MM27.

p75 SP10 Why has all reference to an expectation for developers taking proactive approach to tackling Climate change been removed? We would consider that since the UK appears to be behind the required curve of climate change improvement that any proactive approach, beyond what is required, is a very good thing.

The policies concerning Climate Change SP10 and Sustainable Construction and Design LP23 lack ambition and are totally inadequate in respect of achieving the required net zero target set by Babergh District Council to be achieved by 2030. They pay lip service to “the idea” and as drafted are not sufficiently demanding in their requirements of those delivering developments over the period of the plan. Words such as “where appropriate”, “when practicable”, “minimise dependence on fossil fuels”, “encourage a proactive approach to improve on building regulation requirement” are just a few examples and which in a policy context will enable those who have no regard for implementing the step changes required will drive a coach and horse through these policies as drafted.

The policies concerning Climate Change SP10 and Sustainable Construction and Design LP23 lack ambition and are totally inadequate in respect of achieving the required net zero target set by Babergh District Council to be achieved by 2030. They pay lip service to “the idea” and as drafted are not sufficiently demanding in their requirements of those delivering developments over the period of the plan. Words such as “where appropriate”, “when practicable”, “minimise dependence on fossil fuels”, “encourage a proactive approach to improve on building regulation requirement” are just a few examples and which in a policy context will enable those who have no regard for implementing the step changes required will drive a coach and horse through these policies as drafted.

See full representation

Pigeon supports the inclusion of a policy on climate change within the JLP but note that a number of modifications have been made to this policy. Pigeon’s concern relates to the impact of these requirements on the future viability of developments and their ability to deliver all of the policy requirements set out within this Plan. As part of the evidence base for the Plan, the whole plan viability study does not appear to have been updated to include the requirements of the main modifications to assess the implications for all of these requirements.

With specific reference to this policy, criterion 1(a) of the policy should be ‘informed by’ rather than being required to ‘adopt’ a sequential risk-based approach. This is because it has the potential to significantly restrict development opportunities and viability. In addition, criterion 1(b) requires development to conform to the principle of Holistic Water Management. Whilst Pigeon is supportive of this water management approach, as set out in paragraph 15.59 of the Plan, Suffolk has been designated as a pilot catchment area for testing this innovate approach to reforming water abstraction. As it is a pilot project, with no certainty on whether it will become a permanent project as it may not be appropriate, Pigeon would object to the requirement to conform to it on the basis that it is not yet justified. Pigeon would suggest that conforming to Building Regulations and/or the Future Homes Standards would be sufficient and achieve the same outcome for the Councils with regard to this approach.

Subject to including the suggested wording to address these two points, Pigeon is supportive of this policy.

The inclusion of ‘where appropriate’ in the proposed modification is an important addition to recognise that
dependent on the scale and low carbon energy technology choice, be it generation, storage or transmission, a
development proposal that allows for a wholly decentralised energy system is not always possible, however
proposals that demonstrate consideration of energy supply and security for the locality should be welcomed.

This document responds to the Main Modifications pertinent to the Taiyo portfolio and aspirations
within the Councils jurisdictions, principally the promotion of solar farms, and their contribution to the
government target of 70 GW of solar generation capacity by 20351
. The Main Modifications (“MM”)
and Additional Modifications (“AM”) that this document responds on are as follows:
• MM19 Economic Growth, Chapter 10, supporting policy SP05 and AM55;
• MM23 Strategic Infrastructure Provision Policy SP08;
• MM26 Enhancement and Management of the Environment Policy SP09;
• MM27 Climate Change Policy SP10;
• MM42 Supporting a Prosperous Economy Policy LP09;
• MM49 Environmental Protection and Conservation Policy LP15; and
• MM60 Energy Sources, Storage and Distribution Policy LP25.

Please see attached document.

The following wording is suggested, to ensure sustainable development is achieved:
e. Identifying opportunities, where appropriate, for additional tree planting and shelter in public realms.

MM27: Policy SP10
SCC largely accept the changes to this policy. However, we note that the entirety of part a. has been removed. Whilst SCC finds most of the omissions acceptable as they are addressed later within the policy, we are concerned with the loss of wording around the requirement for additional tree planting. As identified within paragraph 131 of the NPPF, tree planting plays an important role in climate change mitigation, through both carbon capture and storage, as well as provision of shade and shelter in public realms.
The following wording is suggested, to ensure sustainable development is achieved:
e. Identifying opportunities, where appropriate, for additional tree planting and shelter in public realms.

Please see attached full document.

Please see attached full document