Want to have your say on environmental aspects

of the draft NY Local Plan?

Stop press! NYC's LP consultation team have just confirmed that anyone who finds the nyc platform difficult to use can submit feedback by email to localplannyc.consultations@northyorks.gov.uk. 

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North Yorkshire Council is consulting the public on an early draft of its new Local Plan for the whole county (excluding the two National Parks). Here’s a copy, or you can download from the Council website. The aim of the Local Plan is to set out a vision and strategy for future development, alongside planning policies which will guide decision-making on planning applications all the way up to 2045. The final version will dictate in great detail how places are shaped across the county, including what gets built where (houses, business sites, infrastructure) and what protection is given to green spaces. At this early stage, we are being invited to comment on the big vision, objectives and key issues in the plan rather than detailed policies.

Importantly, from NY Climate Coalition's perspective, the Local Plan will have a major influence on how quickly and ambitiously we respond to climate change and protect our natural environment. Think energy-efficient buildings, low-carbon transport, siting of renewable infrastructure, protection for green (and blue) spaces, etc. The consultation document states that ‘addressing climate change will form a golden thread running through the new North Yorkshire Local Plan’, and there is an entire section on ‘Tackling climate change’. That’s a good start, but the planning team still need to hear a strong message from us on the importance of green spaces, energy-efficient homes, water quality, public transport, etc.

There are lots of questions in the consultation document covering every aspect of planning development. Of course, you might want to answer all of them, but we’ve identified the most important questions that have links to climate, nature and the environment, and we’d really love you to submit a response on these subjects so that council officers and councillors can get a sense of the number of local people across NY who want our new Local Plan to lead the way on these crucial issues.

So here’s a selection of the key questions (for us) together with some ideas for points you might want to make – ideally in your own words – in your response. Just suggestions, of course. Do add your own thoughts on the questions that matter most to you!

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Key climate and environment issues and questions

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- Mitigating climate change (i.e. reducing emissions), p.30 - 

 

What the draft Local Plan says

“The local plan could help to mitigate climate change by:

reducing emissions from transport

reducing emissions from new development

identifying locations and/or criteria-based policies for a range of renewable energy technologies

reducing emissions through retrofitting existing buildings, where planning permission is required

supporting nature based solutions for carbon capture, storage (CCS) and carbon offsetting.”

 

Question 1. Are there any other ways the local plan should help to mitigate climate change?

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Suggested points

- All the options listed in the draft LP are good.

- Yes to nature-based carbon capture and storage (CCS), e.g. through peatland restoration, tree planting (with specific target), organic and regenerative farming (no till) to increase soil carbon sequestration. See England Peat Map showing the extent of peat depth across the country (with large patches of blue in North Yorkshire!). Vital to protect peat in the LP!

- Offsetting only for genuinely unavoidable emissions – not as a routine option that allows developers to avoid low-carbon choices or remove/destroy inconveniently located trees, hedgerows, habitat.

- Given the emphasis on sustainable growth in the draft LP, reference the projected economic impacts of climate change, e.g. LSE research indicates 'Under current policies, the total cost of climate change damages to the UK is projected to increase from 1.1% of GDP at present to 3.3% by 2050 and 7.4% by 2100'. By contrast, according to this CBI report, 'The net zero economy has become a powerhouse of job creation and economic expansion'.

- Use the Local Plan (LP) to promote active travel, e.g. pedestrian-friendly streets, dedicated cycle lanes and accessible active travel infrastructure

- Use LP also to disincentivise high-carbon transport choices, e.g. cars for short journeys

- Use LP to design out "waste" and promote circular economy.

- Use the LP to support the development of an ambitious strategy to create a low-waste, reuse and repair economy that moves away from incineration and avoids being tied into incineration contracts that perversely disincentivise efforts to reduce waste. Use the LP to implement the YNY Routemap’s progressive vision for waste.

- Align the LP (especially the objectives) with the UN Sustainable Development Goals in line with NYC's decision to adopt the SDGs as a framework for its policies and work programmes. 

- Construction: All new domestic and commercial developments should be constructed to ‘net zero carbon’ standards, using locally sourced and low/zero-carbon materials wherever possible, and include roof-mounted solar and air source heat pumps to provide energy-efficient homes. This would avoid the need for expensive future retrofit and reduce the pressure on land for ground-mounted solar farms. Timber construction is a great way of sequestering carbon in buildings.

- The LP should support community geothermal heating, Pickering area as an example of what can be achieved  

- 'Cumulative impact​': The LP should provide guidance on avoiding 'cumulative' climate impacts, i.e. multiple smaller-scale developments that individually may not have a large climate impact but in combination may produce a significant level of GHG emissions. 

- The standard planning application form should require an estimate of initial GHG emissions from construction and of subsequent lifetime emissions from operation. Applicants should be required to demonstrate that they have chosen the lowest-carbon options where these are demonstrably affordable and effective. 

- The LP should include an explicit declaration of alignment with the YNY Routemap goals (net zero by 2034 and carbon negative by 2040) and ambitious and measurable sector-based targets. 

- Specify a Community Infrastructure Levy with a climate emergency bonus to help fund local environmental projects (e.g. Lancaster City Council's LP)

- Establish LP validation criteria to screen out unnecessary high-carbon projects before validation. LAs have some leeway to determine their own local validation criteria! Reject high-carbon proposals at this pre-validation stage.

- There is a link between housing affordability and people's ability to make climate- and nature-friendly choices (e.g. buying local and/or organic produce) from their remaining income after mortgage/rent payments. So the LP should be very ambitious in setting affordability thresholds. The NPPF allows local plans to maximise delivery of local  affordable needs, so the new LP could stipulate that affordable housing (including e.g. kit homes, built to high design and environmental standards in local factories using local materials ) is built first. As well as environmental benefits, this local constructor/supplier focus would help to keep money in the county. 

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- Adapting to the effects of climate change (p. 32) - 

 

What the draft says

“The local plan could help to adapt to climate change by:

building in sustainable design in new development

locating new development in the lowest areas of flood risk and requiring sustainable draining systems

avoiding inappropriate development in vulnerable coastal areas and not exacerbating the impacts of physical changes to the coast.”

 

Question 3. In the area where you live, are there any specific concerns that you would like to raise relating to climate change mitigation and adaptation? Please specify the area.

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Specify your area.

Development pressure on green spaces, e.g. (local examples). Green spaces are crucial to wider mitigation and adaptation efforts. Recommendation – strengthen protections for green spaces. 

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Question 4. Are there any other matters related to climate change mitigation and adaptation that should be considered when preparing the new local plan?

 

Suggested points

- Define ambitious and measurable greenhouse gas (GHG) reduction targets for each area of the LP

- Align the LP with the YNY Routemap to Carbon Negative

- Consider good practice as set out in other ambitious local authority LPs

- Avoid "cumulative" climate impacts, e.g. multiple smaller-scale developments that individually may not have a large climate impact but in combination may produce a significant level of GHG emissions

- Require all new developments to give an estimate of initial emissions from construction and their subsequent lifetime emissions 

- Screen out unnecessary high-carbon projects before accepting for consideration (validation).

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- Open space and community facilities (p. 36) - 

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Question 1 What do you think of the availability and quality of open spaces and community facilities in your local area? Please specify the area.

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Suggested points

My local area is xxxx. Open spaces are under constant development pressure. Open green spaces (say where) are vital to quality of life, residents’ health & wellbeing, active lifestyles and the distinctive character of the area and must be protected. The LP should prioritise access to open space and nature in line with Natural England's focus on 'Nature on your doorstep'. The LP should facilitate the creation of local nature reserves and designated country parks.

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- Protecting and improving biodiversity (p. 38) - 

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Question. What approaches should be incorporated in the new local plan to protect and improve biodiversity?

 

Suggested points

- Avoid any further loss of green space wherever possible given scale of biodiversity loss. Brownfield first.

- Allow Biodiversity Net Gain (BNG) offsetting only if it’s genuinely necessary to develop existing green space, not as a routine option.

3. If a BNG offsetting arrangement is permitted, the LP should stipulate an ambitious requirement of +30%, well above the national minimum of +10%.

4. Tighten up rules that currently allow landowners to remove unprotected trees and hedges on their land (i.e. without a TPO or HPO), often prior to submitting development proposals. Many valuable trees and hedgerows are outside protected areas. LP could include a mechanism to increase protection, e.g. county-wide inventory of trees over certain age or size.

-The LP should include enhanced protection for water bodies, especially rivers, as part of wildlife corridors

-The LP should be aligned with the YNY Local Nature Recovery Strategy (LNRS)

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- Enhancing the network of green and blue infrastructure (p. 40) -

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Q1. Are there any other ways the local plan should help to enhance the network of green and blue infrastructure?

 

Suggested points

- Green and blue 'infrastructure' are closely interconnected, e.g. green corridors alongside rivers. Important to highlight  that interconnectedness in the LP. See the Local Nature Recovery Strategy.  

- The LP should identify green and blue infrastructure close to existing settlements and/or suitable nature reserves that can be combined into designated country parks, e.g. in my area ........

- The LP should include a requirement for 'water neutrality', see e.g. Water Neutrality - West Sussex County Council 

- The LP should promote reed bed systems and local water storage

- As required by the Levelling Up and Regeneration Act (LURA), the LP should ensure protection for the immediate and wider settings of protected Landscapes including National Parks and National Landscapes (formerly AONBs) to safeguard this natural heritage and nationally valued landscape for future generations.

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Q2. What types of green and blue infrastructure are valued in your local area? Please specify the area and what you value them for.

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Suggested points

Give examples in your area.  These are all are vital to quality of life, residents’ health & wellbeing, active lifestyles and the distinctive character of the area.

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- Pollution and ground conditions (p.41) -

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Q1. In your local area what types of pollution are you most concerned about? Please specify the area and type of pollution.

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Suggested points

Name your area.

Pollution issues could include agricultural run-off and storm sewage overflows in rivers, also potentially from other currently untested sources, e.g. pesticide residues (e.g. dog flea treatments), forever chemicals (PFAs), pharmaceutical residues). Also possibly air pollution (e.g. from traffic, other sources)

Light pollution? Excessively bright outside lighting is bad for dark skies (esp. close to NY Moors, an internationally designated dark skies area!) and for wildlife, e.g. bats.

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Submitting your response

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You can submit your response using the council’s online consultation portal, but you’ll ned to register first at https://northyorks-consult.objective.co.uk/kse/. Once you’ve registered, select ‘Start the consultation’. Scroll down through the document and enter your responses  by clicking ‘Add comment’ next to the green question boxes. You don’t need to answer all the questions!

 

Unfortunately, the online consultation method is not very user-friendly, so you may prefer to send your response using an alternative method. There is an option to post responses (see address below), but as the deadline for receipt is midnight on Tuesday 15 July, we recommend email. NYC’s LP consultation team have confirmed that anyone who finds their online platform difficult to use can submit feedback by email to localplannyc.consultations@northyorks.gov.uk. If you wish, use this simple template, add in your responses (feel free to use some of the suggestions above), delete any questions you don’t want to answer, copy into an email and send.

 

If you do choose to post your response (deadline for receipt midnight on Tuesday 15 July), send to:

Planning Policy and Place Team,

North Yorkshire Council, County Hall, Northallerton, DL7 8AD

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