Object

Representation ID: 303

Received: 11/10/2019

Respondent: Barton PC, Thrumpton PM, Lark Hill RA, Clifton Village RA, SAVE

Number of people: 5

Legally compliant? No

Sound? No

Duty to co-operate? No

We are supportive of the inclusion of climate change in the suite of strategic policies that shape the Minerals Local Plan. However, SP3 is unsound because it is deficient in two respects which undermine its effectiveness:
a) That the statement in point b) of Policy SP3 needs be modified to clarify what ‘vulnerability’ is referring to. Flood risk is identified as an issue. Communities, natural and historic assets and agricultural soils also need to be highlighted. The need to minimise the vulnerability of existing biodiversity assets to climate change impacts should be identified as an issue, and also should be a factor in determining the general allocation of sites for development.
b) That while the reference to restoration is appropriate in point 1c) of policy SP3, the policy also needs to state that such restoration schemes can contribute to climate change adaptation providing that they compensate for the impacts they have had as a result of the development.
We are supportive of the recognition that in some circumstances mineral development can provide a number of opportunities to mitigate and adapt to the impacts of future climate change (3.34). However, we are concerned that this theme is not carried over into expectations in terms of the issues outlined in point 1a) of Policy SP3. The location, design and operation, and significantly the restoration of sites, should not only seek to avoid climate change impacts, but also deliver a net gain in terms of climate change adaptation.
Given the time frame of the minerals plan, and the national goals of carbon neutrality, the policy fails to be effective in that it lacks any meaningful targets in relation to the need to assess climate change impacts of plans and options. It also fails to provide any targets for the management of carbon emissions or to show how the use of recycled or alternative materials can be encouraged by the Plan.