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Dorset Council Consultation: Planning for climate change guidance

5th June 2023

Dorset CPRE's response to Dorset Council's consultation on guidance considering climate change in planning applications.

The three Dorset Council documents on Interim guidance and position statement, Sustainability checklist and Listed buildings provide guidance considering climate change in planning applications. The documents are to support decision making until the new DC Local Plan is adopted. The consultation is open until 8th June.

All three Dorset CPRE response documents are listed at the end of this page.

Here is a summary of the key points raised in our responses: 

Interim guidance and position statement
This is to help decision makers weigh up the benefits of addressing climate change with other material considerations. It addresses sustainable design and construction and planning for renewable energy schemes.

Dorset CPRE's top 3 summary response points:

We commend DC for recognising the importance of planning in tackling climate change and for attempting to set out clear guidance in this document, especially since the new Local Plan is not expected to be adopted until 2026 or later. However:

1. The documents are only advisory and so are likely to be ignored especially by the large developers with powerful lobbies and finances to challenge local government decisions. Dorset Council could make the sustainability checklist compulsory and make use of Planning Conditions to enforce higher standards than set at national level. For example, developing more PV solar on roofs should be a good thing not only because it provides locally-sourced renewable energy but because it also removes some of the strain on the National Grid. A written opinion dated April 2023 by a barrister for Essex CC makes it clear that local planning authorities have the power to set higher emissions standards for buildings than required nationally. 

2. Ecological and biodiversity loss are not specifically addressed in the Planning Statement and checklist (1.1.3, 1.1.26). This is disappointing and misses a great opportunity to ensure that these highly sensitive issues are considered and discussed early and openly in the planning process.

3. Similarly, the Planning Statement and checklist do not address transport or infrastructure issues related to climate change (1.1.26). This is not good enough. Too many developments are built without any consideration of the impact of transport on climate change and provide no public transport services forcing new residents to use private cars to access facilities and services.

Read our full response.

Sustainability checklist
This sets out questions for applicants to check in relation to their schemes’ sustainable design and construction.

Dorset CPRE's top 3 summary response points:

We commend DC for their preparation of a sustainability checklist for planning policy in respect of planning applications.

1. However, sustainable planning policy in Dorset should we believe be mandatory in terms of requirements as opposed to a guidance “check/wish list” in order to have teeth and be effective to achieve government targets.

We are of the opinion that DC does not go far enough in terms of ambition and timescale since we are in a “Climate Crisis”. We also need to achieve the requirements of the Central Government commitment made at COP26 to achieve a 68% reduction in carbon emissions by 2030.

2. Other councils are already mandating Whole Life Carbon (WLC) assessments of their own accord ahead of central government direction. Evidence so far shows that the policy is achievable and is working, with few barriers to its introduction. Introducing mandatory WLC assessments for buildings could be an easy way for DC to substantially reduce carbon in construction in Dorset.

3. In terms of overarching policy context, we conclude that although the suggested policy framework, ambition and wording are welcome,  these need to be translated into actions by Dorset Council and that this means driving standards and internal targets up to and beyond those adopted nationally.

Read our full response.

Listed buildings
This is to help householders with what they can do to increase energy efficiency in their listed buildings and understand what they would need consent for.

Dorset CPRE's top 3 summary response points:
Praise should be given to DC for the work they have done bringing their own buildings up to a good heat loss standard.

1. Suggest section 2.4 on Quick Wins be expanded. One suggestion would be to add window film insulation for use on wooden or metal windows, which is cheap, effective and usually easy to install.

2. On section 3.7 Can I install double glazing in my listed building? This is probably the one major action that could have a positive impact on the heat efficiency of a listed building and improve the comfort, EPC rating and reduce the cost of heating to the residents. We understand that stone mullion windows or ‘historic’ glass etc. has to be protected from harm however if there is a balance it does need to move to providing a sensible solution where windows need major repair. However the majority of domestic listed buildings have wooden windows, and there are available Historic England approved designs for double glazing.

3. More detailed guidelines on a more positive approach to repairing and maintaining listed and Conservation Area windows would be welcome.

Read our full response.

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