate obligations.

*The percentage reduction in carbon emissions to 2039 (end of the plan period) needs to be calculated by CDC from the 1990 baseline. CDC's current Climate Change Action Plan targets stop at 2025.

Full text:

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