CLIMATE ACTION
INTRODUCTION
3.1 As this is a Review of an existing award-winning Local Plan, policies have only been changed where there are strong reasons to do so. These reasons include:
Changes to national policy and legislation which might impact the previous findings of the Planning Inspector that these policies were ‘sound’ (i.e passed all the legal and policy tests at the last Local Plan examination in 2018);
Changes to the National Park Authority’s own priorities and objectives;
New issues that have arisen since the last Local Plan was adopted (such as nutrient and water neutrality and the growth of viticulture); and
Difficulties encountered in implementing the adopted policies which could be resolved by clarifying wording.
3.2 Where possible policy numbers have been kept the same as in the existing Local Plan to make it easier for people to see what we are proposing to change, however we have regrouped some of these policies so that those most closely related are easier to find. This means that the policy numbers are not always in order. We are not including supporting text at this time but will be adding some back in at the next stage where necessary to explain how to apply policies or to signpost other relevant policies. Proposed policy wording is preceded by a table as below.
Policy Reference and Title
Change Category: No change/minor changes/substantial changes/full review/new policy
Key issues:
Supporting text:
Only included if there is any that needs to be flagged at this stage.
Future considerations:
Consultation questions:
POLICY TEXT:
Tracked changes compared to the adopted Local Plan (deleted text crossed through, new text underlined).
Policy SD48: Climate Change and Sustainable Use of Resources
Change Category: Full Review
Key issues:
Corporate priority for climate action
Net Zero 2040 target within the plan-period
Need to address embodied carbon
Need for greater emphasis on climate change adaptation as well (especially water usage and summer overheating)
Future issues:
Likely to be a National Development Management Policy on this issue
National standards for carbon accounting in preparation
Targets and standards likely to change before next review of the SDLP in 2032 so need to make flexible enough not to go out of date.
Supporting text:
Include definition of ‘multi-residential’ development – such as older person’s accommodation or student flats etc. which have shared facilities.
Refer to higher water efficiency standards applicable in the Sussex North Water Neutrality Zone and provide cross-reference to that policy.
Include definition of HCFC.
Consultation questions:
What are your views on Policy SD48? Strongly agree/agree/neutral/disagree/ strongly disagree
Please expand on your answer to the above
Are the standards in this policy appropriate, legible for applicants and decisionmakers and likely to be relevant until 2032 (when this Local Plan is likely to be reviewed)?
Should the policy cross-refer to the UK Net Zero Carbon Buildings Standard?
Is criteria 2 on embodied carbon appropriate? Should small-scale development (<10 units or <1,000sqm) be required to prepare an embodied carbon assessment, without setting a specific target for upfront embodied carbon emissions?
STRATEGIC POLICY SD48: CLIMATE CHANGE AND SUSTAINABLE USE OF RESOURCES
1. All new build development proposals will be required to achieve net zero operational carbon by applying the minimum standards below unless it can be demonstrated that doing so is not technically feasible or would make the scheme unviable. The following standards will apply:
a) For all residential development of one dwelling or more:
i) Low Energy Transformation Initiative (LETI) 2030 Design Standards for space heating (≤15kWh/m2/yr) and total energy demand (≤35 kWh/m2/yr) must be achieved.
ii) A nationally recognised energy model must be used to demonstrate compliance with this standard, such as Passive House Planning Package (PHPP) or Chartered Institution of Building Services Engineers (CIBSE) TM54 (or accepted equivalent).
b) For all major non-residential and multi-residential development:
i) BREEAM excellent cer tification (or equivalent) shall be demonstrated.
ii) Maximum standards for space heating (≤ 20kWh/m2/yr) and total energy demand (≤ 70 kWh/m2/yr) must be achieved.
c) For all residential and major non-residential and multi-residential development:
i) Fossil fuels should be avoided for operational energy and measures such as battery storage used where practical to reduce the burden on the National Grid;
ii) Net zero carbon should be achieved (where possible, on-site) by energy from renewables matching total energy demand; and
iii) Where, for agreed technical reasons, there is a shortfall in reaching net zero operational carbon on-site, exceptionally this could be made up through financial contributions to a Carbon Fund administered by the Authority.
d) All non-residential extensions and refurbishment projects of 250 sqm or above must achieve the relevant BREEAM refurbishment excellent standard certification (or agreed equivalent).
e) All new build residential developments of 20 homes or more or 2,500 sq m of commercial development must undertake a Post Occupancy Evaluation to a brief agreed with the Authority.
2. Development proposals must consider reducing high embodied carbon materials, and maximising the use of low embodied carbon materials, and the re-use of reclaimed materials, including by:
a) Considering the re-use of existing site buildings, structures, hard surfaces and infrastructure;
b) Where demolition and replacement are proposed, justification must be provided as to why the loss of embodied carbon is outweighed by other benefits; and
c) All major residential development must achieve ≤500kg CO2e/m2 and nonresidential and multi-residential development ≤750kg CO2e/m2 for upfront embodied carbon emissions.
3. All development proposals will be required to meet the following internal maximum water consumptions standards:
a) Residential and visitor accommodation: predicted mains water consumption ≤ 90 litres/person/day
b) Major non-residential development: Achieve at least 70% of available BREEAM Water credits.
4. All development proposals should use sustainable materials such as:
a) Timber from sustainably managed sources (preferably locally grown);
b) Insulation products which avoid HCFC-based materials; and
c) Minimising construction and operational waste.
5. For all development proposals which involve the change of use or redevelopment of a building, or an extension to an existing building, the applicant is encouraged to consider all opportunities to improve the energy efficiency, overall carbon emissions, water consumption and embodied carbon across the planning unit.
Policy SD51: Renewable Energy
Change
Category: Substantial changes
Key issues:
Corporate priority for climate action
Net Zero 2040 target within the plan-period
Facilitate community energy proposals (SDNP Climate Action Plan)
South Downs Renewable Energy Study (LUC, 2024): www.southdowns.gov. uk/planning-policy/the-south-downs-local-plan-review/evidencebase/environment/renewable-energy-study/
Future considerations:
New NPPF proposed with potential increased presumption to permit renewable schemes
National Development Management Policies
Further technical work need on any allocations
Consultation questions:
What are your views on Policy SD51? Strongly agree/agree/neutral/disagree/ strongly disagree
Please expand on your answer to the above
Are there other appropriate potential sites for community-led renewable proposals? Please use the Call for Sites form to provide further details: www. southdowns.gov.uk/planning-policy/the-south-downs-local-planreview/evidence-base/homes-and-economy/land-availabilityassessment/submit-a-site/
DEVELOPMENT MANAGEMENT POLICY SD51: RENEWABLE ENERGY
1. Development proposals for renewable energy schemes, including small-scale solar arrays and wind turbines (up to 1MW), battery energy storage systems (BESS), biomass boilers, solar panels, hydropower and heat pumps except those specifically
addressed in Criterion 2, that contribute towards reducing greenhouse gas emissions and moving towards a carbon neutral National Park, will be permitted where it is demonstrated through suitable site specific analysis that the proposal:
a) Is appropriate in location, scale and design to its National Park context and the statutory purposes and special qualities of the South Downs National Park;
b) Does not result in significant adverse impacts on the local environment that can not be satisfactorily mitigated, including cumulative landscape and visual impacts;
c) Takes opportunities to retain agricultural use and other landscape functions on the site where relevant;
d) Makes provision for the removal of the facilities and reinstatement of the site, should it cease to be operational;
e) Ensures existing public access is not impeded; and
f) Does not result in the permanent loss in use of Grades 1, 2 or 3a agricultural land unless exceptionally justified or significant sustainability benefits are demonstrated to outweigh any loss.
2. Development proposals for small-scale individual wind turbines and freestanding solar arrays serving individual properties or small groups of properties will be permitted where:
a) They are suitably sited and clearly associated with the buildings that they are intended to serve and in the case of solar arrays, are suitably screened; and clearly associated with the buildings or properties that they are intended to serve;
b) They are appropriate in scale to the property buildings being served; and
c) There is no unacceptable adverse impact on local amenity or conflict with public safety.
3. Support will be given to renewable and low carbon energy generation developments that are led by, or meet the needs of local communities. The positive benefits of community energy schemes will be an important material consideration in assessing renewable energy development proposals. The preference is for schemes that are in line with the hierarchy and project attributes below: Community Led Energy:
i) Project part or fully owned by a local community group or social enterprise; or
ii) Local communit y members have a governance stake in the project or organisation e.g. with voting rights.
4. Development proposals for solar panels on existing roofs, car parks within settlements and brownfield land could be supported in principle subject to landscape and heritage considerations.
5. Renewable energy projects on the following sites as identified on the Policies Map will be supported in principle where they are community-led subject to further technical work on grid connections and impact on the National Park and neighbouring uses:
a) Land east of Langrish Primar y School – ground mounted solar arrays;
b) Tolmare Farm, Findon – rooftop solar;
c) Land at Longridge Avenue, Saltdean – ground mounted solar arrays; and
d) Land bet ween the A32 and Policeman’s Lane, West Meon – ground mounted solar arrays.
Policy SD14: Climate Change Mitigation and Adaptation of Historic Buildings
Change
Category: No change
Key issues:
Keep as separate policy or integrate with other heritage or climate policies?
Reference to HE and internal guidance?
Future considerations:
May be superceded by National Development Management Policies
Consultation questions:
What are your views on Policy SD14? Strongly agree/agree/neutral/disagree/ strongly disagree
Please expand on your answer to the above
DEVELOPMENT MANAGEMENT POLICY SD14: CLIMATE CHANGE MITIGATION AND ADAPTATION OF HISTORIC BUILDINGS
1. Development proposals will be permitted, and where relevant listed building consent granted, for works to heritage assets to adapt to, or mitigate the effects of, climate change where it can be clearly demonstrated that this is consistent with all of the following:
a) The preservation and enhancement of the heritage asset’s significance, character and appearance;
b) The preservation and enhancement of the heritage asset’s special architectural or historic interest;
c) The long-term preservation of the historic built fabric; and
d) The setting of the heritage asset.