Climate Change

Dover District Council declared a climate change emergency on the 4th November 2019 and the Council has an ambition to become a net zero carbon emitter by 2030.

This new Local Plan supports and helps to deliver the Council’s approach to the climate change emergency through a series of policies which aim to ensure that development proposals, which come forward between now and 2040, mitigate against and adapt to the effects of climate change.

Draft Climate Change Policies Map

What are the key issues to consider?

From initial consultation, and the evidence we have collected so far, we have identified the following key issues in respect to the mitigation of, and adaptation to, climate change:

Planning for Climate Change

The Climate Change Act 2008 (as amended) sets a legally binding target to bring all green house gas emissions to net zero by 2050. In line with this, the Council has declared a climate emergency with the intention of delivering a carbon neutral District by 2050.

Section 19(1A) of the Planning and Compulsory Purchase Act 2004 stipulates that development plan documents must (taken as a whole) include policies designed to ensure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change. Furthermore, the National Planning Policy Framework (NPPF:2019) states that Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures. The Council therefore has a legal duty to consider the mitigation of, and adaptation to, climate change as part of the Local Plan.

It is however important to recognise that planning is just one tool for addressing climate change, and it will therefore be important for us to work with our partners, and join with other strategies, to tackle climate change in a co-ordinated way, in order to have maximum effect.

Reducing Carbon Emissions

The government's proposed 2025 Future Homes Standard (FHS) was consulted on in late 2019 and early 2020. The aim of the FHS is to tighten the standards on energy efficiency and ventilation in new homes from late 2020 to bring the Building Regulations in line with the EU's Energy performance of buildings directive and to facilitate the delivery of homes that meet the FHS by 2025. The government's consultation set out two approaches to achieve this. Given the outcome of this consultation is unknown, a key issue for the Council is whether it should adopt the government's preferred approach at this stage, or wait for this to be clarified.

The government is also proposing to amend Part L2 of the Building Regulations covering non-domestic buildings, however this consultation is yet to be published.

Sustainable Design and Construction

The NPPF (2019) states that Plans should take into account the risk of overheating from rising temperatures. There are two types of overheating - the overheating of buildings, whereby the internal environment of a building becomes uncomfortably hot; and the wider scale overheating that occurs through the urban heat island effect. Overheating is likely to become a more frequent problem because of climate change, but also because of improvements to energy efficiency standards. Given this, design interventions will be required to allow passive cooling. Green and blue infrastructure can be used to both reduce heat build-up and allow ambient heat to escape. Urban trees can also provide shading that cools surfaces and reduces ambient air temperature through evaporation of water via the leaves.

A building’s carbon emissions can also result from indirect sources, such as the energy used to extract, grow or manufacture building materials, to transport materials and people involved in construction, and the energy used during construction. These emissions are often referred to as “embodied carbon”. As the operational carbon produced by buildings falls due to improving energy efficiency standards and a decarbonising energy supply, addressing embodied carbon emissions is likely to become more and more critical if carbon emissions are to continue to fall. Embodied carbon is not addressed by the building regulations. Given this it will be necessary to address this issue in a policy in the Plan.

Sustainable design and construction measures can often increase the cost of development. The provision of future homes standards and sustainable design and construction may need to be balanced against other priorities such as the provision of affordable housing, due to the potential impact upon development viability.

Renewable and Low Carbon Energy

Under legislation, local planning authorities are responsible for planning applications for renewable and low carbon energy development of 50 megawatts or below. Planning applications for developments above this size are the responsibility of the Secretary of State for Energy. However it is the government’s intention to amend legislation so that all applications for onshore wind energy development are handled by local planning authorities.

The NPPF (2019) is positive about low carbon energy developments and requires plans to “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)”, “consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure” and “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” (paragraph 151). The Council will therefore need to consider whether in addition to having a policy to manage the development of renewable and low carbon energy infrastructure in the District it is also necessary to allocate sites to deliver these schemes.

Sustainable Transport

The NPPF (2019) states that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes, and that Plans should identify opportunities to promote walking, cycling and public transport use. We need to adopt a policy approach that seeks to reduce the reliance on the car through the provision of a range of 'smarter' sustainable transport options to give people the choice to not use their car for every journey, which will enable people to live healthier and more sustainable lives, whilst also cutting the amount of private car use, traffic and resultant pollution. The Plan will also need to help people engage in more active forms of travel (i.e to walk and cycle more) as part of their daily travel routine. This needs to be facilitated in two ways: first through the provision of high quality public realm and landscape design, to create streets where people can enjoy walking, cycling or just spending time; and secondly through the provision of more walking and cycling networks and supporting facilities.

The NPPF (2019) recognises however that opportunities to maximise sustainable transport solutions will vary between urban and rural areas. In respect of Dover, the District has a large rural area and a quarter of the existing residents live in rural villages and countryside, where there is significant reliance on the use of the private car and public transport options are limited. Initiatives which encourage the use of public transport over the use of the private car should be supported alongside opportunities for active travel.

Water Resources, Flood Risk and Coastal Change

Water resources are renewable but not unlimited, and our District is one of the most water scarce areas in the UK. Given climate change forecasts and population increases, this situation is likely to worsen.

The risk of flooding within the district is diverse; the coastal settlements of Sandwich, Deal and Dover are all shown (to some degree) to be at risk of flooding from the sea, with the River Stour and River Dour presenting a fluvial risk of flooding to the settlements bordering these rivers. The centre of the district is in parts low lying, and the varied topography throughout the district can present a risk of surface water flooding to both rural and urban communities. The NPPF states that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at 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. Given this, it is important that the Council actively manages this risk through the planning process to ensure that new development takes into consideration the impact of future climate change and is designed to mitigate risk.

Flooding from surface water runoff typically occurs following an extreme rainfall event, where water from higher in the catchment flows overland and accumulates in topographic depressions. This is further exacerbated in areas with steeply sloping topography, low permeability ground conditions (e.g. urban areas), or where the surface water drainage system (e.g. highway gullies) are overwhelmed. The Strategic Flood Risk Assessment (2019) highlights a number of areas in the District that are susceptible to surface water flooding and it is likely that this will be further exacerbated by the extreme weather events associated with climate change. Given this it will be necessary to include mechanisms in the Plan to manage surface water in a sustainable manner, primarily through the use of Sustainable Drainage Systems (SuDS), to reduce the risk of flooding through reducing surface run off rates on site or elsewhere within the catchment.

Global sea levels will continue to rise, depending on greenhouse gas emissions and the sensitivity of the climate system. The reliance of villages and towns (such as, Deal and Sandwich) on tidal flood defence infrastructure will increase over the next century as sea levels increase. The consequences of such structures failing (i.e. a breach), or becoming overtopped, will therefore increase too. Given this, there is a need to reduce the risk from coastal change by avoiding inappropriate development in vulnerable areas and not exacerbating the impacts of physical changes to the coast.

Carbon Sequestration

Carbon sequestration is the process of capturing and storing atmospheric carbon dioxide. It is one method of reducing the amount of carbon dioxide in the atmosphere with the aim of reducing climate change. Methods of carbon sequestration include tree planting, provision of green corridors, encouraging bio-diversity, and re-wilding.

Tree planting is recognised by the Government as being one of the main ways the UK can achieve carbon neutral status by 2050. We need to consider how we can promote tree planting in the District to help meet this target.

View our Evidence Base

How could these be addressed through planning policy and what is our preferred approach?

The policy options for addressing the key issues identified are set out below:

Planning for Climate Change

Dover District Council declared a climate change emergency on the 4^th November 2019 and has committed to preparing a Climate Change Strategy and associated Action Plan. The Council also has an ambition to become a net zero carbon emitter by 2030 at the latest.

Setting out clearly in a strategic policy what the climate emergency declaration means for the Local Plan and how it will be reflected in and shape all policies is therefore considered important, and not doing so would be unreasonable in light of the strategic objectives of the Draft Local Plan.

Reducing carbon emissions

The Council can either adopt the lower Future Homes Standard: a 20% reduction in carbon emissions compared to the current standard for an average home, delivered through very high fabric standards (typically with triple glazing and minimal heat loss from walls, ceilings and roofs); or
Adopt the government's preferred Future Homes Standard: a 31% reduction in carbon emissions compared to the current standard, delivered through better fabric standards, though not as high as in option 1 (typically double not triple glazing), and the installation of clean electricity generation technology such as photovoltaic (solar) panels and a choice of renewable or low carbon energy technology which could include: photovoltaic panels; wind turbines; solar thermal panels; air or ground source heat pumps; anaerobic digestion; combined heat and power plants; and biomass boilers; or
Require the full 2025 Future Homes Standard to be delivered now; a 75-80% reduction in carbon emissions compared to the current standard; or
Consider a phased approach to the introduction of the 2025 Future Homes across the Plan period; or
Set an alternative local target for reducing carbon emissions, which focuses on the use of a decentralised energy supply; or
Require all new homes to be built to achieve net zero carbon. Where it can be demonstrated this cannot be delivered on-site, developers would then be expected to pay into a carbon off-set fund. This fund would be administered by the Council;
Not set out the council's preferred policy approach until the results of the Future Homes consultation are known; or
Instead rely on the National Planning Policy Framework, Planning Practice Guidance and the National Technical Standards when providing determining planning applications for development in the District.

The governments preferred option is to deliver a 31% reduction in carbon emissions through the Future Homes Standard, as they consider it would support the move away from reliance on fossil fuels, deliver more carbon savings and result in lower bills for the householder, whilst acknowledging it has higher build costs. Furthermore, the government is also considering removing the ability for a Local Authority to set higher efficiency standards for homes. Given this, the Council feels that it is appropriate to adopt the governments proposed approach, as set out in option 2 above, in the Local Plan. This has been tested within the Local Plan Viability evidence, and is considered to be deliverable when taken in combination with other policy requirements, including affordable housing.

With regards to reducing carbon emissions from non-residential dwellings, policy options include:

Continuing with the existing approach that is set out in the Core Strategy which requires new non-residential development to meet BREEAM very good standard. This rating is given to the top 25% of buildings and is considered to represent advanced good practice in sustainability performance; or
Require new non-residential development to meet BREEAM excellent standard. This rating is given to the top 10% of buildings and is considered to represent best practice in sustainability performance; or
Rely on the National Planning Policy Framework, Planning Practice Guidance and the National Technical Standards when providing determining planning applications for development in the District.

The Council's preferred approach is to continue to require non-residential development to meet BREEAM Very Good, instead of requiring higher standards of sustainability, which may place an undue burden on the viability of new commercial development in the District. This has been tested within the Local Plan Viability evidence, and is considered to be deliverable when taken in combination with other policy requirements, including affordable housing.

Sustainable design and construction

With regards to promoting sustainable design and construction in the District, the council can either adopt a local approach to managing this issue and include a policy in the Plan to facilitate the delivery of sustainable design and construction to reduce greenhouse emissions in relation to all new development; or
Instead rely on the National Planning Policy Framework, and Planning Practice Guidance when providing planning advice and determining planning applications for development in the District.

Sustainable design and construction can make an important contribution to delivering sustainable development and addressing climate change. Given this, having considered the evidence, opportunities and policy context within Dover, the preferred approach is to include a policy on sustainable design and construction to assist in the delivery of the Council's target of achieving net zero carbon by 2050. This is considered to represent the most appropriate method for setting out a set of clear principles that each development will need to consider, and will assist in the effective management of development in the District. The preferred approach aligns most appropriately with national legislation and most effectively addresses the issues outlined above.

Renewable and low carbon energy

With regards to promoting renewable and low carbon energy in the District, the Council can either adopt a local approach to managing this issue and include a criteria based policy in the Plan to facilitate the delivery of local renewable and low carbon energy to reduce greenhouse emissions; or
Allocate sites in the Local Plan to deliver renewable and low carbon energy schemes. For example, the KCC Renewable Energy Action Plan for Kent (2013) identifies the central areas of Dover District as having a high potential for large scale installation of wind energy; or
Instead rely on the National Planning Policy Framework, and Planning Practice Guidance when providing planning advice and determining planning applications for development in the District.

Increasing the proportion of renewable and low carbon energy generated is one of the ways Dover District can contribute to the UK governments target of net zero greenhouse gas emissions by 2050. Given this, having considered the evidence, opportunities and policy context within Dover, the preferred approach is to include a policy on renewable and low carbon energy to assist in the delivery of this target. This is considered to represent the most appropriate method for setting out a set of clear principles that each development will need to consider, and will assist in the effective management of development in the District. The preferred approach aligns most appropriately with national legislation and most effectively addresses the issues outlined above.

If the council were to allocate sites for renewable energy in the District then further evidence would be required. However currently no specific sites have been put forward for renewable energy installations.

Sustainable Transport

With regards to promoting sustainable transport in the District, the council can either adopt a local approach to managing this issue and include a policy in the Plan to ensure that new development provides the opportunity to maximise the use of the sustainable transport modes of walking, cycling, and the use of public and community transport, and opportunities for people with disabilities to access all modes of transport; or
Instead rely on the National Planning Policy Framework, and Planning Practice Guidance when providing planning advice and determining planning applications for development in the District.
A further option would be to specify the individual sustainable transport measures which should be provided on each development site allocated in this Plan.

The option to not have a specific policy covering this issue, but to consider planning applications against the NPPF and Planning Practice Guidance, is considered to provide an insufficient level of guidance for applicants and officers. Given this, having considered the evidence, opportunities and policy context within Dover, the preferred approach is to include a policy on sustainable transport. This is considered to represent the most appropriate method for setting out a set of clear principles that each development will need to consider, and will assist in the effective management of development in the District. The preferred approach aligns most appropriately with national legislation and most effectively addresses the issues outlined above.

Water resources, flood risk and coastal change

With regards to water efficiency, the Council can either adopt the minimum standard in the National Technical Standards and Building Regulations of 125 litres/person/day; or
If the Council has sufficient evidence it can require new dwellings to meet the tighter building regulations optional requirement of a maximum usage of 110 litres/person/day.

Given the we have clear evidence that Dover is in a water stress area, we consider it is most appropriate to adopt the second option in the Plan, and this is reflected in our preferred policy approach. This option has been tested through the Whole Plan Viability evidence and is considered to be deliverable.

In respect of flood risk, surface water management and coastal change the council can either adopt a local approach to managing these issues and include policies in the Plan to ensure that flood risk and coastal change is managed effectively and sustainably as part of the planning process; or
Instead rely on the National Planning Policy Framework, and Planning Practice Guidance when providing planning advice and determining planning applications for development in the District.

Given the Strategic Flood Risk Assessment (2019) highlights that a number of areas in the District are at risk of flooding from a variety of different sources we feel that the first option is most appropriate, as it allows the Council to effectively manage this issue at a local level through the policies in the Local Plan, and this is reflected in our preferred policy approach.

Carbon Sequestration

The Council can either adopt a local approach to managing this issue and include policies in the Plan to facilitate the delivery of more trees to sequester carbon from the atmosphere to help address climate change; or
Have no specific requirement concerning carbon sequestration.

Tree planting is recognised by the Government as being one of the main ways the UK can achieve carbon neutral status by 2050. Given this, we feel that it is appropriate to support this initiative at a local level through the introduction of a policy to facilitate tree planting and protection. This is considered to represent the most appropriate method for setting out a set of clear principles that each development will need to consider, and will assist in the effective management of development in the District. This has been tested within the Local Plan Viability evidence, and is considered to be deliverable when taken in combination with other policy requirements, including affordable housing.