07 Tackling the climate emergency and responding to climate change

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Chapter 07.pdf

Tackling the climate emergency and responding to climate change

Reducing emissions and promoting zero carbon development

The climate is in crisis. The latest warnings from the 2021 IPCC sixth assessment report are stark. Human-induced climate change is already affecting many weather and climate extremes in every region across the globe, the atmosphere and seas are warming at rates unprecedented in human history, and some of the consequences are irrevocable. Time is running out and these trends are set to continue without drastic cuts in carbon emissions in the next decade. It is clear that now is the time for bold collective action.

No organisation or individual is exempt from responsibility, and in 2019 the Council declared a climate emergency where it committed to become carbon neutral by 2040. The Local Plan has a key role to play and it is imperative that we go further than ever before by introducing a suite of ambitious and implementable policies which addresses the severity of the crisis that we are all facing.

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Climate Emergency

We have set out an overarching policy as part of our response to the climate emergency. 

27. Strategic Policy – Climate Emergency

The East Devon target is to become carbon neutral by 2040, this overarching strategic policy for climate emergency requires developments to support East Devon becoming carbon neutral by 2040, through:

  1. Delivering net-zero development;

  2. Maximising opportunities for delivery of renewable energy, district heat networks, zero-carbon energy and energy storage facilities; and

  3. Calculating the impact of embodied carbon and retaining existing buildings where possible.

Net-Zero Carbon Development

Net-Zero Carbon Development is concerned with seeking to ensure that overall, in their use and occupation, new buildings make a net zero carbon contribution to the environment.  This can be achieved to a great extent through very high efficiency standards and incorporation of renewable energy generation technology.

28. Strategic Policy – Net-Zero Carbon Development

All new residential and commercial development will deliver net-zero carbon emissions. Developers will be required to submit a “carbon statement” to demonstrate how this will be achieved, in accordance with the energy hierarchy.  

In addition, homes will be required to be future proofed to avoid temperature discomfort as a result of rising temperatures.  

There will also be requirements to maximise opportunities for renewable energy and ensure that in-use energy performance is as close as possible to design intent. 

Finally, there will be a requirement for major development to calculate the whole life-cycle carbon emissions, through a nationally recognised Whole Life Cycle Carbon Assessment.

Promoting renewables and zero carbon energy

We have drafted policy that seeks to ensure that as much of our energy as possible comes from zero-carbon sources. This will play a crucial role in achieving climate objectives. Renewable energy makes up an ever-increasing proportion of the energy supply and this is a trend which is set to continue.  

29. Strategic Policy – Promoting renewables and zero carbon energy 

Development of zero carbon and renewable energy schemes within the District will be supported. We will encourage the use of community-led schemes and promote their use within Neighbourhood Plans.

The Local Plan will support renewable and low carbon energy proposals where there are no unacceptable impacts on: 

  • Landscape, visual or residential amenity
  • Noise, air, water, highways or health
  • Biodiversity, the natural or historic environment
  • Radar, telecommunications or the safety of aircraft operations

Planning permission will only be granted for development of non-renewable forms of energy generation where it can be demonstrated that there are clear and compelling circumstances that generate the need for the proposal and that all reasonable opportunities for using renewables to supply the need are non-credible and exploration of alternative options have been exhausted.


Solar energy and electricity generation

Solar energy has become increasingly important in supplying electricity and of lesser importance for direct heating in recent years.  Many smaller-scale installations, for example on the roofs of some residential dwellings, do not require planning permission.  However, large-scale solar farm installations would require permission and can be, unless sensitively sited and designed, intrusive in the landscape.  

Plan policy sets out considerations with respect to supporting new solar installations.

solar energy

30. Strategic Policy – Suitable areas for solar energy developments

Solar photovoltaic development will be supported in the identified solar energy suitable area, as shown on the Policies Map, where there are no unacceptable impacts on any of the following:

  • Landscape, visual or residential amenity;

  • Noise, air, water, highways or health;

  • Biodiversity, the natural or historic environment;

  • Radar, telecommunications or the safety of aircraft operations;

And subject to not leading to direct conflict with any local plan policy that allocates land for an alternative development type or specifically affords safeguarding protection to land (unless development can be accommodated within the policy terms of the safeguarding).

Energy from wind and wind farms

Windfarms can be found on-shore and off-shore, sometimes many miles out to sea.  Off-shore windfarms largely fall outside of the remit of the Council as the relevant planning authority, though there may be planning implications associated with any on-shore infrastructure or connections that are required.

Plan policy sets out considerations in respect to supporting new on shore windfarms.

31. Strategic Policy – Suitable areas for wind energy developments

Wind energy development will in principle be supported in the identified wind energy suitable area, as shown on the Policies Map, where there are no unacceptable impacts on:

  • Landscape, visual or residential amenity

  • Noise, air, water, highways or health

  • Biodiversity, the natural or historic environment

  • Radar, telecommunications or the safety of aircraft operations

And subject to not leading to direct conflict with any local plan policy that allocates land for an alternative development type or specifically affords safeguarding protection to land (unless development can be accommodated within the policy terms of the safeguarding).

The impacts of any development on key landscape characteristics must be acceptable. Proposals must have regard to the landscape sensitivity and be of a scale and type where landscape sensitivity has been identified as being low/moderate or moderate.

Energy storage

One of the challenges associated with renewable energy generation is that the time when it is ‘made’ is not necessarily the same time as when consumers want to use it.  Much of the electricity consumed by households is done so in the evening, often after sunset, but this of course is the time when solar panels cease to generate electricity or at least production starts to rapidly fall.

Policy in the plan therefore sets out considerations that are relevant to storage of electricity.

32. Strategic Policy – Energy Storage

Planning permission will be granted for energy storage facilities to help to achieve carbon neutrality and support renewable energy production and use in East Devon subject to such schemes not having adverse impacts on account of noise, environmental considerations or amenity impacts.  And not being in direct conflict with any policy in the plan that allocates land for a different specified use or safeguards land unless the energy storage facility can be accommodated without compromising the policy intent of the safeguarding.

Strategic heat networks

Strategic heat networks are created from systems where a central plant or plants will generate heat and this will then be distributed along pipe networks to residential, business and other consumers.  Strategic heat networks provide a more efficient way of producing heat than individual properties having their own separate boilers. 

33. Strategic Policy – Heat Networks

For all major developments proposed within 1km of an existing heat network a connection will be required in order to secure planning permission. In addition, where no heat network currently exists, a new heat network will be required for proposals above 1,200 homes or 10 ha of commercial floorspace.

Embodied carbon

One of the major sources of greenhouse gases is the manufacture of building materials.  We see, therefore, real benefits in using all or key parts of the existing building stock in development projects.

34. Strategic Policy – Embodied carbon

All developments shall demonstrate actions taken to reduce embodied carbon and developers should retain existing buildings, or at least the foundations unless it can be demonstrated that refurbishment is either unviable or impractical. 

Replacement of existing habitable buildings with new developments will only be supported in exceptional circumstances and will need to demonstrate that the full lifecycle carbon emissions will be net-zero.

Flood Risk

Government policy makes clear that development should be directed away from areas at highest risk of flooding now and in the future. The level 1 strategic flood risk assessment will help us to show how this can be done. It will (amongst other things): set out the relevant issues; give advice on the need for local policies; highlight any cross-boundary issues; identify any land needed for future flood risk solutions and map flood risk from all sources for the whole of East Devon. A level 2 strategic flood risk assessment may be required to inform strategic allocations at the next plan making stage. This draft plan generally avoids areas currently known to be at risk of flooding, although there are areas within existing settlements that are at risk of flooding that may be considered suitable for redevelopment, subject to detailed flood risk assessments (in a level 2 strategic flood risk assessment). 

There is extensive national policy on flooding, which was recently updated. We will need to await the outcome of the strategic flood risk assessment before  finalising flood related policies that are necessary in an East Devon context. A draft policy to highlight the issues likely to be covered is included here as an interim measure.

35. Strategic Policy – Flooding

The policy will require development proposals to:

  • Meet the sequential and exception tests as set out in the NPPF; 

  • Avoid land required for flood management, including natural floodplains; 

  • Be safe over its lifetime, taking into account the increased risk of flooding due to climate change and without increasing flood risk elsewhere; 

  • Ensure that any flooding measures respond to the specific requirements of the site and respect the character and biodiversity of the area; 

  • Preferably reduce or at least not exceed existing run-off rates; 

  • Manage site surface water run-off as close to the source as possible.


Coastal change management areas

We have worked with the University of Plymouth on a way to predict coastal erosion and flooding and have published a briefing paper and a topic paper on coastal change. The University of Plymouth have mapped areas that may be vulnerable to coastal change over the next 20, 50 and 100 years using the agreed methodology, which takes account of potential impacts from climate change through sea level rises. This work has been used to identify coastal change management areas (CCMAs) in accordance with the National Planning Policy Framework. 

This is a highly complex topic, and it is recommended that the local plan is supported by supplementary planning guidance to give more details of how the CCMA approach would work in practice.

36. Strategic Policy – Coastal change management areas (CCMAs)

Applications for non-residential development within the CCMA will be assessed in relation to the most up-to-date evidence available for when coastal change can be expected so that:

In parts of the CCMA expected to be at risk within a 0-to-20-year time horizon, only the following developments will be allowed: -

  • temporary development directly related to the coast, such as beach huts, cafes, car parks or sites used for touring caravan and camping;

  • temporary modifications to other existing commercial facilities where a positive link can be made to the local economy; 

  • mitigation measures for dealing with coastal change that are in accordance with the relevant coastal strategy or

  • nationally significant infrastructure projects related to offshore development that are constructed to withstand the impacts of the expected coastal change.

In parts of the CCMA expected to be at risk within a 20-to-50 year time horizon, in addition to the development allowed in the 0 to 20 years zone the replacement, relocation and adaptation of infrastructure, commercial and community uses will be permitted, providing they require a coastal location and provide economic and social benefits to the local community. 

In parts of the CCMA expected to be at risk within a 50 to 100 year time horizon, in addition to the development allowed in the 0 to 50 year zones, extensions to residential properties and householder applications may be acceptable.

All applications for development within a CCMA must show that it would not result in an increased risk to life or any property through the submission of a coastal change vulnerability assessment, which should be proportionate to the scale and nature of the development.

 Planning permission for all development in a CCMA will be time limited according to the risk identified in the coastal erosion vulnerability assessment.

Relocation of uses affected by coastal change

Where evidence shows that certain existing uses would be vulnerable to coastal change in the short term, we propose to maintain our current approach of allowing relocation in some circumstances to areas where development would otherwise be unacceptable.

37. Strategic Policy – Relocation of uses affected by coastal change

Where there is robust evidence to demonstrate that permanent homes (with unrestrictive occupancy) or community facilities, commercial or business uses that are considered important to coastal communities are likely to be affected by coastal erosion within 20 years of the date of the proposal, proposals for relocation/replacement may be considered favourably subject to the following criteria: 

  1. The new development is located in an area at less risk of coastal erosion; 

  2. The replacement property is located close to the community from which it is displaced and has an acceptable relationship with it in terms of character, setting, local amenity and any special landscape designations; 

  3. Overall, taking both the existing and proposed buildings into account, the proposal should not have an additional detrimental impact on the landscape, townscape or biodiversity of the area, taking into account any special designations; 

  4. The existing site is either cleared and restored with enhancements for nature conservation or put to use to benefit the local community within three months of the first use of the replacement. The future use of the site should be secured in perpetuity and provision made for public access to the coast where appropriate; 

  5. The development is consistent with the criteria set out in Policy  6 - Development Beyond Settlement Boundaries; and 

  6. In the case of a residential proposal, the gross volume of the replacement dwelling is no larger than the one it is to replace.

Development affecting coastal erosion

The broad national and local approach to coastal erosion (as set out in the Shoreline Management Plan (SMP)) is to defend the centres of the main settlements and allow natural processes to continue in the more rural areas. Large parts of our coastline are designated as a World Heritage Site, the integrity of which would be undermined if natural processes were not allowed to continue.

38. Strategic Policy – Development affecting coastal erosion

Where compatible with the most up-to-date coastal policy (as expressed in the SMP or a strategy such as a beach management plan), the Council will promote proposals for sustainable coastal change management such as improvements to coastal defences or managed realignment, provided that they would not have an unacceptable adverse economic, social or environmental impact, including an unacceptable detrimental visual impact on a protected landscape. 

To protect the integrity of the Dorset and East Devon World Heritage Site, the natural processes that created it will be allowed to continue, unless the safety and economic well-being of any coastal community would be undermined, provided that the implications of this for the World Heritage Site have been fully considered. 

Where there is a conflict between allowing coastal erosion and protecting coastal communities from that erosion both interests will be recognised and wherever possible impacts will be mitigated where they arise. Schemes that are incompatible with coastal policy are unlikely to be supported.

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