Climate Emergency Development Plan Document - Cornwall ...

Information Classification: CONTROLLED

Climate Emergency Development Plan Document Pre-Submission Feedback

Strategic Planning

SD11


Contents:

a) Contents 1. Introduction ..................................................................................................................... 3

2. Response Overview.......................................................................................................... 3

3. General Comments: ......................................................................................................... 5

Reponses to specific Policies: ........................................................................................... 40

4. Climate Change Principles .............................................................................................. 40

5. Proposed Policies Natural Climate Solutions ................................................................. 55

6. Proposed Policies Whole Estate/Farm Plans and rural development ............................ 65

7. Proposed Policies Town Centre Development Principles ............................................... 73

8. Proposed Policies Sustainable Transport ....................................................................... 85

9. Proposed Policies Renewables (including geothermal & mine water) ......................... 106

10. Proposed Policies Energy and Sustainable Construction .......................................... 136

11. Proposed Policies -Coastal Change and Flooding ..................................................... 152


1. Introduction We carried out public consultation on the Climate change Development Plan Pre-Submission

Document (DPD) between 10 August and 25 September 2020. The period was extended to

take account of the bank holiday.

We welcome all feedback and the detailed evidence that has been very useful. We have

again received some suggestions and concerns that can’t be addressed by this Climate

Emergency DPD, but this is just one way that Cornwall Council is taking action to address

climate change. All evidence and information are shared with colleagues across the Council

to support the delivery of the Council’s Climate Action plan.

The Climate Emergency DPD will be subject to a further period of public consultation as required by the Local Plan Regulations. It is anticipated that this next key statutory engagement stage will be held in early 2021.

Our consultation approach was adapted to ensure a broad cross section of people were engaged despite the continuing health emergency. We have received responses online, by post and in telephone conversations, demonstrating the value of all the options we offered. As this consultation is for a DPD aimed at addressing the Climate Change Emergency we hoped to keep printing to an absolute minimum, and this has been successful.

2. Response Overview

The team received a varied and interesting range of comments, whilst there will always be differing views on how to tackle climate change, and indeed if it is an issue at all, it was great to get such a positive response from stakeholders.

There was some concern expressed that by explaining the areas that Planning Policy doesn’t control and stressing in the need for change but reflecting the scale and difficulty it poses had given the DPD a negative tone. This was not the intention rather it was meant to show how the work being undertaken addresses climate change and to reassure the reader that all feedback has been reviewed and shared with other services across the Council as appropriate even if it was not part of the DPD. We can reiterate that the Climate Emergency DPD is just one of the many actions the council is taking, and it continues to evolve as a result of the feedback received.

Here the aim is to give an overview of the comments received and to demonstrate where they have led to changes to the draft policies. Many responses were positive and recognised the urgent need for the work that the DPD supports and the time and effort expended to reach the current stage.

Calls were made for use to ask Government to do more. In light of the recent Government

paper proposing a range of reforms to the planning system, including changing the role of

local plans we concluded that the proposals are subject to consultation and require


legislative changes. As such we as a Council remain committed to continuing the

preparation of the DPD.

Some format changes were requested and to help with some of the more technical

language a glossary will be included in the next version of the DPD.

The need for an overarching policy C1 was questioned. The policy covers all areas in the DPD

and will be amended to reflect the expanded policies throughout the DPD that should be

read in conjunction with this policy. It was also noted that social justice should be included

in the overarching policy.

The policies within the DPD do not discriminate against any sector of the population and

health and wellbeing have been considered in all the draft policies. The DPD is the subject of

a published comprehensive impact assessment. The new policies, in helping tackle the

effects of climate change will provide benefits for all.

Focus groups continue to make sure that make sure that the proposed policies integrate

with legislation and the plans of other groups such as the AONB management plan. It is

acknowledged that some uncomfortable changes in behaviour will need to be adopted by

everyone in order to address the Climate Emergency.

In response to questions around enforcement and measurement work continues to refine

the metrics that will be used e.g. the DEFRA Eco-metric, the Green Points System and

Carbon Capture tools. All the suggested metrics, if adopted will be supported by

comprehensive instructions to ensure they are useable. The development of a Local Nature

Recovery Strategy will become a Statutory requirement as part of the Environment Bill.

Support was mainly positive for the policies that consider Town Centre Development. The

current situation with Covid has had an additional adverse, effect on the already changing

and hard-hit Town Centre’s. The policies were welcomed as a way to support the necessary

changes to the way Town Centres may be used in the future.

Based on the Travel Hierarchy, there was a level of support for active travel, but it was

noted that there are concerns that there would need to be additional infrastructure to make

walking and in particular a cycling a safe choice. Improvements to public transport would

also be needed.

The policies look at reducing the need for individual car journey’s in order to reach the 2030

carbon neutral target. This has proved unpopular with many responders pointing out that as

a predominantly rural county, there would remain a need for private vehicles.

Landscape sensitivity work to allocate and map areas where renewable energy generation

could be considered, is due to be completed shortly, having been delayed by the pandemic.

Many responders are awaiting this information. This has also proved to be an area where

responders were split many with the view that renewable energy of all kinds is a positive

move, whilst the siting of wind turbines is a contentious issue that will need further

engagement.


Other concerns were raised around community benefits, which will be clarified further, and

the ability to generate and keep the renewable energy in Cornwall. Battery and other

storage options are being investigated and will be supported and the Council is engaging

with Western Power Distribution and the energy sector.

Concern was raised that offshore wind power was not included in the Renewable Energy

policies. This is because development outside the low water mark would not be covered by

the policies in the DPD. Although the policies have been strengthened to look positively on

the on-land supporting infrastructure that would support any future off-shore sites.

Coastal Change is clearly connected to the Coastline Management Plan and the Council is

working with environment agency to refine these policies.

Whilst many responders made general comments with some quite diverse views,

continuous engagement provides us with a clearer basis to strengthen the policies needed

to help address climate change.

Co-housing and alternative living were popular and supported themes. Policies relating to

these areas are being developed and will be included in the DPD.

The suggestions for amendments to policy wording have been useful and have been

adopted where appropriate. Some other comments have prompted clarification and a

change in language that make policies more useable.

A further period of consultation that will reflect the amendments and actions following this

feedback will take place next year.

3. General Comments:

URN Comments

058 Thank you so much for your commitment and drive in putting together this document, and setting out a desperately needed path towards achieving zero carbon by 2030. Could you please tell me how the national Government's recent planning proposals (zoning etc) will affect this draft DPD?"

114 I have been reviewing your most recent climate emergency draft document and see that you have removed the requirement that renewable energy proposals have the support of the respective relevant communities before they are permitted. Community support remains a requirement in the NPPF, therefore Cornwall Council must also include community support as a requirement in its dpd. I request that you include community support as a requirement in your next draft dpd. Otherwise, your dpd will be in violation of the national laws.

350 Dear TEAM, YOU just seem hell bent on ruining the countryside in Cornwall you can fill it up with solar panels and windmills but your not going to alter the way the world climate is going to change [ if it is ] your going to look pretty silly when we move into a colder climate why don’t you look back in history


354 I would like to congratulate you on your document which, if approved and implemented, will help Cornwall achieve the vital goal of carbon neutrality by 2030. Here is a short response from myself as an active member of two Transition groups (Falmouth and Truro) who had a hand in producing two documents in 2018, regarding Local Neighbourhood Planning in the Falmouth/Penryn Community Network Area, and the Truro Place-Shaping Project, offering a Transition perspective. You may find these two links helpful in themselves as a contribution to your consultation - https://www.transitionfalmouth.org.uk/wp/wp-content/uploads/2018/03/TF-sustainability-march2018.pdf and....... https://www.transitiontruro.org.uk/wp/2018/06/truro-place-shaping-project/ Here are a few comments under some of your headings - which may or may not be relevant, or achievable through the planning process, but I offer them for consideration. They apply to more than one of your headings, and relate to some important areas which I feel are key to achieving carbon neutrality :"

353 I gather that you are soliciting comments on your Climate Emergency Development Plan Document. Suffice it to say that it is a complete joke if you won't even take the necessary step of implementing an Article 4 to stop the most needless heavily polluting activity in Cornwall: the helicopter joyriding taking off every year for two weeks from Bussow Farm outside St Ives. And it is also a complete joke to talk about nature recovery when its flight path is over an about-to-be-designated SSSI due to its extremely rare birds. Really, how on earth do you expect us to continue to take you seriously? By the way I'm a former full Professor of Philosophy and Environmental Studies and a former member of the Board of Directors of Friends of the Earth. So my comments are not exactly based on complete ignorance. I trust that you will forward my comments directly to your Service Director for Planning & Sustainable Development.

357 I have read the entire document and find it well written and laudable and fully support it's aspirations. I just wish it wouldn't take so long to get to the implementation phase. My concerns are: 1.There is nothing about helping the residents of Cornwall to understand the behaviour changes that will be required of them. There needs to be a public education strategy not just based on Council websites which few seem to be inspired to access. It needs a very active campaign that impacts on their day to day behaviour and feeds it to them in bite sized pieces through a range of media and events. The aspirations are only achievable through the engagement of the population and you need to find a way to get the majority of them signed up to it. 2. There is nothing directly about promoting eco-tourism or about 3. the need for more allotments. 4. In our area there are narrow 'quiet lanes' which as a cyclist I often find far from quiet as cars and lorries use them as short cuts and often drive far too fast. Could there be more emphasis on access only (apart from pedestrians and bikes) and/or speed limits as they are essential for walkers and cyclists who want to avoid the dangers of so many main roads without cycle lanes. 5. Should solar power be restricted to sustainable land use sites or would it limit the provision of renewables too much?"


361 "I am writing in response to your consultation for locals in Cornwall regarding climate change. I think the country and county is well aware that we need to do something, but erecting more and more turbines in Cornwall is not the answer. You appear to forget that this is a county of natural beauty that holiday makers from the rest of the UK are keen to visit and turbines will wreck the scenery and there will, as a result be a negative impact on Cornwall’s economy. THEY WILL NOT COME HERE. THEY WILL GO TO DEVON. Don’t you think this county has more than its fair share of renewables? There are areas in Cornwall that are an absolute eyesore as a result of fields of turbines or solar panels. Around our village of Grampound we have a number of turbines including two massive ones. When an application went in for a further turbine three years ago the village was up in arms which resulted in 300+ signatures protesting. I think the vast majority of residents in Cornwall have had enough of the Council allowing more turbines resulting in a blight on their County. Why on earth don’t you explore wave power. We are surrounded by the sea. Has anyone explored this natural renewable? Or is it just convenient for the council to let others undertake the work for them? Please, please, please, consider this beautiful county – NO MORE TURBINES."

362 The first point to make is that, when it comes to the flora, Cornwall is the most comprehensively and intensively surveyed region in Britain. More is known about the wild flowers of Cornwall than anywhere else in Britain (this is true of a number of other taxonomic groups also). Indeed Cornwall has been systematically surveyed twice in the last thirty years. The first was an eleven year survey of every 2km square by Botanical Society for Britain & Ireland (BSBI) volunteers which was published in 1999 as a Flora of Cornwall. The second was a survey of every 1km square (3940 squares) which began in 2007 and culminated in the publication of A Flora of Cornwall in July this year. During the latter survey the use of GPS devices meant the majority of the data gathered was at a much higher resolution than 1km square. CORNWALL'S BIODIVERSITY The Cornish are one of the nations that make up the British Isles with a language and culture closely related to those of Brittany and Wales. It is this culture that has shaped the distinctive landscape that Cornwall has today, moulded over thousands of years by the indigenous people who have worked the land, and the minerals contained beneath. This legacy is a largely treeless landscape, with a diffuse settlement pattern, clothed by a patchwork of relatively small fields, bounded by Cornish Hedges, together with sizeable semi-natural areas of moorland, heath and mine sites, all surrounded by spectacular coastal scenery. This mosaic of man-made and semi-natural habitats has tremendous diversity due to the small size and variety of its individual constituent parts and the juxtaposition of contrasting plant communities. One of the most important distinguishing features of Cornwall is the comparative lack of trees, which is not just a defining character of the scenery but is critically important to the wildlife, as the areas of Cornwall with the greatest nature conservation value are invariably those with no or very little tree cover. Such open communities are the essence of Cornwall’s unique landscape which attracts vast numbers of tourists each year. TREE COVER


18.1.5 Afforestation is totally wrong for Cornwall - both its distinctiveness and its biodiversity. Woodland - If wildlife habitats were ranked in order of wildlife conservation importance Cornish woodlands would appear at the bottom of that list. Woodlands are the least important plant habitat because they are poor in species richness, contain very few rare or threatened species, are mostly secondary woodland or plantation and are generally dominated by alien tree and shrub species. The reasons for the lowly status of Cornish woods is mainly historical. Cornwall was cleared early and pretty effectively in prehistoric times and this clearance wiped out tree species and their associated ground flora and fauna from most of Cornwall. Whilst some species were able to adapt and find a new home in the moorlands, such as Bluebell (Hyacinthoides non-scripta), Wood-sorrel (Oxalis acetosella) and Wood Anemone (Anemone nemorosa), a significant number would have disappeared altogether. For much of Cornwall treeless conditions were then maintained for many centuries such that when secondary woodland eventually was able to develop the available pool of woodland fauna and flora to colonise was very limited. Consequently, the woodlands of Cornwall are poor in species richness and generally poor for nature conservation. Well over 90% of Cornish woods are either secondary woodland or plantation. Even the small percentage that is officially designated as ancient woodland is mostly secondary woodland and, with a few exceptions, little better than undesignated woods. Furthermore, many woodlands are dominated by alien trees and shrubs including Beech, Sycamore, Lime, Sweet Chestnut, Holm Oak, Turkey Oak, Laurel, Rhododendron and conifers. Very few rare or threatened species grow in Cornish woods: • 466 flowering plants and ferns are designated as rare or threatened (31% of native species) in Cornwall. • Only 29 of these are woodland species (6%). • Only 4 are trees. Thus 94% of rare and threatened plants are not woodland species. Instead those key species overwhelmingly grow in open habitats - heaths, moors, Culm grassland, marshes, bogs, mine sites, maritime grassland, saltmarshes and arable fields. Such open communities are the essence of Cornwall and define the landscape that attracts tourists in their droves - they do not come to see woodland! Finally, the proposal by Cornwall Council to create a forest for Cornwall is fundamentally wrong. It ignores 4000 years of Cornish history and will undoubtedly do much more damage to the environment than good, by inevitably destroying better habitat and replacing it with low grade woodland. Instead Cornwall Council should concentrate on improving the existing stock of woodland through management such as coppicing. The overriding concern for one and all should be the retention of Cornwall’s distinctiveness! • Cornwall has a lower than average tree cover at around 10%, and it is vital that trees are not lost in new development or replaced with other habitat types. All applications for major development will need to demonstrate through the biodiversity metric that there will not be a net loss of canopy cover by retaining existing trees and hedges where possible and enhancing canopy cover provision. This will be measured for major developments by the DEFRA metric, with the specific requirement that all canopy providing habitat types (e.g. woodland, hedges, street


trees, orchards etc) achieve no net loss, on top of the requirement for a 10% minimum net gain overall. As indicated above, having such a low percentage tree cover is one of Cornwall's greatest assets for biodiversity and is a defining character of its landscape. Development proposals should deliver gains for the environment and biodiversity. Development should not result in any net loss of canopy on site by means of the retention of existing canopy (including trees and hedges) and the planting of new canopy in the form of trees and hedges as reinforcement of existing hedges and woodland, street trees and other planting. The retention of Cornish Hedges is really important both for biodiversity and landscape reasons. Every opportunity should be used to build fresh Cornish Hedges in the planning process. Cornish Hedges should not, however, be considered as canopy as many of the finest in Cornwall have no trees or shrubs present. CORNWALL'S BIODIVERSITY The draft policy suggestions of the DPD recognise the critical importance of biodiversity in relation to climate change and further embeds the Council’s Environmental Growth Strategy and the emerging approaches to nature recovery. The Climate Emergency Development Plan Document makes the critically important points: ‘sustain local distinctiveness and character and protect and where possible enhance Cornwall’s natural environment and assets…’ ‘conserve, protect and where possible enhance biodiversity…’ But what is distinctive about cornwall? The Cornish are one of the nations that make up the British Isles with a language and culture closely related to those of Brittany and Wales. It is this culture that has shaped the distinctive landscape that Cornwall has today, moulded over thousands of years by the indigenous people who have worked the land, and the minerals contained beneath. This legacy is a largely treeless landscape, with a diffuse settlement pattern, clothed by a patchwork of relatively small fields, bounded by Cornish Hedges, together with sizeable semi-natural areas of moorland, heath and mine sites, all surrounded by spectacular coastal scenery. This mosaic of man-made and semi-natural habitats has tremendous diversity due to the small size and variety of its individual constituent parts and the juxtaposition of contrasting plant communities.One of the most important distinguishing features of Cornwall is the comparative lack of trees, which is not just a defining character of the scenery but is critically important to the wildlife, as the areas of Cornwall with the greatest nature conservation value are invariably those with no or very little tree cover. Such open communities are the essence of Cornwall’s unique landscape which attracts vast numbers of tourists each year.

363 Please find attached my comments on your consultation document.1 Conclusion; As always I like to simplify and clarify so that plain actions are taken in plain view of everyone. We know developers are out to get as many houses preferably big expensive ones as they can everywhere to maximise their profits. That is the nature of property development and property developers. The function of the Council is to ensure that the developers do not turn Cornwall into Blackpool or Brighton although they have got a pretty firm foothold in Newquay already. Some of these are old saws like building on flood plains, anaerobic digestion and riparian maintenance. Will anything ever change? There is a lot of ground that has been covered before so some of my comments may be familiar. Perhaps one day some things will change before I run out of breath? Am


I holding my breath? Not recommended. I see it is an early draft so I hope that the finished thing will be unblemished by language and typing errors without me having to copy edit it. Please acknowledge receipt of my e mail and attachment as I am working in Eswatini just now.

364 Dydh da Planning department Konsel Kernow, I have read right through as many documents as I can on this consultation. I am sorry but I find the complete ignorance of Kernow her people and our culture, by who ever wrote all of this, to be a disgrace for us all. Have all the people in this department come to Kernow from some other part of Pow Sows? And believe themselves to be superior to us Kernewek.? Firstly; because we have been constantly mining in EVERY PART of Kernow, for the last four to five thousand years, there is no part of our country that has not got mine workings and mine shafts in it. So for crooked builders to ignore this fact is very dangerous, for the people who are silly enough to purchase, or have to live in the houses when the area has not been completely tested by lieder which is the best way to find if there is a mine shaft or air shaft under the land. Because; no one knows where all the mines are that where dug there thousands of years ago. Over the last fifty or so years, many houses have had to be demolished because of this fact. Secondly; Do the people of this department know that ALL our power comes into Kernow from the EDF nuclear power station in Somerset? And, they will not permit any power to be entered on to the power line to undermine them. That is why the marvellous Hayle project was not permitted. The power line also only takes power from one direction, so no power can travel in the opposite direction out of Kernow. So, most of the power that is produced in Kernow is wasted at this time. Unless the company that owns it can use it for its own purpose. We need to have the power able to leave Kernow and travel to the rest of the UK.

365 I was sent the poster inviting comments on helping to address the climate emergency. My comments are as follows: The Authorities mustn’t allow any more animal agriculture and encourage existing to convert to plant agriculture as Animal Agriculture causes so much pollution and use of resources for a smaller return. Land use for green energy needs to be encouraged BUT please don’t just put all the solar farms in ‘poorer areas’ such as the Clays, St Stephen for example, already has its fair share of these. Please don’t allow housing to be built where there isn’t the infrastructure to support it especially now the government is relaxing restrictions massively. New houses should have solar panels and other measures to reduce carbon footprint.

366 Duty to cooperate response - no comments

368 I have to raise a concern that in the section relating to Geothermal Energy your sentence infers that as areas of specific interest for the generation of geothermal energy have not yet been fully identified then there should be no protection from development - for other uses . I find this a very negative approach to what may well prove to be the biggest single opportunity for our County for the development of a natural power resource. There are studies that have been carried out identifying probable areas of significant interest for production of geothermal energy and these should be taken into


account when completing this document. At the very least temporary planning restrictions should be put in place until these areas have been properly explored. An example is the Hayle development. Hayle sits only a few miles away from a possible area of a major geothermal structure and I have written and expressed my views on this previously. The long term future for cheap and never ending renewables for Cornwall is geothermal. Please protect possible areas of generation from future planning development. Please.

369 As a regular cyclist I agree with the proposals to cater increasingly for cyclists. During lockdown I have spoken with many people who have said that they would cycle more but they are scared of the traffic so I think that there should be a lot of thought given to creating more lanes for cycling which are substantial and therefore reassuringly separated from vehicles. If this is at the detriment of available space for cars, so be it. My wife and I travel in Europe and we have seen buses that have space to carry bikes. This is a winner, I think, because it will be mutually beneficial to both forms of transport. If buses could deliver bikes and riders to a suitable destination people could then ride back from whence they came on suitable country lanes. Buses get used more and people are encouraged to get on their bikes. Healthier people. My wife and I would buy an electric car if only there were more charging points available During lockdown people have got into gardening. This I interpret as an indication that there is a latent demand for more allotments. I would hope that Cornwall Council would look favourably on any planning applications for change of use to allotments. I suspect that this aspect of climate change prevention is not within your remit but in whatever way possible I hope that Cornwall Council would encourage farmers to keep fewer cattle and sheep and people to eat less red meat. A study done by Oxford, Cambridge and Aberdeen universities has shown that lowland grassland can only sequestrate 40% of CO2 in the form of methane. Cornish farmers do have a lot of cattle and sheep. I agree with all that was said about the care of the environment but I would like to emphasize the importance of wildlife corridors .

370 Good day. My name is David Forsyth and I currently live in falmouth and run a design business here. I have became aware of the climate change development plan and would love to talk it over a little with someone as I cant find out all the information online. is it possible for someone to give me a call to talk about it and how to show an interest in this new scheme that is about to start.

371 I am looking at the above document that I think is about 8 years old and Cornwall Council's interesting and current Climate Emergency Development Plan Document Draft Policies consultation August 2020. I am wondering what progress has been made with this net carbon negative, biodiversity, soil, energy and food positive, One Planet development for Alternative living in Cornwall? Are there more recent documents available?


Has any work been done to establish areas where a regenerative approach, tree planning, nature recovery and restoration /management of neglected habitats such as woodland, marshland, heathland /rewild the most marginal agricultural land, as mentioned in the original report, where such developments might be encouraged?

372 Would it be possible to talk with somebody regarding climatechange.dpd as we here at Unique Domes are developing a new bespoke office and education Dome for schools please could you take five minutes to look at our web site to see if we fit in with you. www,uniquedomes.co.uk

373 I have not read the whole Climate Emergency document or the Sustainability Appraisal, however have quickly glanced through aspects of them relating to car use and Transport links. I think that since the easing of lockdown there has been a very significant return to road transport, either privately or commercially, and that, having enjoyed the brief absence of it ( and the improved air quailty), we should now attempt to reduce it significantly. Your reports stress ""convenience"" and the way in which people's "" behaviour"" may be influenced. There is also a related issue to which you refer- Planning and local development. It is clear to me that private cars are an integral part of any new development, apart from design for reuse of redundant buildings in city-centres, and the location of such development is viewed by planning authorities in relation to car-use, as there is often little viable alternative. I would like to see the implementing of a reward system for those who forgo use of private transport for many areas of daily life. ( it already exists in some centres, such as reduced price entry to Eden Project).Perhaps this could be introduced in public facilities such as leisure-centres, or by imposing a community-tariff for use of out- of town- shopping carparks? The building of Park and Ride with E.U.subsidised funding has had a bonus effect on those who work or shop in Truro, while the present poor public transport links to this town have persisted( though I do not think this is beyond remedy.) Ultimately we must hope that a way to increase undamaging environmental private car usage will be extended, as motor manufacture moves in this direction, but meanwhile let us try to nudge people through creative policies towards cutting their reliance on private transport, whether for convenience or out of necessity. The community benefits of cleaner air and health should be an incentive for people to come on board.

375 I have read through this plan and wholeheartedly support it.

376 Thank you for consulting on the Cornwall Climate Emergency Draft DPD. We recognise the hard work that has gone in so far, especially considering the difficult circumstances. Effective consultation relies on feedback, so we would like to set out our thoughts. A forward looking DPD would create policies that promote the development in a manner that responds to the Climate Emergency and delivers Carbon Neutrality, or Net Zero. Cornwall Council has stated with laudable ambition that this must happen by 2030. It is not clear if the Planning Department of Cornwall Council has been fully briefed on the significance of what is needed to meet this target. To provide some scale, in the next nine years we have to develop, finance, and build between 10 and 20 times more renewable energy capacity than has been installed in total over the past 20 years. This will create a Carbon Neutral Cornwall, which itself can only be an interim target. In time we must aim for a Carbon Negative Cornwall.


The Draft DPD may have Climate Emergency in its title, but it appears to have been written with pre-Climate Emergency thinking. “Fossil Fuels” appears just once in a document that should be all about planning to reduce dependency upon them. “Landscape” features 12 times, “Heritage” 13 times – the tone of the document is wrong. Cornwall must change its mindset if it is to seriously address the Climate Emergency. Instead of writing fresh policies to promote the replacement of fossil fuels and the development of renewable energy it has, for example, contorted the wording of policies to fit with an outdated NPPF, in particular paragraph 154, footnote 49 (also known as the Written Ministerial Statement

377 Climate Emergency Development Plan Consultation August – September 2020 Representations on behalf of National Grid Response We have reviewed the above document and can confirm that National Grid has no comments to make in response to this consultation.

351 Sorry, I cannot grip the pen to write, nor can I fill in Forms via internet, nor can I hold opinion ,on subjects I know little about. Could somebody take my views , if significant and feed them into the pool , for me. Firstly , I am glad you are incorporating Kate Raworth’s Doughnut Economic principles into your own. Secondly, I am pleased that you are seemingly, prepared to listen to your rate payers. Thirdly , I hope you will face in just one direction, not in two opposite directions. Fourthly, I hope you will stand firm in your dealings with HMG. Generally The Absurdities of incineration are a matter of hilarity, if the matter wasn’t so serious . Can you really believe the Environment AGENCY would give permits to incinerator companies to set light to material we can use, to emit tonnes of Carbon Dioxide to the air, to acidify the seas and damage and thin the shells of crustaceans knowing the world is on fire, due mainly to Global Warming . Methane gas , which has been locked in icy ground is being released ,to foul our air for around 12 yrs. The Carbon Dioxide emitted from unnecessary or over indulgent industries like incineration and aviation and selfish transport is turning our world into a No Go planet. At least Cornwall has no excuse now, not to have its own electric grid ,powered by wind , solar and geo thermal energy to provide free transport run on rails. One mention of Corona Virus. This pandemic may be found to sit squarely on the shoulders of AIR. POLLUTION, weakening our immune systems."

380 I believe, in order to encourage participation & improve things - the waste & recycling collection needs much improvement. I think you already know the flimsy recycling bags are inadequate and we're overdue wheelie bins. But also we need to have food waste collection bins. In addition there needs to be more points for recycling plastic bags/plastic film & tetra paks which are used more than ever with the uptake in dairy milk alternatives. At the moment we have to collect separately from the rest of the recycling & travel to other towns to take for recycling. We find this difficult & I suspect as a result, the majority of people just don't recycle them. These need to be added to doorstep collection or at least provide multiple collection points in every town. These few things alone, if handled efficiently, could vastly reduce land fill. In addition you need to find out why some people don't recycle at all. If they can't, you need to address this & find solutions to enable them. For those


who could recycle but are just too lazy - these people need strong encouragement. Home composting could be encouraged, educated about & made easier. And people need to consider fast fashion, be educated on reducing waste and consider materials used. It would help if children & teens were educated. Their attitude & knowledge would help change next generations but hopefully positively influence their parents attitudes. Overall, in comparison to many other local councils, our range of recycling points & type/range of collection, falls short. It need updating & improving if we're to encourage a more eco friendly Cornwall. I'd hope this will go towards encouraging more people to take individual responsibility and action. And make it possible to meet Cornwall's ecoogical plans.

381 Regarding the climate change emergency which is supported by my local parish council at Feock. My name is Sally Austin Brown and Cornwall has been my home for the past 40 years. I enclose a Mind Map of my thoughts and I hope you have been radically inspired by the ideas you have received. Climate Change Develoment PLan in clucing infrastructure. Support local Shops, Green Companies with Green Jobs, Newquay Airport , Refuse funding for Richard Bransons Rocket Project. Local Housing Increase taxes on second homes and holiday lets.Respect the Environment

383 Thank you on behalf of Devon and Cornwall Police for the opportunity to comment on this DPD. For information I reference Secured By Design (SBD) in this response. SBD is the national Police crime prevention initiative. The SBD website is www.securedbydesign.com where there is a wealth of information including design guides and also Police approved certificated standards and links to companies and products that meet these for example approved cycle stands etc

384 Since Cornwall became a Unitary Authority planning policies have become a lot more transparent. I do not envy the job you have to do in trying to protect one of the most beautiful landscapes in the country whilst trying to ensure that it develops and prospers. Since all things are inter-related it is worth being mindful that allowing one thing may well destroy something else. I have jotted down a few points that I think are relevant to the discussion. • There needs to be strict control over the amount of countryside that is concreted over. Once all the beautiful and open countryside is taken for housing and every few miles there is a Premier Inn what will be the point of coming to Cornwall at all. • Housing that is provided must be for local families who can neither afford to rent or buy. When you are on £8.50 an hour and rents in Helston are around £1,000 pcm how do young Cornish families survive. • Our new housing stock is cheap for anyone from the south east of the country to swoop in and buy as a holiday let. I live in the Lizard village and a significant number of the properties are empty for most of the year, but we don’t have enough housing so we have to build more. • Brownfield sites must be used for development first. The regeneration of these sites in Redruth is something to be proud of. • I am fed up with the number of times that the planning application states that there will be an associated school or doctor’s surgery built. Do these things ever


materialise? However, that is only part of the issue, a vast influx of people not only require schools and doctors but hospitals. When central government says that you must build your quota of houses tell them that it will not happen unless they build more hospitals. Every year the RCH goes on black alert as its capacity is exceeded. • I applaud all the renewable energy schemes, and the support that you give to the Cornish Language, but these schemes have to be given on-going support. It can’t be a case of ‘oh well we have ticked the Cornish language box so that is alright then’. • What Cornwall needs is a ‘Czar for Cornwall’ someone who oversees all policy decisions in Council and says ‘this is right for Cornwall’ or has the foresight and courage to say ‘No this is wrong and disrespects our unique cultural heritage’. • I was born in Cornwall a long time ago and have seen a number of changes. As a girl Newquay was a sweet little village and Falmouth was a place that was pretty rough. Now Falmouth is a lovely holiday spot and well, the less said about Newquay the better. I have not been to Newquay for some time and I believe that you have stopped all the drunken orgies but the plethora of gift shops were full of vulgar tat that would not have looked out of place in Skegness. • One thing that will always remain untouched will be the land between the tides because no one can build on that. However, it is possible to over-develop land overlooking the sea. Jet ski’s disturbing both bathers and wildlife can all add to spoiling something that is inherently beautiful. • If we are going to try to ameliorate climate change, we need to stop losing green spaces. Farmers need to be encouraged to grow those ‘pea crops’ that can be used to made edible alternatives to plastics wrapping. The leguminous crops photosynthesise, thus removing Carbon Dioxide from the air, also adding nitrogen compounds to the soil. • We need to grow more of our own food so that in the case of emergencies we can be better prepared to feed our nation. • As electric cars become more affordable there will be a need for more charging points. • When new roads are built there need to be more consideration given to cycle lanes. • More support for people to install their own wind turbines. • Stopping developers from land banking. Fields are cheap, land for building is expensive. So, if you can buy a field and build on it you are ‘quid’s-in’. Actually, what I have observed is that some developers cut off the edge of a field so that is no longer of use for anything other that building on. What the council needs to do is say ‘you are building on these 3 acres of agricultural land so you will pay the council the difference between what you have paid and what it would cost as building land’. • Double the cost of council tax on all second homes unless they can prove that they are available for rent to local people off season. • Stop developers reneging on affordable housing. • Extending the scheme that was/is operating in St Ives to ensure that second homes are severely restricted. This should be extended to all costal locations where the majority of houses are second homes and hence empty for the major part of the year.


• I don’t think there is a shortage of housing in Cornwall. There is a shortage of available and affordable housing. • Support all household in becoming energy neutral by being able to generate their own electricity. Subsidising solar panels and storage batteries. • Fit all new housing with solar panels. It is now possible to tile a roof with solar panel tiles, this is energy efficient and aesthetically pleasing.

385 Sustainable Pendeen is a part of the work of The Centre of Pendeen, (community centre). It hosts a variety of free, public awareness raising events about environmentally friendly living and sustainability in the locality; information about these events can be found on the above website. At Sustainable Pendeen events we actively seek and record feedback about the event subject from attendees and the feedback on this DPD is based on the comments we received at two all-day events in August and November 2019, the first event was about electric vehicles, the second about sustainable homes. Sustainable Pendeen feedback will therefore be focused on sections 16, 17 and 18 of the DPD. It is noted that the Council has an aim of zero carbon emissions for Cornwall by 2030. While this DPD shows an appetite for moving towards cleaner and more sustainable ways of living and development, there are no quantifiable targets set out in the document. It is therefore difficult to know what weighting the Council is placing on the various policies and the expected proportion of their efficacy in achieving the goal of zero emissions.

034 We know that to achieve our ambitions by 2030 may well prove impossible; but we will not back away from the challenge, not trying is worse than doing nothing.” History tells us that this is simply not true. Doing nothing is often the best option. Changes made by man usually have a negative impact on other species or systems: not interfering with nature can produce excellent outcomes. Another thing history teaches is that when you fail, or know that you will fail, consider another option. Planning means adapting to circumstances, not proceeding blindly along a fixed path. Everyone else is aiming for net zero carbon emissions by 2040 or 2050. Cornwall Council should not be forming policies on an objective which is more likely to fail than succeed. Rather than plan for failure, look to partnership working for a common goal or even phased goals. Failure will precipitate demoralisation and reaction. Seeking to encourage people to invest in failure is poor leadership: there was nothing heroic about the Charge of the Light Brigade. It is still not too late to change the target date. 1.0.3. To what extent does the Cornwall Local Plan act against actions precipitated by a Climate Emergency? For example, the number of new houses required in the Plan (which well exceeds the indigenous demand); new road building and widening; the airport; the Stadium?"

386 "Thank you for providing Highways England with the opportunity to comment on the August 2020 Climate Emergency DPD, Draft Policies consultation. Highways England is responsible for operating, maintaining, renewing and improving the strategic road network (SRN) which in Cornwall comprises the A30 and A38 trunk roads. It is the light of these responsibilities that are comments are made. We are supportive of the Climate Emergency DPD, particularly with regards to creating sustainable and connected places that reduce the need to travel and seek


to change travel behaviours especially for shorter trips. The SRN fulfils a strategic function to enable the safe, effective and efficient long distance movement of people and goods and makes a significant contribution to enabling and sustaining economic growth, prosperity and productivity, while also contributing to wider sustainability objectives and improved accessibility to key economic and social services. This strategic function is unlikely to change and we therefore need to ensure, and where necessary safeguard our network so that it continues to be fit for purpose now and into the future. We note that within the aims section, reference is made to targeting CIL towards projects which lead to carbon neutrality supported by low carbon infrastructure. We would welcome further clarification here to ensure that this does not jeopardise funding streams for strategic highway interventions that may be identified as necessary to enable planned growth to come forward, or address existing safety or capacity constraints. Whilst recognising the value of “green” measures, these do not negate the need for or importance of highways schemes where appropriate. "

387 Linkinhorne Parish Council welcomes the approach and principles that Cornwall Council are adopting and seeking to embed within the planning framework and looks forward to it development.

122 "CLIMATE EMERGENCY DEVELOPMENT PLAN DOCUMENT ('the Document') Finally, we would ask that you keep us on your mailing list. In particular please notify us as soon as possible when the Policies Map is available for comment. We are also willing to speak at the examination of the DPD, particularly if the final draft policies do not differentiate between land within and affecting the setting of the AONB and land without the AONB. Draft Policies Consultation I write as Chairman of the above Society with our comments on the above document. This letter has been approved by the committee (technically the board) of the Society."

126 "Firstly, I would like to thank those involved for the developing the dpd to this point and particularly for the high level of consultation. It considers the climate and ecological emergency with more seriousness, depth and inclusiveness than any local government document that I have seen before. As a broad comment on reading the dpd, it comes firmly from the perspective of continued growth and infinite development. I cannot see any mention of capping or limiting future building of any type. ""Support the economy"" is given as the first principle in Future Cornwall. The targets for house building for the county have been arrived at with little public scrutiny and the council having its own building company - at the very least - muddies the waters of its decision making process. The lowest carbon option is always not to build and Cornwall currently and since the 1990's has seen a huge ammount of building of large scale housing, holiday complexes, industrial estates and industrial agricultural buildings and infrastructure. CC has targets for approving housing, which are not sustainable and are overwhelmingly opposed by the local population. Planning permission for large industrial or housing estates by national building companies seems easy to achieve despite public opposition, whilst small, low impact developments are often subjected to the full


force of the planning process and restriction I am glad to see this last point addressed to some extent in policy AG. I believe that managed degrowth is vital to achieve carbon neutrality. In the wider context of Cornwall Council as a whole, I believe that a formal citizens assembly, the conclusions of which are legally binding is necessary to change the conventional, institutionalised nature of local policy making with the needed rapidity. I broadly agree with C1, but would like to see degrowth at least mentioned - even if enshrining it in law at this time is considered too radical. I would favour a 20% biodiversity increase on large developments, as I think that 10%, with a ""creative"" assessment by the develper, may ammount only a few token trees being planted. Likewise, an urban greening factor for small sites seems to me to be an anchievable improvement. I would like to see the consideration of removable dwellings in the countryside linked to measurable improvements in biodiversity - with the proviso that CC has the money and the ""teeth"" to investigate and remove developments granted with this condition which are not fulfilling the conditions imposed. With rural developments of housing and retail with the aim of reducing travel - the devil is in the detail and I could see this being used by developers to justify building on green field sites with the justification that there is, for instance, a vilage shop included in the application. Correctly policed, the policy could allow villages to build appropriate local needs housing and small retail enterprises. My concerns centre around a lack of full consultation with the local community and the possibility of inappropriate development being granted at appeal using this exception. I broadly approve of diversification of town centres, with the retention of historic architecture. I approve of restricting parking spaces and the provision of electric charging points. I support the use of historic railway line as new cycle routes, particularly where this provides a transport link and goes beyond being only a leisure amenity. I am strongly in favour of safe cycle lanes on the existing road network. I would like to see bus fares subsidised. There should be an assumption of no new road building in the county, with any exceptions being thoroughly and publically scrutinised. I strongly support a degree of community ownership for renewable energy. I strongly support higher energy efficiency standards for new buildings and, where CC are able to influence, supprt retrofitting for older buildings and higher standards in conversion and alterations to existing buildings. I am quite happy to see an historic building with, for instance solar thermal on the roof. Preference in planning should be given to low carbon building materials, techniques and to a significant ammount of on site renewables. These could be included as conditions in the planning approval to ensure compliance. I would support greater planning control over farm development, particularly where this is likely to emit pollution, such as slurry pits or large pig or poultry units.


I think that the council should offer no protection to vulnerable coastal areas, including towns and villages, as sea level rise and storm surge will rapidly become an insolluble problem. I would like the council to be explicit in publicising this decision and the reasons for it and therefore fulfill its role in raising public awareness of the climate and ecological emergency.

391 I think you should include a planning regulation that all new houses MUST have some form of renewable energy ie solar, ground source or airsource. Larger developments could have a shared wind turbine, All housing should have adequate roof and wall insulation. Older houses should have a grant to reduce their energy usage. Households use of energy creates a high percentage of our total carbon emissions.. I can't see anything in the document about Lithium. The government need to fund the development of this miming opportunity for Cornwall which will hasten the development and usage of batteries for electric cars. I do hope your excellent plans will come to full fruision.

392 "I am writing in response of the One Planet proposal, with my views on the matter. Firstly i would like to comment on what a very wonderful and great opportunity this will be for the growing number of people who are of this mindset already. I think something needs to be done with land and opportunity to people who want to live on it. Everything is very expensive today, land, houses, whatever, its hard to believe. I understand and know there to be many people who already live this way of life within Cornwall, and not only live but thrive off of the land in such a way that gives back to the land and community rather than take from it. So firstly i would like to point out a few things i feel may be slightly juxtaposing to the actual reality of liveing on and off of the land, self supporting and sufficient in ones own produce, livelihood and home life. I think that the first bullet point outlining that it needs to be connected in some way to an already existing building etc. To be only aiming at a certain background of people, to whom have a lot of money. I also understand that it says otherwise to live on the land where it can be justified in terms of the activity being carried out, which i agree with. I think if people are serious about living on the land in such a way as to be low impact then that should be sufficient to warrant it. Farming is a very labour intensive lifestyle, living on the land is a very hard and arduous way to live, and that's why modern man lives the way he does now ! Although saying that there are many many people doing it and have been doing it the entire way through the last centuries, because they realise it to be the better way of life for the planet and ones self.


I myself have lived on the land for a number of years now, and i can tell you that it isn't easy especially if you have been brought up in such a way that is opposite to it. I would love to see people have the opportunity to give back to their communities, to the people of Cornwall in a way that shows them nature is key. I think that to deliver a zero carbon approach in construction is a very hard task to meet. For one even if someone was to insulate their ho.e with hay bales rather than kingspan hard insulation board, the carbon emissions are probably drastically lower but still evident, due to having needing a tractor to make the bales. Unless one sets out to the field with a sycth and cuts grass and make hay bales that would be a extremely intensive task, not un doable, but hard none the less. One could collect pre used timber or fallen trees from near by in construction. But in this day and age there will always be a carbon usage somewhere, but maybe offsetting would be a good idea to add here. To be self sufficient in energy, water and waste is a contradiction to the above. To be sufficient in solar, needs at first a big layout of money that requires someone to make batteries, solar panels, wiring, this all requires chemicals, metals, glass all sorts of strange and possibly toxic materials, again carbon. To be sufficient in water means getting the services of someone who can drill into the earth using more than likely a desiel engine and fuel. Again Carbon. Waste again if in the ways of tin cans, plastic etc. Is no good to just take to the general waste. Again all of the 3 above are come from carbon and also mean having a lot of money to implement these in the first place. How is any of this going to be possible if the outside world doesn't change along side of the one planet scheme ? I am all for the scheme, i want the scheme to be available to people who truly want to live low impact, self sustaining lives, who can help, teach and provide for food resources for others in the community, but the leash shouldnt be around their necks, the rope shouldn't be that tight. When the wider world is doing practically zero to stop deforestation, or huge oil tankers spilling oil every other week. So here's some people that want to do good for their planet why restrict them ? Let them do it, they know how ! I whole heartedly agree with the regeneration of the site they live on, anyone who's studied permaculture, will be planting trees that are beneficial in fruit and nut, for wildlife, for the land etc. Regeneration is key now more than ever especially after years of destroying the country in the name of progress but in fact its been regress. The simple act of planting fruit and nut trees has so many great implications. To meet the needs of the residents is also a good point, this should be a key part, and anyone who will be taking on the scheme i should imagine would have this at the forefront of their minds."

021 Stithians Parish Council (SPC) was instrumental in setting up and actively involved in the activities of Stithians Energy Group (SEG). SPC delegated their response to the above consultation to SEG.


At the September Parish Council meeting, held on Tuesday 15th September 2020, Members unanimously endorsed the SEG response. We would therefore appreciate that you consider all the comments made by SEG to also be the considered view of SPC for the purpose of this consultation.

394 "The St Austell Town Council’s Community Committee discussed the draft Climate Emergency Development Plan document (DPD) at its meeting on the 14th September 2020. Members welcomed the document and felt that it was well drafted.

297 Water quantity/supply. Consideration should be given to water quantity/supply issues. For instance, will new storage be required for water storage? Also, should policies be included to ensure and maximise the availability of freshwater. Glossary A glossary of terms would be useful at the of the document, for instance to explain terms such as natural capital, natural climate solutions, ecosystem services and, climate change adaptation and mitigation

041 "Please find attached our response to the Cornwall Climate Emergency DPD Consultation Many thanks for all your hard work on this. Overall we think this is an amazing document of which Cornwall Council can be very proud.

253 "14,6,2 Cohousing. It is good to see mention of cohousing in the document. Within our group we have 2 board members of the UK cohousing network. (UKCN) Cohousing can be new build or retrofit. We would like to encourage Cornwall Council to consider such developments should they be able to provide social housing. They do have a lower carbon footprint, can provide affordable housing and address the issue of isolation. They can also be intergenerational or for older groups. There is some work underway at UKCN to provide a good definition of Cohousing for planning purposes. It would be good if Cornwall could also undertake this. With the possible demise of S106 agreements some other way of ensuring the cohousing community remains in perpetuity. Should a definition and the perpetuity issues be resolved perhaps policies as suggested below could be considered. Cohousing will be allowed on exception sites provided they provide (50%?) Affordable housing. The definition of ‘affordable’ housing should be changed to include low-cost homes that are part of a community or self-build scheme. Retrofit cohousing or rural Cohousing. Any existing buildings associated with the Cohousing proposal will be allowed to change holiday planning permission to residential. There will be a presumption in favour of additional small buildings or changes of use to residential provided they would qualify as affordable housing."

005 "Hayle Town Council is happy to endorse the document and support Cornwall Council's endeavours excluding policies CC1 and T1-T3 inc. Members feel that Policies T1-T3 are not ambitious enough and do not include sufficient detail on modal shift and Policy C1 needs to go further to protect areas, like Hayle, from erosion.

401 I would like to praise whoever the team behind this is.


Concisely put together ideas and proposals which should be able to make a real impact. By using the Doughnut Economics model to then make the decisions is truly amazing. Thank you for working so hard.

402 "SECTION 1 INTRODUCTION Cornwall Council’s Invitation 1.1 Cornwall Council have invited comments on the Planning for Climate Emergency Development Plan Document (DPD). Cornwall declared a climate emergency in January 2019 and this document will seek to address climate change concerns within the authority and help the Council meet its aim of becoming carbon neutral by 2030. The Climate Emergency DPD will seek to strengthen the existing national and local plan policies relating to climate change, and help the Council protect and shape the future of Cornwall. 1.2 At this stage, the Council are requesting comments on the draft policies proposed for inclusion within the Planning for Climate Emergency DPD. Following this round of consultation, it’s understood a further official consultation period will take place. 1.3 Once adopted the Planning for Climate Emergency DPD will site beneath the adopted Local Plan and support its strategic policies. The document will be a material consideration in the determination of planning applications and, as a Development Plan Document, will hold greater weight than Supplementary Planning Documents. Instructions 1.4 The Leith Planning Group have been instructed by EPC-UK to review the policies proposed within the Planning for Climate Emergency DPD and make representations as necessary. Context 1.5 EPC-UK are a leading commercial explosive, drilling and blasting company with sites from the Shetland Islands through to Cornwall. Representations are being made on the Climate Emergency DPD due to the EPC-UK Longstones depot being located within the Authority, close to Nanpean. 1.6 We currently monitor planning applications within a given radius of a number of EPCUK sites, including Longstones, such that we can establish whether there would be any detrimental impacts from development on the operation and viability of the existing depot. We evaluate each application to ensure that the proposed development would not adversely impact our client’s site commercially, or pose a risk to safety due to the operations which take place at the site. We also review progress of the Local Plans and Supplementary Planning Documents within the relevant authorities and make representations as necessary. Submission Content


1.7 This document answers the questions of relevance to the policies of reference within the draft Climate Emergency DPD, as well as providing comments more generally on the draft document. This submission has been set out to address the policies and associated questions in order before providing a general comment. A conclusion has been provided at Section 4. SECTION 2 LEGISLATION AND REGULATIONS Legislation Planning and Compulsory Purchase Act 2004 2.1 In drafting these representations due regard has been had to the content of The Planning and Compulsory Purchase Act 2004 and the duties it places on Local Planning Authorities. Particular attention is drawn to the following sections: 2.2 Section 13 refers to the need to keep an up to date evidence base. Section 19 details the process required in the preparation of Local Development Documents and reads: 19. Preparation of Local Development Documents (1) Local development documents must be prepared in accordance with the local development scheme (2) In preparing a local development document the local planning authority must have regard to – (a) national policies and advice contained in guidance issued by the Secretary of State; (b) the RSS for the region in which the area of the authority is situated, if the area is outside Greater London; (c) the spatial development strategy if the authority are a London borough or if any part of the authority’s area adjoins Greater London(d) the RSS of any region which adjoins the area of the authority; (e) the Wales Spatial Plan if any part of the authority’s area adjoins Wales; (f) the community strategy prepared by the authority; (g) the community strategy for any other authority whose area comprises any part of the area of the local planning authority;(h) any other local development document which has been adopted by the authority; (i) the resources likely to be available for implementing the proposals in the document; (j) such other matters as the Secretary of State prescribes. (3) In preparing the other local development documents the authority must also comply with their statement of community involvement. (4) But subsection (3) does not apply at any time before the authority have adopted their statement of community involvement. (5) The local planning authority must also – (a) carry out an appraisal of the sustainability of the proposals in each document; (b) prepare a report of the findings of the appraisal. (6) The Secretary of State may by regulations make provision – (a) as to any further documents which must be prepared by the authority in connection with the preparation of a local development document; (b) as to the form and content of such documents.


(7) The community strategy is the strategy prepared by an authority under section 4 of the Local Government Act 2000 (c. 22). 2.3 Sections 20 to 23 relate to the Examination of local development documents through to document adoption. It is assumed however, that the LPA has been mindful of the relevant sections of the Planning and Compulsory Purchase Act in the preparation of this plan. Regulations 2.4 The referable regulations governing Local Plans are contained in The Town and Country Planning (Local Planning) (England) Regulations 2012 (the ‘Regulations). The Regulations set out the Duty to Cooperate, the form and content of Local Plans, public participation, Local Plan preparation, Independent Examination through to document adoption. Once again, it is assumed that the Council will have paid the necessary regard to the content and requirements laid out within the Regulations in the preparation of this plan. General Comment 3.17 More generally, we feel it would be beneficial for the Council to place greater emphasis on encouraging communication between potential applicants/developers and existing landholders. By encouraging early engagement with existing businesses within the authority, prior to the submission of a planning application. Early engagement has the potential to improve the efficiency and effectiveness of the planning system and enables better coordination between the existing and proposed developments. This is also encouraged within Paragraph 39 of the National Planning Policy Framework.

406 "To whom it may concern Today a friend forwarded me an excerpt from the climate emergency development plan, I've now read the whole paper and I'm impressed by the ambition and scope of the project. It gives me great hope. I was aware that Cornwall Council had declared a climate emergency but I had no idea that it was being pursued so actively and progressively. At the start of 2020 my partner and I purchased 8 1/2 acres near St Keverne, it's been an exciting learning curve already. We started documenting our experience via our blog and I feel that the content is very relevant to the emergency development plan, if you have 5 minutes to spare please have a read at wildsideofthevalley.com Admittedly I haven't updated the blog since June 14th as we now have a 12 week old baby girl, It's coming together slowly though! A quick glance over the site will give you a good idea of our motivations and aspirations for the land. We are very keen to become involved with any scheme that embraces/replicates the one planet development scheme in Wales and how it may work in Cornwall. Please could you keep us updated on any progress via this email address, if you would like any more information or if we could be of any assistance please don't hesitate to get in touch.


407 "How do the aspirations and intent of this document relate to the new planning White Paper? At what point will the policies within this document become “material” particularly given the new white paper? Comment Number Page Section/Question Comment 1 8 3.2.1 Some Neighbourhood Plans already have climate change related section(s) drafted against the current regulations and understanding of the issues, What “update infrastructure” will be available to update these plans and how often should this be done? 2 23 13.5 Bullet 5 The statement “The Council will not tolerate pre-emptive clearance of sites to circumvent biodiversity requirements. Where there is evidence of pre-emptive clearance the habitat lost will be treated as the highest distinctiveness and condition and must be replaced as such.” is welcomed 3 31 14.6.1 Line 5 Suggest delete “they ” “Schemes usually they also have an aspiration for eco-living” 4 32 Policy AG3 We may need to consider putting “European Protected sites” into Uk defined nomenclature 5 33 14.8.2 Currently the requirement for “Clustered uses and facilities, potentially to be shared by a number of smaller settlements may also help to reduce the need to travel and distances travelled.” is met by small towns and villages. We must be careful not to disrupt existing social links. What about schools and other education facilities which are “self efficient” but put a large carbon load on society as a result of transport issues resulting from the centralisation? 6 35 15.1.3 Suggest use either “assist in the mitigation of the impacts of climate change” or “ help mitigate the impacts of climate change” 7 40 15.7.3 The development of council owned high density, low energy affordable urban housing (as at Norwich City Council’s Goldsmith Street development) should be consided as a “kick starter” for commercial developments 8 41 16.1.3 & 16.1.4 bullet 7 These two sections, particularly if they are applied to existing urban areas, do not take into account the needs of residents in more outlying areas who do not have access to any public transport to urban centres until the “neighbourhood” system implied in bullet 8 is created and effective 8 45 Policy T3 The need for maintaining effective access to potential trunk routes should be specifically identified 9 54 18.1.2 It is important that Carbon reduction is considered both at “construction” and “through life”. We should be careful to ensure that “target date” thoughts do not store up future carbon debt. 10 57 SC1 It would be useful to design in “For but not With” designs to allow developing technologies to be installed with minimum cost and delay but also allow those who cannot currently afford to install current technology to do so in the future. 11 61 19.4.3 Suggest “unless it can be demonstrated that the impacts would not impair the natural environment’s ability to adapt sustainably to the impacts of a changing climate.


12 64 CC3 Cumulative development numbers should be allowed for"

212 "I attach the response form with the initial section completed and also my response as a pdf in answer to some of the high level considerations raised by the DPD so far. In particular this response is about the legal duty on the Council to include planning to reach carbon zero by 2050, as required by the Climate Change Act as amended and the totality of several Planning Acts, requiring the Council to prepare plans according to several elements of government policy. "1.1 Plans & policy preparation: legal duty on climate change mitigation Planning policy has entered a new era with the Climate Change Act 2008 and its subsequent amendment in 2109 requiring the UK to reach zero carbon by 2050. Several Acts work together to make climate mitigation and adaption central principles in plan making. The results of the analysis below show that local plans must include the aims of the net zero carbon objective by 2050 in the amended Climate Change Act and that local planning authorities have a duty to prepare Development Plan documents which must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change. ‘The planning system should … help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions ... Plans should take a proactive approach to mitigating and adapting to climate change … In line with the objectives and provisions of the Climate Change Act 2008.’""1.2 Acts and guides for local planning authorities The following notes indicate the main legal and government documents providing duties and guidance to local planning authorities when preparing local plan policies relating to climate change mitigatioin • Climate Change Act 2008 as amended 2019 • sets UK target of net zero carbon by 2050 – with interim carbon budgets to be set taking into account, amongst other issues, scientific knowledge about climate change, energy policy and fuel poverty. • Section 13 requiries the preparation of proposals and policies as... will enable the carbon budgets …. to be met. • This has the impact of ensuring that energy policy and the target for net zero by 2050 are inextrically linked. • “Sustainability appraisal can be used to help shape appropriate strategies in line with the statutory duty on climate change and ambition in the Climate Change Act 2008” quote from DCLG website Sep20 • Planning and Energy Act 2008 allows local planning authorities in their plan making to impose reasonable requirements on renewable energy, energy efficiency


and low carbon energy in developments • reasonable must now include the Net Zero by 2050 UK target by virtue of section (5) which requires that local plan policies must not be inconsistent 2 with relevant national policies for England • relevant national policies include those relating to renewable energy, energy efficiency and low carbon energy • these relevant policies now rely on the UK Net Zero by 2050 target, as laid out in the Carbon Budgets eg Carbon Budget 3 by March 2023 UK Targets: carbon budget down 35% against 1990 baseline emissions with 30% renewable electricity , 12% renewable heat and 10% renewable transport • Planning Act 2008 empowers the Secretary of State to prepare and review National Policy Statements to set out national policy in relation to … development. (Sections 5 and 6) • (1) For each NPS, the Secretary of State must carry out an appraisal of the sustainability of the policy in the statement.... • (7) the NPS must give reasons for the policy • (8) the reasons must (in particular) include an explanation of how the policy set out in the statement takes account of Government policy relating to the mitigation of, and adaptation to, climate change. • this is reinforced in section 10 Sustainable development where • 1) This section applies to the Secretary of State's functions under sections 5 and 6. • (2) The Secretary of State must, in exercising those functions, do so with the objective of contributing to the achievement of sustainable development. • (3) ... the Secretary of State must (in particular) have regard to the desirability of— (a) mitigating, and adapting to, climate change • Planning and Compulsory Purchase Act 2004 in Section 19 (1A) • states that Development plan documents must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change." "These Acts make clear the legal duty of local planning authorities to ensure that climate change mitigation and adaptation are core objectives integrated across all local planning policy. There is also a legal obligation under the Strategic Environmental Assessment (SEA) regulations to assess planning policy’s consistency with wider climate change objectives. The more recent amendment to the Climate Change Act 2008 to require the UK to reduce emissions by 2050 by 100% relative to the 1990 baseline also makes clear a central government policy objective relating to climate change which requires, in section 13, as


noted above, the preparation of proposals and policies as will enable the carbon budgets … to be met. 3 This duty is supported by the Planning and Energy Act 2008, which allows local authorities to impose reasonable low carbon and other energy requirements on new developments. It is clear that reasonable now includes the requirements of the Climate Change Act. These duties are also supported by requirements in national planning policy and guidance that local planning must support “radical reductions in emissions” in line with the Climate Change Act, on the basis of a “robust evaluation of future emissions”. Significant professional bodies such as the Royal Town Planning Institute have emphasised that “without adequate planning systems and policies, there is no realistic way to progress to zero carbon” and that “nothing should be planned without having successfully demonstrated it is fit to take its place in a net-zero emissions future”. Given the vital nature of meeting this imperative, this is the only cost-effective, resilient and sustainable way to plan. The need to prepare plans and policies which will meet Zero Carbon being a legal duty has consequences for achieving compliance. This is expressed by Client Earth in a recent letter to English planning authorities showing the need to achieve specific tasks,which are :- •Set a local carbon target framework. •Demonstrate proposed planning policies’ consistency with this. •Monitor performance on at least an annual basis using relevant indicators. The requirement for this outcome-focused duty on local planning authorities clearly signals the priority to be given to climate change in plan-making. • National Plannng Policy Framework NPPF core planning principles Paragraph 8 of the NPPF makes clear that ‘mitigating and adapting to climate change’ is a core planning objective. To be in conformity with the NPPF, local plans should reflect this principle, ensuring that planning policy clearly and comprehensively deals with climate change mitigation and adaptation. The NPPF also highlights climate change as a key part of strategic planning policy which local authorities are legally obliged to set out in their local plans (see para 20 and footnote 12 of the NPPF).


In discharging this duty, local authorities should consider paragraph 149 of the National Planning Policy Framework and ensure that policies and decisions are in line with the objectives and provisions of the Climate Change Act 2008 (Section 1) (the target reduction in climate change emissions) and support the National Adaptation Programme. This means that local plans should be able to demonstrate how their policy contributes to the Climate Change Act target regime, and this, in turn, means understanding both the baseline carbon dioxide emissions and then the actions needed to reduce emissions over time – which, in turn, means that annual monitoring reports should contain ongoing assessments of carbon performance against the Climate Change Act target, as noted above. 4 The Section 19 duty in the Planning and Compulsory Purchase Act 2004 is much more powerful in decision-making than the status of the NPPF, which is guidance, not statute. Where local plan policy which complies with the duty is challenged by objectors or a planning inspector on the grounds, for example, of viability, they must make clear how the plan would comply with the duty if the policy were to be removed. Whatever new policy may emerge, compliance with the legal duty on mitigation must logically , and practically mean compliance with the provisions of the target regime of the Climate Change Act Whilst the National Planning Policy Framework (NPPF) wants a balance to be struck between social, economic and environmental sustainability, it is important to be aware that the NPPF is guidance rather than a statute. Therefore the legal duty must take precedence in the plan-making process. Ie the requirement to aim in policies for carbon neutrality. It is understood that the balance implications of the NPPF guidance on what it means by sustainable development ie economic,social and environmental has tended historically to mean economically viable with a nod to social and environmental issues. Now however there are several threads which suggest this is no longer the “balance” to be struck – that social and environmental issues must have higher weight in decisions on the balance indicated in the NPPF, for the very reasons why the Council has declared a Climate Emergency. • Technology has moved on and zero carbon buildings are only a few percent more expensive to build than high energy ones. In fact zero carbon homes command a higher sale price because their running costs are so low,potentially allowing a higher profit margin to the builder/developer. • It should be remembered that the housebuilding industry, after ten years of preparation, was ready for zero carbon homes to be built from early 2016, until the government of the day pulled this requirement in 2015. • Companies which work in sustainable ways and in sustainability show much higher returns on investment in general than all other types of businesses • The cost of capital is very low and likely to remain so for some time – allowing house


builders to continue to make significant profits -even including >10% biodiversity and with zero carbon homes It is suggested that some real life research is carried out on “viability” issues to enable the Council to feel more confident in developing legally compliant policies to meet carbon neutrality. It has also been noted that the Scoping Consultation responses included one from the Centre for Sustainable Energy making the same legal points which are made in this submission. ClientEarth has written to councillors and planning officers from areas that are revising their local plans, reminding them of their legal responsibilities. These duties include setting targets and policies based on the local potential to reduce emissions, and that are at least in line with the UK’s Climate Change Act. The latter target was recently increased to net zero greenhouse gas emissions by 2050, meaning that all sectors now need to plan for full decarbonisation. 5 Lawyers said that for carbon targets to be meaningful, they need to be incorporated into local planning policy as a core objective against which all other policies and decisions will be tested. Local planning authorities also need to monitor performance against local targets at least annually. See https://www.clientearth.org/press/lawyers-put-local-authorities-on-notice-overclimate- inaction/ See also https://www.rtpi.org.uk/media/3568/rising-to-the-climate-crisis-1.pdf Why has this legal duty which has already been made clear to the Council been ignored so far in this plan-making process? 6

276 "I’d like to start by saying how impressed I am with the changes you have made to this DPD from the original version. You have really listened to the responses you recieved. Thank you. The language is much more conducive with the urgency of our situation. Its still a shame you say it may be impossible to reach our targets, but the rest of the document gives me a hope that we are now charging in a better direction. Language and excitement will give people the initiative and confidence to adopt and adapt quicker, so please push all your policies even 5% further. As you say ‘Some changes may be seen initially as radical and could feel a little uncomfortable but will rapidly come to feel normal’. This is a very true statement. Points of brilliance I noted: your highlighting of ‘Green gimmicks’ in part 5 of the document, and also your acknowledgement of ‘decisions not being popular…but this is an emergency and we need to act now’ in part 6, ‘Green infrastructure should be central to design’ and ‘grass habitats should consist of 50% insect pollinated plants’ in 13.4 (I am hoping this includes winter flowers for bees who have woken up from hibernation due to warmer winter days), and I really appreciate your policy for sustainable construction. My notes:"


300 "(DPD) August 2020 Thank you for the recent consultation on the Climate Emergency Development Plan Document, Draft Policies August 2020. We welcome the councils aspirations on the topic of climate change and the progress made over the last 12 months. The DPD provides clarity on the expectations of new development and the need to ensure climate change resilience is at the heart of the decision making process. We are of the view that the policy could be improved by ensuring that the wording reflects the need to take a wide ranging perspective on what constitutes sustainable development within a coastal community. Policy addressing coastal zone management, must allow decision makers to adequately balance the environmental, social, institutional, economic and cultural characteristics of an area. Policy CC1 instructs decision-makers to apply the SMP policy unit intention, limiting the type of flexibility required to sustainably manage and grow coastal communities. It is imperative that each and every coastal community develops a long term strategy for growth and development, providing a more sophisticated recognition of the problems associated with coastal zones and developing a bespoke strategic approach through the application of Integrated Coastal Zone Management principles. Such a strategy must encompass all the elements of management from planning and design through to financing and implementation. With such a strategic approach in place, balancing planning decisions will be made much easier in future years. In the meantime we must ensure that we do not over simplify the decision making process by constructing policy based on the advice from a single document. Policy CC1 places significant weight on conformity with the recommendations of the local policy unit of the Shoreline Management Plan (SMP). Whilst the SMP provides a useful tool in aiding decision-makers on the likely susceptibility of development to changes in the coastline, it must be remembered that as a large scale assessment, focusing on a narrow range of issues it is unlikely to capture the full spectrum of unintended consequences. Translating the preferred approach for each epoch directly into policy, then slavishly following the SMP’s preferred policy option, will result in significant conflict with economic growth options and the overall sustainability of many coastal towns and villages across Cornwall. The notion presented in Policy CC1, that development within the coastal zone must comply or be consistent with the SMP to be considered appropriate and sustainable, would in many circumstances conflict with the first, second and third bullet points in the chain of conformity. In addition it would not provide the flexibility required when considering those options not strictly in accordance with SMP policy, yet shown in the short, medium or long term to be a sustainable option. We would welcome a policy that heals the dissonance between economy and environment in the coastal zone. In its current iteration Policy CC1 only exacerbates this conflict. In light of the above we recommend that the policy be amended and should read as follows.


1) New development including replacement buildings (unless classified as exempt) within the Coastal Vulnerability Zone must be accompanied by a Coastal Vulnerability Assessment and show that development will: a) Positively and demonstrably contribute to the following priorities were relevant; - Preservation and improvement of the socio-cultural capital of the area - Protects and enhances the areas environment and natural habitats - Strengthens the economic fabric of the area - Actively supports tourism, recreation and jobs - Protects public health and safety b) would not impair the ability of communities and the natural environment to adapt sustainably to the impacts of coastal change; and c) will be safe through its planned lifetime, without increasing risk to life or property; or d) is a garden or other open area; and e) where applicable, makes provision for coastal access and the South West Coast path to be moved inland; and f) would not affect the natural balance and stability of the coastline or exacerbate the rate of shoreline change to the extent that changes to the coastline are increased nearby or elsewhere. Exceptions will only be granted where it can be demonstrated that a time limited permission would be consistent with the above criteria. 2) Soakaways and other infiltration based sustainable systems within 5 metres of the Cornwall Coastal Vulnerability Map (CCVM) zone or discharge of surface water over or down the face of a cliff will not be permitted unless demonstrated through a Coastal Vulnerability Assessment that the proposed drainage method would not adversely affect coastal stability. Changes to Part 1 of the policy would make the policy more concise by removing the need for Part 2. Reference is made to coastal management objectives in Part 2 of the policy. It would be useful if these are laid out in the policy with supporting text explaining how the objectives have been agreed. Should you have any queries with regards to the above please do not hesitate to contact us. "

234 "The Ecological Land Cooperative is a not-for-profit community benefit society founded to support the creation of sustainable land-based livelihoods in the UK. To this end we purchase sites and secure planning permission for low impact rural enterprises and associated dwellings. The sites are kept affordable and their use tied to ecological farming enterprises in perpetuity. Our work strengthens local economies and communities, mitigates climate change, enhances biodiversity, provides healthy food and creates rural employment. Over the last ten years we have raised over £1million in funding, had our research commended by the Research Council UK, and have been in discussion with DEFRA about our work. Amongst other things, our funding covers campaigning for policy change at a national and local level and developing guidance to assist LPA Officers in assessing Low Impact Development (LID) applications, in order to further promote sustainable land based living.


We have recently submitted a pre-application enquiry for our site in Cornwall where we hope to secure planning permission for 3 affordable smallholdings and as such we are looking forward to engaging with Cornwall Council Planning Department in the near future. For more information on our Cornwall site please see our website (https://ecologicalland.coop/orchard-park). We have only provided a response to those questions related to agriculture and rural development, section 14, of the Climate Change DPD and which directly relate to the aims and objectives of our organisation. It is important to clarify that this is by no means a reflection on the relative importance of the other issues set out, or dismissive of the importance of a coherent, holistic approach to climate change and the interconnectedness of all the issues discussed. The limited response is solely due to the fact that the other issue areas sit outside the remit of our organisation. For ease, we have set out our response to the relevant questions below; these are also duplicated in the attached form at the appropriate places."

414 I am a homeowner in Truro, but I am concerned about the climate emergency and as such, have familiarised myself with the Climate Emergency DPD, which raises some exigent points. The One Planet policy in particular, which has already been initiated in Wales, would I'm sure have a wide ranging impact on Cornish residents, such as myself, who would like to live more sustainably, whilst also lessening their impact on the natural world. As an approach, it encourages residents to live and work within an agricultural framework, working within a low-impact local community to improve the quality of the land that surrounds them, in the process reducing emissions and recovering the land. There has been growing interest in co-housing in recent years, which has been proved to have wide-ranging social, economic and environmental benefits. Generally, land is expensive in Cornwall, but having spoken to a number of local farmers, several would be open to hosting such communities were funding available from schemes such as the DPD or One Planet policies.

416 "Helston Town Council's Planning Committee has reviewed the Climate Change DPD document and whilst some items are not within the Council’s expertise the Council understands that a detailed submission has been provided by the Helston Climate Action Group. Helston Town Council is supportive of the principles that have been proposed by Cornwall Council but would encourage Cornwall Council to take the proposals further where possible. In respect of sustainable transport there is very little reference to commercial transport. The demand to move goods may decrease as we move to rely on more locally produced goods and services, but until that demand is dramatically reduced we will be relying on road and rail. Therefore the essential re-instating of railway links should be one of the priorities, with the addition of cycle routes alongside. The alternatives to large diesel transportation needs to be discussed and a long term strategy developed. Helston Town Council is aware that there will still be a need for personal transport in rural areas. A vast investment and a change of mindset is required for public transport. Cornwall desperately needs small electric buses for narrow streets and country lanes with more frequent availability. Speculation in future local need will


have to be intensified. Individuals are not able to afford new low-emission vehicles or even e-bikes (needed in these hilly areas). There will need to be schemes of grants, loans or leasing arrangements to encourage this usage, with local and national campaigns to fund, subsidise, promote and support this."

056 "About Communities for Renewables CIC Communities for Renewables CIC (CfR) is a Cornwall-based mission-led community interest company which helps to set up local energy enterprises and works with them to develop, finance and manage their own renewable energy generation. Since setting up in 2012, CfR has worked with local energy enterprises in over 30 localities, managed the development and financing of community solar projects with a capital value of £57million, and our company and asset management team looks after 50MWp of community solar across 7 localities (about 1/3 of the UK's community solar capacity). These projects are projected to generate over £17million of surplus income over their lifetimes to support community action in their localities, including fuel poverty and low carbon transition initiatives. CfR’s contribution to the community energy sector has been recognised through CfR winning a number of industry awards and, in 2020, being listed in the Natwest SE100 index of top UK social enterprises. As a Community Interest Company (CIC), any surplus made by CfR is re-invested in supporting further community energy projects. www.cfrcic.co.uk Vision for Cornwall’s net zero transition CfR CIC’s vision for technological transition is one broadly shared by many in Government and business: a low carbon energy infrastructure based on distributed renewable energy generation, energy storage and smart technologies, electrification of transport, retrofit of the existing building stock and high standards for new builds. This low carbon technology transition is well underway and will happen. But, will it happen fast enough to achieve net zero by 2030 and will it happen in a way which brings economic, social and environmental prosperity to Cornwall’s communities, and minimises the potential negative impacts of rapid change? CfR CIC’s vision is for the net zero transition to: • To be based on a plan which works back from the net zero carbon end-game and sets out the scale and speed of change required; • Be shaped by and have the consensus of Cornwall’s communities, and have their interests at its heart; • Be led by collaborations of local organisations including community energy enterprises, climate action groups, Cornwall Council, community institutions and local businesses who act as trusted intermediaries to engage the wider population and ensure this is done with and for communities, not to them; • Create prosperity through local ‘build back better’ jobs, local ownership of low carbon infrastructure, and reducing and localising energy spend which is currently a drain on Cornwall’s economy; • Be an opportunity for positive system change - towards one which makes capital work for Cornwall’s communities and environment; • Be realistic, with plans for the adaptation, mitigation and compensation measures that will be required under the range of unavoidable climate change scenarios.


Community-owned business models which enable communities to influence and benefit from the net zero carbon transition are key to securing the community buy-in essential to the speed and scale of change required. They are also key to the efficient financing of the change, as the surpluses generated can be reinvested in hard to finance infrastructure and deep retrofit. CfR CIC believes that, if community-owned business models are put at the heart of net zero policy objectives, they can deliver at the scale needed – i.e. hundreds of megawatts of generation capacity and hundreds of £millions of capital value. Cornwall should embrace the so far largely missed opportunity to not just decentralise how energy is generated, but to decentralise ownership and economic benefit of energy generation. "Community energy in context The community energy sector has demonstrated that communities can develop, own and operate renewable energy generation at scale. This is illustrated by the community solar projects which are managed by CfR which range from 4MWp to 15MWp. These projects are in line with the scale of solar project being developed by commercial developers at the time they were commissioned (2016-17). We are now working on early stage larger scale projects (up to 50MWp) which is the scale currently required to achieve grid connection viability and economies of scale in the absence of subsidies. Some of these projects are community initiated, some are partnerships with commercial developers. Community energy has delivered a small percentage of the UK’s renewable generation capacity against the odds in a policy environment which has favoured commercial ownership models. Cornwall is no different. Despite a high level of engagement and interest from early stage community energy groups between 2010 – 2015, very little community-owned generation has been installed in Cornwall. During this same period Cornwall was a leader in solar deployment but, with the exception of a few hundred kilowatts, none of it was community owned. With the required capacity and a favourable policy environment community energy could make a significant contribution to the Cornwall’s renewable generation needs and deliver wider low carbon transition and economic recovery objectives. Renewable energy generation delivered under community owned business models bring significantly greater social and economic benefits to the local community than commercial ownership models. The jobs benefits from construction and operations should be the same regardless of ownership model. The key difference is the level of local involvement in the project through ownership and governance and the surplus income generated by community-owned projects being re-invested in the local communities’ net zero transition, tackling fuel poverty and supporting community services. This is an efficient use of capital, and subsidy where required. Surpluses from large-scale investable projects support harder to finance low carbon measures and the needed public engagement recognized in The Committee on Climate Change Net Zero report. CfR believes policy measures which support a mainstream role for community energy in the renewable energy sector would be good for the sector as a whole. We can have a thriving renewable energy industry based on local ownership.

423 "St Enoder Parish Council broadly welcomes the intention of the unitary authority to produce a DPD to ensure that future developments play in a part in combatting climate change.


However, we wish to raise concerns about whether some of the proposed new policies would be consistent with other policies in the Cornwall Local Plan. In addition, we would point out that St Enoder Parish Council has just completed a Neighbourhood Plan. We worked very hard on this important document and feel that some of the proposed new policies in the DPD override content in our Neighbourhood Plan. In many ways, this is a very general point and we feel that the document should be audited in this regard."

424 "I am pleased to be submitting comments on your Climate Emergency Development Plan Document. To be clear I am doing so on an individual basis and not in any other capacity, including my role on the Devon Net-Zero Task Force. I am a rural specialist and the main author of the Welsh Government’s OPD Practice Guidance, and will focus my comments mainly on these areas. James Shorten, September 2020"

019 "General Comments on Climate Emergency Development Plan Document (DPD) Draft Policies consultation (August 2020) Historic England notes that Cornwall Council has declared a climate emergency and is aiming to become carbon neutral by 2030. Historic England welcomes and supports this intent. We consider that climate change is one of the most significant and fastest growing threats to people and their cultural heritage. We recognise that the historic environment sector must contribute to reducing greenhouse gas emissions, so as to minimise the most harmful impacts of climate change. Given the scale of the challenges, Historic England has committed to collaborating to understand and address the impacts of climate change on the historic environment as a signatory to the Joint Heritage Sector Statement on Climate Change in June 2020. Historic England recognises the importance of climate change mitigation and adaptation as part of building resilience for the historic environment. We believe that energy efficiency, sustainable technology and reducing carbon emissions are compatible with the conservation of our heritage. Research by Historic England has found that reusing, refurbishing and retrofitting existing buildings should be a priority for meeting the Government’s net zero carbon target by 2050, taking into account their embodied carbon and that we can reduce the carbon emissions of historic buildings by over 60% by 2050 if we take a whole of life carbon approach. We offer information and advice on many related topics including the installation of renewable energy generation, and also on energy efficiency and historic buildings, to help advise on how this can be undertaken while minimising negative impacts on the historic environment. As you will see from our detailed comments on the Climate Emergency DPD in Appendix 1 to this letter, Historic England has found much to welcome and that we support. However, we have seven main concerns about how this DPD will integrate with the conservation and enhancement of Cornwall’s valued and distinctive historic environment that we would like to see resolved before the publication of the Submission Document version. These are:


1. A Heritage Topic Paper should be prepared to understand the issues, opportunities, risks and challenges of climate change in relation to Cornwall’s historic environment, including heritage ‘at risk’ and wider townscape, landscape and seascape character. For example, there is no mention of Bodmin Moor or mires, where water management and peat restoration may offer opportunities for carbon capture. This work could then inform the approach to the DPD policies. It is notable almost all of the topic papers that have been prepared make no mention heritage assets let alone consider the implications of the DPD’s policies for Cornwall’s historic environment. • The DPD would benefit from greater recognition of the positive contribution that the historic environment can make to delivering carbon neutrality and climate change resilience as described above. To this end, the DPD should include a section that focuses specifically on the historic environment, which we note has not been identified as a theme or topic for policies or as a cross-cutting issue. This could also be informed by relevant content in the emerging Heritage Strategy and other related Council work, e.g. on Cornish Distinctiveness. • There are many draft policies in the DPD that would benefit from additional policy wording to ensure that impacts (positive and negative) on the significance of heritage assets, including their settings, as well as on wider townscape, landscape and seascape character are appropriately understood, avoided where possible, and then minimised and mitigated. In some cases, there are uncertainties to be resolved around the integration of the DPD policies with other supplementary planning documents and/or material considerations, e.g. conservation area character appraisals and/or management plans and the town centre policies. There are also processes proposed in some policies for the endorsement of binding plans, e.g. Whole Estate/Farm Plans, and we seek assurance that they will take appropriate account of the requirement to conserve and enhance the historic environment. • The DPD should give greater attention to Heritage at Risk and climate resilience, especially where the reasons for particular heritage assets being or remaining ‘at risk’ are related (even in part) to climate change. This should include designated heritage assets that are on our Heritage at Risk Register 2019 (and any subsequent updates) as well as those designated and non-designated heritage assets that are not. We would welcome further discussion alongside local authority conservation and archaeological staff to help identify relevant heritage assets and to ensure that the policies themselves encourage finding solutions to heritage at risk. We also have a particular concern about the implications of the coastal change and flooding policies in relation to existing and future heritage assets at risk. • The outcomes of some of the DPD policies, in particular the encouragement of tree planting, may have unintended consequences for the distinctiveness of Cornwall’s historic environment and its wider townscapes, landscapes and seascapes. This needs to be better understood for and integrated into the policies in the DPD. This could be addressed in a Heritage Topic Paper. • We note that there will be a policies map that accompanies this DPD that will identify particular sites or areas as being suitable for particular uses or development, including for biodiversity offsetting, renewable energy installations and wind energy, carbon offsetting, Coastal Vulnerability Zone and candidate Coastal Change


Management Areas. In our previous comments on the Scoping Report, we advised that there needs to be an evidence based approach to determine allocations, including appropriate historic environment assessments, and to inform associated policy provisions related to the conservation and enhancement of Cornwall’s distinctive historic environment. We are remain unclear how Cornwall intends to approach this work and would welcome further discussion on this matter. • We are aware that the DPD intends to leave some allocations, e.g. Coastal Change Management Areas and wind energy, to Neighbourhood Plans. We are likewise concerned to ensure that this process will be informed by proportionate heritage impact assessments and is appropriate resourced. Again, we would welcome further discussion on this matter. Many of these concerns were expressed in our earlier comments on the DPD Scoping Report and it is disappointing to see that they have not been addressed. In our view, additional work is necessary to ensure that this DPD can be found ‘sound’ including the preparation of a relevant and up-to-date evidence base required by paragraphs 31 and 35 of the National Planning Policy Framework (NPPF) and ensuring that the DPD sets out a positive strategy for the conservation and enjoyment of the historic environment as required by paragraph 185 of the NPPF.

425 "I'd like to put forward some ideas for environment policies regarding building. 1. All new builds should be fitted with solar panels or planning permission should be denied. Incentive to developers could be that they get paid back for any excess energy produced till the cost of fitting the panels is payed back. 2. Ban or reduce usage of plastics in the design of the houses. There is no need for things like astro turf and the plastic panels on the outside of houses. 3. Properties under say 1acre should be prevented from gaining planning permission for anything other extensions. To prevent destroying green space for wildlife. 4. Housing plots should have minimum size outdoor space or be in proportion to size of house. During lockdown many found comfort in outdoor space and growing plants and veg current developments garden sizes are pathetic is size. Bigger gardens would promote planting flowers and trees making a more bio diverse environment for wildlife. 5. Reduce panel fences and replace boundaries with stock fencing lined with hedging plants this would improve wildlife ability to roam between gardens and more places for birds to nest and feed as well as reducing the need for cutting down trees for the timber. 6. Plan housing developments surrounding industrial so there is an opportunity to live within walking/cycling distance to work. Ensure developers provide good quality footpath and cycle paths and if possible join up other urban and industrial areas of the same area with footpaths and cycle paths.

426 Overall your proposals are wrong for the following reasons: Councils permitted / encouraged out of town shopping centres and allowed parking charges in towns thereby creating vast traffic movements. Independent engineers show many of the renewable energy systems now used e.g. onshore wind and wave power, have greater whole life energy costs than their effective output. Most of your premise on CO2 removal is dishonest and you are only transferring it to other countries. China being the obvious example because of the West's appetite


for cheaper goods has enormously expanded its industrial output using obsolete energy production methods. The West has cleaner air at source but globally it is worse. Small, old houses cannot become carbon neutral, only factory produced replacement housing will meet this need. If the Council stop having grandiose ideas, some small practical steps will not only be cost effective but have less potential for unforeseen consequences. 1. Have bylaws preventing shop doors being fixed open during winter months with consequent heat loss and unnecessary power station output. 2. Remove car parking charges in towns for stays under 4 hours. 3. Encourage rail companies to lengthen station platforms to permit longer trains, thereby increasing carrying capacity efficiently. 4. Facilitate building companies in replacing inferior terraces of housing with efficient town houses. 5. Aid all home owners, regardless of income, to improve the insulation over, under and around their houses. 6. Do not promote electric cars which, in reality, are more damaging to the environment worldwide than liquid fuelled vehicles. The list of their failings should have been studied by your members and an in depth, un-politicised assessment made instead of publishing these sweeping and ill considered ideas.

427 I apologise as I realise the deadline for this was last Friday. I hope you can still consider the comments below: St Erth Parish Council is broadly positive in relation to the principles of this report. However, the document itself requires greater expertise and capacity than the Parish Council has to go through with confidence and the feedback questions are lengthy and in depth. In general, it has concerns that there is no coordination between the new planning reforms proposed by the Government, how this will work where conflict appears and the potential impact on NDPs. Furthermore it feels that climate change should be part of our everyday thinking but that in many areas things are not moving at the pace they should be with no joined up thinking across all areas. In order to comply with the proposals, Parish Councils may suffer potentially major budget implications with no clear detail about funding options and there needs to be a plan for how these are dealt with.

354 "Thanks for your messages. Following my submission I would like to add a couple of key points relating Waste/Resources and the Circular Economy : These relate to acknowledging the role that Third Sector Organisations are playing, and have the potential to play, in addressing the climate emergency by reusing and recycling large quantities of materials that would otherwise go to waste. Enterprises like charities and community-based initiatives, often in the voluntary sector, need ongoing support and encouragement to thrive and develop. Could the planning process help in this respect ? I touched on this in respect of Community-led Energy Projects, and the work of Cornwall Food Action in addressing surplus food redistribution, but other key examples come to mind following similar principles of community-led activities. Only last month a new Library of Things was launched in Penryn https://www.kloth.org.uk/home-1 inspired by the work carried out in Bugle


ttp://www.buglelibraryofthings.co.uk/ . These are exciting developments and address the climate emergency head-on. Here is an excerpt from the Bugle website *It's for the whole community. It's not about how much money you've got. It's about saving carbon emissions, saving landfill, cutting waste, and reducing that pile of stuff filling up your shed"".Charitable organisations like the Salvation Army and Oxfam along with many others are doing tremendously important work supported by volunteers, and their contribution, along with local Repair Cafes and Furniture Recycling Groups (e.g.GOFA), and the examples already mentioned, need to be recognised and supported,wherever possible, as an integral part of the overall plan to tackle the climate emergency. I hope you can find space in your Development Document Planning for these further thoughts."

Reponses to specific Policies:

4. Climate Change Principles Policy C1 – Climate Change Principles Development in Cornwall must represent sustainable development and manage our natural and cultural assets wisely for future generations. Proposals must contribute to and achieve the following objectives: 1. Be low carbon and make the fullest contribution to minimising greenhouse gas

emissions in accordance with the following energy hierarchy: a. Be lean: use less energy b. Be clean: supply energy efficiently c. Be green: use renewable energy 2. Mitigate against and improve resilience to the effects of climate change; 3. Contribute positively to the health, wellbeing and resilience of our communities; 4. Contribute positively to environmental growth, protecting and increasing the ability

of natural systems and nature recovery networks and ensuring a net gain for biodiversity;

5. Ensure resource efficiency, minimisation of waste, reduction in embodied carbon and conditions that create opportunities for a circular economy;

6. Maximise the ability to make trips by sustainable and active modes of transport in all developments through careful design and mix of uses that support walking and cycling rather than car use for day to day living;

7. Use and reuse land efficiently through the delivery of appropriate higher densities of development on the most accessible sites (including town centres and public transport hubs such as stations);

8. Conserve the capacity for sustainable production of food, water, raw materials and energy and minimise the impact upon the quality, stability, and function of soil;

9. Conserve and enhance our natural and historic environment and cultural heritage and increase built and natural environment distinctiveness through locally distinctive, high quality and sustainable design and multi-functional green infrastructure provision;


10. Minimise or avoid light, water, air and noise pollution and improve or maintain air quality;

11. Protect and enhance carbon storage in our natural environment (including the marine environment); and

12. Improve or maintain the natural functioning of coastal and river processes, avoiding areas at risk of flooding and coastal change and further reducing flood risk elsewhere wherever possible.

Pre-submission Consultation Questions

1. Does Policy C1 pick up the right issues and principles – is there anything you would add? 2. Is there anything else that should be included in this policy? 3. Do you have an alternative approach to C1 that you think the council should consider? 4. Any further comment?

URN Comments received

352

1. Provide for a sustainable system of renewable energy through the implementation of energy storage and reuse. 2. Principles 12.2.2 should point to where desired new NPPF content is identified. 3. No 4. Various comments re vision economic implications and concerns re the ability to use existing legislation to effect desired change – e.g., CIL and S106.

355 1. Yes Policy C1 picks up on the right issues and principles and I am very supportive of the direction of travel laid out and Cornwall Council’s intention to use planning policy as a tool to drive our response to climate change. 2. Re. point 6 and sustainable modes of transport, it is very important that the council’s policies goes beyond just ‘promoting’ – the main barrier for more cycling and walking is inappropriate infrastructure that makes it unsafe to cycle or walk such as no dedicated cycle lanes or narrow payments; cycle lanes and payments that suddenly end (often at dangerous junctions such as roundabouts). Enforcement of existing rules also needs to be referenced as existing cycling or walking infrastructure is often blocked by cars parking or stopping on pavement/cycle lanes forcing pedestrians and cycles to join the main road which is dangerous. Re. point 8 it would be good to see reference to small scale food growing in gardens and public spaces and the council could do more to encourage the use of gardens and communal street areas for food growing within towns.

358 1. Yes, nothing to add 2. No, nothing to add 3. No, nothing to add

359 1. Many important issues and principles are covered here – what is missing though is any mention of air travel. There is no mention, however, of a fundamental conflict of interest between development of air travel (via Newquay airport in which Cornwall council has an interest) and the green policy of Cornwall council.


2. A policy on air travel. For example, should Newquay airport create income by being a training site for large commercial airlines (like easyjet). This creates substantial noise and fuel pollution over an area of immense natural beauty. If one is on the coastal path looking at the gorse and heather flowers (unique to that part of the coastal path) one is subjected to large commercial flights training in taking off and landing and circling over the bay, creating noise pollution, visual pollution and fuel pollution. Surely the principles should include something along the lines of: Air travel into and out of Cornwall (ie Newquay airport) should remain within specified limits and investment should be on train travel rather than on building up a large airport with many flight paths? Gratuitous flight intrusion in the form of training flights for large commercial airlines should be discouraged. Furthermore, some mention should be made of a potentially fundamental conflict of interest between Cornwall Council’s interest in Newquay airport and its green plan.

360 1 a. Education particularly in the younger generation about the use of electricity would be a good place to start. Make them aware of how much they could reduce their use with this policy. What it takes to produce power for their life styles. 3. If renewable is to be used sitting of renewable producers should be carefully considered to prevent stresses and health hazards to people local to the sites. 5. Make as much use of local means of producing electricity. We have a large amount of water in the south west, cannot this be put to better use to help with this project? 6. Encourage the use of public transport where possible to prevent car use. It must be regular and reasonably priced and clean. 8. Good quality food producing farm land must not be sacrificed to renewable of housing. This land should be used to produce food that should be available and reasonably priced for local consumption thereby preventing unnecessary transport journeys by lorries. 9. This cannot be stressed enough so that our heritage and countryside is preserved for future generations. 10. In introducing any renewable project it must comply with all other environmental issues and be made to comply. This is to prevent curing one problem, i.e. going green. with introducing noise and environmental impact to communities. 11. Encourage any development that, in the right place, helps achieve this. 12. It may be argued that allowing gardens and areas to be concreted of covered with artificial grass this prevent the natural absorption of rain water ."

363 1. 9 Policy C1 item 6. I wonder if this will include improving and maintaining all Public Rights of Way rather than the current approach of trying to eliminate at least half of them through neglect? 10 Pre submission questions; 10.1 Analyse the natural resource base of Cornwall and identify scope for climate friendly economic development 10.2 Water wheel sites for instance as a means of electricity generation using repurposed ‘wind’ turbines


10.3 Geothermal energy production and use sites 10.4 Sources of rare earths 10.5 Potential for recycling old mine wastes 10.6 Extraction of copper and other minerals from the County Adit flow. 10.7 Scope for fish farming in the estuaries 10.8 Revise the land classification system to take account of the economic value of land and not just base classification on slope and soil type as at present, and use the new system to evaluate land when processing planning applications 10.9 Potential for using railways to ship freight on lorries as per channel tunnel and the impact of that on the demand for road infrastructure and impact on air quality, fossil fuel use reduction etc 10.10 Adopt SUDS everywhere as the obligatory approach 10.11 Use natural systems such as Vetiver Grass to manage run off of water from land into water courses 10.12 Look at high density wood plantations using selected individuals to maximise production volumes of wood per hectare. Then use the wood either in building or other uses. It can be used as charcoal as it is a renewable source and the charcoal dust is a good soil additive."

364 1. PC1; 1 to build the incinerator the council had to get permission from EDF. And, a lot of the time it does not produce any power, as it is not needed. 2 Quick answer to this. Stop using any plastic for any purpose what so ever. Re open all the old rail network, this was stolen from us. By the oil industry, for their cars. In the whole of this PC1 1 to 11 no mention is made of disabled people of any age. One suspects that the fit healthy people in the department do not believe that disabled and elderly people exist and if they do they are of no importance.

367 1. I believe this Policy covers important issues and principles. Members of the Public would like I believe to see clearly the chain of accountability, monitoring and responsibility for ensuring policies are put into practice

374 1. Provide for a sustainable system of renewable energy through the implementation of energy storage and reuse. 2. Principles 12.2.2 should point to where desired new NPPF content is identified. 3. No 4. Various comments re vision economic implications and concerns re the ability to use existing legislation to effect desired change – e.g., CIL and S106.

029 1. The effectiveness of Policy C1-6 in achieving walking or cycling as a day to day travel mode is seriously compromised by the existence of the large out of town retail parks and supermarkets. There needs to be a counter policy of moving retail back into town centres and of making it more profitable for small local shops to survive. Policy C1-9 raises the question of how to reconcile the highly subjective assessment of what is good locally distinctive design. There are already conflicts between parishioners objecting to contemporary designs and planning officers who believe we cannot continue to live in the 1890’s. Many of the new innovations coming with low energy requirements will bring in designs that are not currently locally distinctive e.g. green roofs versus traditional slate ones. The requirements of “conserve” and “locally distinctive” are likely to be at odds with “high quality and sustainable design and multi-functional green infrastructure provision”." 2.Not that we can think of. 3. Not that we can think of. 4. In Section 3 there is a reference to S106 and CIL. The latest UK planning reforms propose scrapping the S106

032 4. POLICY C1 Climate Change Principles 6. Maximise the ability to make trips by sustainable and active modes of transport in all developments through careful design and mix of uses that support walking and cycling rather than car use for day to day living. Does this mean that locations which


are remote or with difficult access will not be supported or, more positively, that development will be driven towards locations which are close to existing services and employment centres? Pre-Submission Consultation Questions There is no mention of landscape protection or social justice which are important elements of Planning and Carbon Neutral Policy. These issues require proper consideration in the context of both pursuing carbon neutrality and the development of renewable energy. Natural Climate Solutions 13.1.1. Mention must be made of landscape, which is a key element of Natural Capital, not least because it provides natural shelter against weather systems to create the environment for biodiversity. Landscape protection is essential for the environment, for biodiversity, for recreation, for tourism and of course for food production. Consideration should be given to extending protection to local landscape designations such as AGLV as part of environment/climate planning policy.

378 Add to C1-7 Develop policies to provide and encourage the use of public transport. Add to C1-10 The requirement to avoid visual pollution. As Cornwall is hilly, many of the roads narrow and the average age of its population is higher than average, there is limited scope for developing non-leisure cycling. This makes it all the more important to have a well-developed and well-integrated public transport system."

351 4. 5 minimise waste You don’t seriously attempt to do this. People who live in Cornwall and visitors lay waste all over Cornwall and not in receptacles provided This does not happen in , eg ,Singapore."

053 We welcome these principles. We recommend slight word changes at 4) To reflect the importance of the integrity of functional ecosystems. E.g. ""Contribute positively to environmental growth, protecting irreplaceable habitats and the integrity of ecosystems, restoring natural processes and strengthening nature recovery networks, and ensuring a net gain for biodiversity. With regard to soil - we highlight the more explicit, good recent example from Teignbridge under local plan draft polict SC1: l) Minimising the impact of development on soils through the use of appropriate construction techniques which should not result in the over-compaction, pollution or reduction in the quality of soil.

383 2. "Policy C1 Climate Change Principles I would suggest that the DPD also references the importance of reducing the carbon cost of crime and disorder In Cornwall by ensuring all development designs out crime. I have attached some research as below. One single incident can have a massive carbon cost including the cost of emergency services attendance, ongoing enquiries, medical care, court procedures which could all last months or even years. https://www.securedbydesign.com/guidance/research-case-studies-guidance/addressing-the-carbon-crime-blind-spot/viewdocument/198"

034 Does this mean that locations remote or with difficult access will not be supported or, more positively, that development will be driven towards locations which are close to existing services and employment centres? There is no mention of landscape protection or social justice which are important elements of Planning and Carbon Neutral Policy.

348 1. Vistry Group support the principles set out. Vistry Group is committed to a Fabric First approach as a platform for sustainable construction. We believe consideration should be given to the procurement process and the local supply chain capacity when implementing into Local Policy. 2. The policy is comprehensive. 3. Vistry Group support the proposed policy. 4. In relation to C1.5 Ensure resource efficiency, minimisation of waste, reduction in embodied carbon and conditions that create opportunities for a circular economy. Does “create opportunities for circular economy” imply a full lifecycle analysis assessment? We would be keen to understand what this would require to ensure that it would not adversely impact on the delivery of new homes of all tenures.

122 A lot of policy Cl is of the 'apple pie and custard' syndrome. However, it is vital that this policy includes an explicit statement that the climate change principles are also subject to the full requirements of AONB, SSI and other legislation.


Paragraph 4 introduces the concept of 'natural systems nature recovery networks'. It would be useful to have a commentary somewhere on what is meant by this. Concerning paragraph 6, we have to be realistic about car transport. Public transport is insufficient and probably always will be insufficient, given the nature of the geography of communities in Cornwall. Only some people will walk and only even fewer people will cycle. We should plan positively for car use which will always be the prime mode of transport in Cornwall, bearing in mind that all new cars will be all electric in the 2030's.

388 1. THE NEED TO REDUCE TRAVEL should be added as a “Climate Change Principle” even though it is covered under AG. 3. There should a methodical approach which quantifies benefits and costs both in total and for individual policies. Is there a calculation that shows that it’s possible to be carbon neutral by 2030? A statement of the current level of emissions, a list of costed actions and their expected emission reductions and how this impacts progressively?

389 1. Yes it does but (3) should include reference to communities in the broadest sence and not just the implication of settlement communities. This needs to include people who identify as Cornish who are likely (by nature of living here since birth or long term by identity) to be most disadvantged in the labour and housing markets. (6): the encouragement of walking and cycling is not just through the development itself but also the infrastructure that supports it. An example is the ‘Copperfields’ housing development in Truro which is supported by dedicated cycle lanes which disappear at the traffic lights and do not follow desire lines past the football club. Cycling has to be safe and segregated for people to use it as an option." 3. At the outset ‘sustaianbility’ needs to be defined. I suspect it is about accomodating exponetial population growth and using remaining land in a ‘sustainable’ way to support food, energy etc. That is not sustainable. 4. (7) Higher density housing may not be compatible with later policies which refer to back gardens of a similar footprint to the housing itself. Developers will like high density because it is cheaper to supply but it may not deliver the living conditions conducive to either sustainable living or good mental health (for example space to study, to be alone etc). Carbis Bay is an example of high density replacement development (in some cases) which has been good for the developer and ‘good’ for the purchaser. Flats have replaced houses or been built in gardens: wrecking biodiversity and often paving space to make room for parking – in a village with some of the best public transport services of a community in Cornwall. If the Council is serious about this DPD this kind of development has to stop and there is a choice to be made between ‘high density’ (ie packing more people into a smaller space to cater for demand) or truly sustainable development. The Carbis Bay justification falls, no doubt, on retail and school provision; not deterrence of car use and the maintenance and increase of biodiversity. "

390 1. Principles are OK but could be more bullish. E.g. Be Green – Use renewable energy is fine but perhaps should say maximise renewable energy, or develop xxGW of renewable energy or a similar metric. 2. Improving energy consumption of existing buildings and lead the way in ensuring new buildings exceed current building regulations for energy efficiency. Also improve the electricity networks to enable renewable energy generation as well as electric vehicle charging and the installation of heat pumps for low carbon heating. 3. Set targets to be clearer.

393 1. C1 picks up the right issues. Nothing to add 4. We feel the C1 climate change principles are quite comprehensive. However, we have concerns over how these will be accepted by the general public. Cornwall Council is asking for big changes not only to policies but also to people’s behaviours. To achieve these goals, you will have to get the public on board with the climate change issue. I guess the vast majority of Cornwall’s population don’t even know CC has declared a climate emergency. We at Stithians Energy Group (SEG) realised that people would not make changes unless they understood why it was necessary. To achieve this, we produced a forty-page booklet explaining climate change and what they could do about it. This booklet was then distributed to every home in the parish and has been adopted by various organisations across the UK. What we are trying to say is: For Cornwall Council to


achieve carbon neutrality by 2030 it will have to put aside a fund to finance as many forms of public information as possible. Whether it is a booklet, social media, TV, posters, talks, or posted flyers. So, we propose a policy for Cornwall Council to inform the public of the climate emergency measures and explain why these measures are necessary.

394 1. Bullet point 6 should be strengthened to give greater emphasis to the need to maximise the benefits and use of public transport.

395 1. Better protection and large fines or worst for damage to Historical monuments and areas. 2. Sewage control especially in Critical drainage Areas. Green corridor networks Carbon storage detail on how the net gain calculation is done and by whom." 3. Yes, in light of the Government’s changing building policies and this document pause all non-started developments and reassess the actual number of houses needed and their location in Cornwall by local people first, district by district and where the work centres are for possible incomers so builds would be near to those locations. Social housing must also be a priority!! 4. What Funding is available and from where for the actions needed to achieve the gaols? This will only work if you can oppose the strength and greed of the developers and the changes by Government in Planning Policies which must be on a case by case assessment and run by the local authority.

174 1. 8. Conserve the capacity for sustainable production of food, water, raw materials and energy and minimise the impact upon the quality, stability, and function of soil;” The reference to raw materials should be expanded further to include minerals, as minerals are essential for economic development, our quality of life and the development of sustainable communities. Cornwall has a wealth of mineral resources which have been exploited throughout the centuries. Mining and quarrying have shaped Cornwall’s landscape, natural environment, economy, settlement pattern and transport routes. Minerals remain an important natural resource for the Cornish economy and need to be managed carefully and used efficiently.

192 1. Yes, but there is one key principle missing – the need to support a Just Transition. This is highlighted in Cornwall Council’s Climate Change Plan but is not reflected here. Point 1 needs to be supported by carbon budgets for all development. Point 2 needs to include ecological breakdown among the effects of climate change. Mitigation should not be achieved by the use of offsetting. Point 4: We suggest inserting “greatly increasing” and “ensuring a substantial net gain for biodiversity.” Point 6 needs to go beyond “supporting walking and cycling”. We need to be actively encouraging active travel and prioritising these as a primary form of transport. Point 8: This section needs to go beyond minimising the impact upon the quality, stability and function of soil. Developments need to show how they will enhance these. Please explain what is meant by “conserve the capacity for sustainable production of food, water…” We are facing food insecurity and water shortages. Current practices are clearly not sustainable, and simply conserving them will not address pre-existing effects, such as the degradation of biodiversity and soil health, poor flood management, and marine impact. We need to address this. We feel this policy should include the use of doughnut modelling to scrutinise development impacts at all levels and ensure no compromise on planetary resource. Point 10. This is vague and unambitious; and we should be avoiding water pollution at all cost, not minimising it. Point 12. This point should Include “eliminating pollution from industrial, domestic and agricultural sources.’

041 1. Yes the aspirations of these policies are excellent and to be commended. There is one significant omission and that is mineral mining in the marine environment. This will contravene all environmental principles within the marine environment with considerable impacts back on terra firma for the environment, social health and wellbeing and the tourist financial economy. " 2. To be added: Monitoring programmes for habitats and species to ensure biodiversity gain. Inclusion of the next generation in DPD decision making through engagement in schools, colleges and universities. "


4. CSGRT strongly support all aspirations, but particularly C1 item 4. Cornwall is a challenging county for achieving C1 item 6. Build upon the changes begun during COVID-19 for more people to work at home C1 item 6. Every development to have quality natural green infrastructure creating corridors throughout the development C1 item 9. Aspire to create seagrass forests in the marine environment for carbon sequestration C1 item 11. It is critically important to maintain the natural functioning of coastal and river processes in this county C1 item 12."

396 2. Increased help for businesses / households to transition from fossil fuel systems to renewable energy based ones.

266 2. "In general, Policy C1 picks up on the right issues and principles, but I would add: - at objective 8, rather than “Conserve the capacity…” I would state “Conserve and enhance the capacity...” and include “biological health” in the list of soil attributes at the end of the sentence (ie “…quality, stability, biological health and function of soil;”."

397 1. All new development must have more than minimum insulation levels. Must be heated and lit by renewable energy sources. Must carry PV panels. 2. Re introduce Green Deal grant/secured zero % loans to promote renewable energy heating, PV panels and insulation to existing dwellings 4. Encourage / incentives for Electric Vehicles

253 4. In our responses as Quakers, we are mindful of our commitment to Faith in Action and to our Testimonies to Equality, Justice, Truth, Peace, Simplicity and Stewardship (which we might now refer to as Sustainability), which we see as underlying our specific responses. We are concerned for all beings on our planet, human and other. The over-riding concept of Climate justice needs to be embedded in all policies. The impact of all proposed policies should be evaluated to ensure that no one group is unfairly neglected or excluded when policies are formulated. Policies should be evaluated taking into account poverty, disability and race. ·We remember that this is a planning document, and that not all suggested solutions to the Climate Emergency are achievable through planning policy. However, it is important that Cornwall Council do not simply argue that their hands are tied by planning restrictions – they can do other things eg. on the cost of transport, the 3 mile minimum limitation on providing transport for taking children to school, speed limits . Where we feel there are additional measures needed over and above planning we have included these in the hope that they might be shared with relevant colleagues in the Council ·As Cornwall Council points out, their actions may be limited by national government policies and we draw attention to the distressing national limitations on: a)energy standards in new homes b)permissions for onshore wind-power c)clear policies on reducing air transport d)clear policies for reducing imports. But efforts must continue to address such issues with the government. ·The response of Cv-19 has shown that not only are there additional problems, but that some solutions have been proved possible, eg. pedestrianisation of thoroughfares. ·We would like to see encouragement for one planet living and the development of Cohousing schemes. These can address affordability and isolation issues as well as being low impact living. ·‘Offsetting’ can be a dangerous concept, authorizing opt-out (eg for limited improvements on greening, biodiversity and energy) Similarly. the phrase ‘wherever possible’ almost implies permission for an opt-out. ·The requirement for more audits would give more structure to some of the general ideas, for example, the phrase ‘pre-emptive clearing of a site’ avoids a biodiversity audit requirement, and should not be allowed. ·It is also important that the enforcement side of planning is used to audit compliance with existing energy standards in new houses. ·It is easy to adopt a negative mind-set which considers what should be prevented or restricted. We hope that we can think positively, in terms of actions which should be supported and encouraged.


·The DPD states that “….we will all need to take responsibility and make changes in the way we live.” We agree that actions by individuals are important, but recognise that individual changes best take place when policy conditions allow or promote them. Incentives to change are usually necessary. Individuals need support to help understand the reasoning behind proposed changes. ·We are promoting within our members a concept we call Earth Weight Checkers. This is based on a simple calculation of individual carbon footprint and ideas on how to reduce it over time The peer to peer encouragement is then similar to weight watchers. We would be happy to share this process with any interested parties. ·We made the following point in the May 2019 stage of the consultations. The point about Newquay Airport was not addressed, so it was asked in a follow-up question, but the answer to that left us with significant concerns, so we bring it again: ‘Quakers in Cornwall welcome the declaration of a climate emergency. What action will Cornwall Council take to identify and address current measures and policies which are incompatible with the declaration of a climate emergency. We identify, for example, the provision of a significant subsidy for the expansion of Newquay Airport.’"

398 3. I am concerned that policy C1(7) will be used as a green light for building at high densities in inappropropriate localities and in wasteful ways. I suggest qualifying this statement to state that it is aimed at regeneration of eg town centres, industrial areas and derelict sites and excludes eg the AONB, conservation areas and established green spaces in residential areas. It should also be stated that it is aimed at eg increasing the numbers of housing units on a site rather than encouraging fewer bigger housing units.

064 1. It is considered Policy C1 picks up the right issues. Given the policy relates to development per se, the Council needs to be satisfied that it is supportive of new energy projects, including for geothermal renewable energy, which would support other development types.

402 1. Policy C1 is unclear as to whether it relates to major, minor or all developments. In order to accurately assess the issues and principles of the proposed policy, further clarification as to what development it relates to will be required. In particular, further information should be included as to the expectations of the Council in circumstances where an existing business may seek to expand. It should be made clear whether the Council expect existing businesses to meet the requirements as set out within Policy C1, or if the policy relates exclusively to new development. Without this being clear, it is not possible to fully comment on the effectiveness of the proposed policy.

403 1. Agreed 4. Education, communication, engagement and resourcing at a local level are going to be essential to success

163 1. I support all these objectives, I particularly welcome the inclusion of better health and wellbeing in this Climate Emergency DPD 4. I think policy 2 could be clearer as community resilience is mentioned in the next objective

280 1. Agree with everything it states.

109 1. Point 9 – To conserve and enhance protected landscapes? Protected Landscapes is missing from this statement 2. As above

405 2. We would like to say how glad we are for the presence of a Climate Emergency Development Plan. Robotmother ltd is a business familiar with taking bold steps to work towards a more sustainable future and we’re glad that what was, in 2007, possibly seen as something for “hippies/ eco-warriors” when Jubilee Wharf was built is now much more mainstream. We whole-heartedly support the Council to be more and more bold in making systemic changes to reach for a target of carbon neutral by 2030, which is fast-approaching. Need for more bold moves Rather than “asking for” measures to reduce impact, we feel that the council must insist on such measures. So we’d love to see a slight change to the statement, on page 7 Energy efficiency standards which currently reads “Along with other Councils we are continuing to ask for either a faster move to zero carbon in new buildings or the power to raise our own standards”. We would like this to read that the council “..are continuing to insist on either a faster move to zero carbon in


new buildings or for the power to raise our own standards.” We are in an emergency, yet we know that central government action is unlikely to act quickly, especially during the pandemic, and so Cornwall needs to make sure we move forwards despite of central government inaction. In the earlier Climate Change Plan section 2.12 it stated that “There are some extremely difficult choices ahead, which will need us to revise the way we live; requiring redesign of existing societal systems and infrastructure as well as reviewing the impacts of plans which have been developing for future delivery.” This was bold, inspiring and exciting. Perhaps it could be put back into the Development Plan? Timescales The timescale of this plan means that it can’t be used to determine planning applications until the autumn of 2021 at the earliest. So that leaves 8 years to become carbon neutral/…. The consultation timetable loses one fifth of the time!!!! This further supports the need for really bold measures, to make up for lost time. Whilst this is in consultation and doesn’t yet have any weight, Cornwall Council is making planning decisions which may go against this, so we are not just losing precious time, but are making progress even harder. By 2022 we will have moved in the wrong direction, building inappropriate carbon-hungry estates and buildings, meaning that in the remaining 8 years will be even harder to get towards being carbon neutral.

292 1. In general, Policy C1 lists the right issues and principles, but they are purely aspirational – fine in principal but the devil is in the detail of plans for their execution.

097 1. C1.2 ‘Mitigate...change.’ Mitigation and resilience will, of course, be necessary. But they will be necessary to the extent of the failure of other policies sufficiently to constrain and enable society to live within environmental limits. This should be made explicit in the DPD and it should be made clear that they cannot provide a solution and that many of the consequences of the climate and ecological emergency cannot be mitigated against and that in many cases it will not be possible to make society reilient to them.

407 1. Maintenance of existing and “historical” water and rail transport routes for future use

408 4. The Council feel that the following points should be emphasised: 3.2.1 on page 8– “A number of Parishes and Neighbourhood Plan groups in Cornwall have declared climate emergencies. The DPD will act as an umbrella document to help in the development of Neighbourhood Development Plans, creating a link between the Local Plan and the climate emergency. Cornwall Council is keen to put in place Cornwall-wide policies to create consistent standards and provide certainty for applicants and communities. Whilst there will be a number of local actions that groups will also wish to pursue, Neighbourhood Development Plans will be expected to follow the emerging guidance set out in this DPD when considering policies in their neighbourhood plan areas to help ensure later conformity. Further guidance has been developed by the Neighbourhood Plan team to help guide groups that wish to create climate change policies.” 11.1.2 on page 17 – “A number of issues are cross-cutting and will impact on all areas. In particular biodiversity is critically significant to our long-term survival and has been identified as being in a state of decline. The draft policy suggestions of the DPD recognise the critical importance of biodiversity in relation to climate change and further embeds the Council’s Environmental Growth Strategy and the emerging approaches to nature recovery”

409 4. In particular relation to principle 11, Cornwall Council should be alert to opportunities to encourage the cultivation of kelp forests, which absorb CO2 at least as effectively per hectare as on-shore forests without competing for land use. They increase marine biodiversity, absorb wave energy and may be combined with shellfish cultivation. The American non-profit GreenWave (www.greenwave.org) sponsors such endeavours. Cornwall and the Isles of Scilly offer large areas suitable for kelp forests. Planning applications for marine developments, including offshore wind structures, could be encouraged to include provision for kelp cultivation. Cornish kelp forests could offer accredited carbon offsetting.

410 4. Wainhomes response As an overarching point which relates to the entirety of the document, we are concerned that the proposed DPD sets a series of standards which are not consistent with national planning policy and guidance. The Framework, NPPG and the Written Ministerial Statement from March 2015 (still referred to within the NPPG) give local planning authorities the option to set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access and water, and an optional nationally described space standard. However, the proposed


Climate Emergency DPD goes well beyond this, setting additional standards on a range of issues such as energy efficiency (i.e. matters which are already covered by building regulations). Notwithstanding our fundamental concerns in relation to the plan as a whole, Policy C1 is not clear as to what is meant by ‘be low carbon’, ‘use less energy’ etc. What standards are actually required? What is the impact upon viability? This needs to be set out through the policy, and evidence provided including on viability and how this will affect development planned for in the adopted Local Plan."

411 1. Quantifiable; what level of low carbon is being chosen as base? 2. Multifunctional green infrastructure provision should not just be focus within development but also the surrounding environment 4. I feel the C1 climate change principles are quite comprehensive. However, I have concerns over how these will be accepted by the general public. Cornwall Council is asking for big changes not only to policies but also to people’s behaviours. To achieve these goals, you will have to get the public on board with the climate change issue. AND the needed biodiversity-ecological parameters and the use of landscape for climate balance is an absolute as much as a negative carbon balance from fossil fuel use. I guess the vast majority of Cornwall’s population don’t even know CC has declared a climate emergency. We at Stithians Energy Group (SEG) realised that people would not make changes unless they understood why it was necessary. To achieve this, we produced a forty-page booklet explaining climate change and what they could do about it. This booklet was then distributed to every home in the parish and has been adopted by various organisations across the UK. What I am trying to say is: For Cornwall Council to achieve carbon neutrality by 2030 it will have to put aside a fund to finance (each parish town council could Crowd Fund this absolute) as many forms of public information as possible. Whether it is a booklet, social media, TV, posters, talks, or posted flyers. So, I propose a policy for Cornwall Council to inform the public of the climate emergency measures and explain why these measures are necessary. Yes this is important but we must realise this is a knee jerk response to the Climate and Ecological Emergency and refers to Planning. We must begin to redress this to all forms of activities in Cornwall not just in relationship to so called Sustainable Development over the next ten years inclusive of the current Cornwall Local Plan to 2030 and its addiction to the NPPF of a tory based administration. In this DPD proposal we are only seeking a response to increase of land conversion for a commitment of the NPPF need for a further 35,000 homes plus until 2030. This would amount to under 3500 hectares of land (1% of the land area of Cornwall). Yes it is important but it should be a pathfinder to all of Cornwall’s 356,000 ha.This is where we will be address this total Emergency not just on a current level of about 10,000 ha of land under the guidance and guardianship of Cornwall Council

265 1. The policy broadly covers the right issues and principles. It would be useful if references to energy explicitly include heat as well as electricity, given that decarbonisation of heat presents a pressing policy and planning issue that currently lags behind decarbonisation of the electricity grid.

329 "I would like there to be more focus on having a reciprocal relationship to nature and our natural environment. This seems very focused on the human benefits of these approaches and to achieve the aims of this consultation and future actions I think this is a huge opportunity to rethink the language we use and the ways we relate to our place within the natural world. I would like the opening statement to be changed to “Development in Cornwall must represent sustainable development and manage our natural and cultural assets wisely for future generations and for the benefit of the natural world” I would like #3 to instead of reading “Contribute positively to the health, wellbeing and resilience of our communities”, to say “Contribute positively to the health, wellbeing and resilience of our communities including the natural world.”"

276 1. • Major planning developments won’t effect us so much in St Just, but when we are asked by government to provide such a large number of houses in the next few years minor planning applications become major points of production. Because of this I would like to push for your Green Points system for minor developments to be stronger than it sounds. This should be a lot more robust and cohesive, include green corridors, hedgehog highways (gaps in fencing) making


sure as little natural ground is covered as possible (driveways, patios, astroturf). You could literally give applicants extra leeway with their planning applications, so like offsetting but it would work the other way around. More Green Points, more give in rules about what your windows/materials/design looks like. • Q6 – If more trees can be planted and more hedges be created without being connected to the forest for Cornwall then keep it separate. The idea is to plant as much as possible, so lets do whatever we can to make that so. • Q8 - The target for biodiversity should be 20% at the very least. We are already too late with this. We can afford to be radical here."

412 1. • We recognise that this is a planning document, and that not all our suggested solutions are achievable through planning policy. However, it is important that Cornwall Council don’t limit actions to issues associated with planning. They can do other things by subsidy of transport, scrapping the 3 mile minimum limitation on providing transport for taking children to school, and reducing speed limits. • Offsetting can be a dangerous concept authorizing opt-out (eg for limited improvements on greening, biodiversity and energy) • Similarly. the phrase ‘wherever possible’ almost implies permission for an opt-out. • The requirement for more audits would give more structure to some of the general ideas, for example, the phrase ‘pre-emptive clearing of a site’ avoids a biodiversity audit requirement, and should not be allowed. • We also would like to see a better audit of energy efficiency in new houses"

413 1. Only allow developments that are needed, ideally for local residents and not allow speculative developments 2. Only allow highest standards – e.g Passive Haus and exemplary building materials should be demanded

095 1. This is a good plan. Although 2030 is said to be an ambitious target, our comment is that this date should be brought forward. 1.0.1 says, “we can take urgent action when needed” and we think ten years is definitely not urgent enough!

234 1. We would suggest slightly raising the policy hurdle for point 8 by making the following additions, so that Point 8 would then read: 8. Conserve and where possible enhance the capacity for sustainable production of food, water, raw materials and energy. Minimise the impact upon the quality, stability, and function of soil and contribute to soil quality improvements where possible.

415 This is a good plan.

417 Draft Cornwall Council Climate Emergency DPD consultation response on behalf of the Plymouth and South West Devon Joint Local Plan (JLP) councils The following comments are the joint response of Plymouth City Council, South Hams District Council and West Devon Borough Council on the Cornwall Climate Emergency DPD Regulation 19 Pre-Submission draft. The three councils have also declared climate and biodiversity emergencies.

418 4. A bigger change to the functioning of the economy and society needs to be considered. Cornwall might need to become self-sufficient, living off local food and energy with very little imported, within the next 10 years. I am a Quaker and believe that spiritual wellbeing is fundamental to the quality of life. There is no mention of spiritual wellbeing in the DPD. Deep Adaptation, which is about the possible need to adapt more deeply to huge changes in the future, need much greater consideration: Positive Deep Adaptation: the 4 Rs R1 = Resilience: How do we keep what we really want to keep? R2 = Relinquishment: What do we need to let go of in order to not make matters worse? R3 = Restoration: What can we bring back to help us with the coming difficulties? R4 = Reconciliation: What could I make peace with to lessen suffering?

421 4. Generally, a good plan, although bringing forward the target date of 2030 would be advisable. As always, the devil is in the detail.


243 2. Policy C1.3 (health, well-being and resilience of communities) It’s crucially important that communities themselves decide what is good for their health, well-being and resilience. For example, an existing open space or path that on paper might look insignificant could in reality play a major role in community health, well-being and resilience known only to local people. Communities must be genuinely involved: it’s not for developers (or Cornwall Council) to second-guess what matters to a community. And consultation must engage heard-to-reach people too, especially the 25% or so who are digitally excluded. (See also response on Policy C1.8 below) Policy C1.5 (reduction in embodied carbon): this should be made more explicit by including a requirement for development proposals to be accompanied by an energy statement that includes the whole life carbon footprint of the development, in line with the Net Zero Carbon Framework developed by the UK Green Building Council which recommends that “a whole life carbon assessment should be undertaken and disclosed for all construction projects, to drive carbon reductions”. Such an approach would be wholly in line with Council’s net zero ambition. Policy C.1.6 (sustainable and active modes of transport) This policy is meaningless as regards large-scale development unless proposals are required to demonstrate genuine accessibility to shops and other facilities on foot or by bike. It is also crucial to avoid mismatches between provision of housing and employment space: building hundreds of dwellings in parts of Cornwall where employment provision is contracting (or rising only slowly) will inevitably increase car use as people are forced to drive longer distances to find work. Policy C1.8 (sustainable production of food): we believe that the Climate Change DPD should include a specific policy on allotments and community food-growing facilities, as proposed in our previous response to the scoping document. This would embed the allotment/self-sufficiency movement in Council planning policy and provide a means of expanding community food-growing at a time of rising food insecurity. Allotments are also well recognised as providing health, well-being and resilience benefits to local communities, so such a policy would be a good fit with C1.3. We suggested applying a formula that reflects existing supply and demand for allotments within the parish or town area in order to provide allotment space for residents of the proposed development. Ideally, this would be provided onsite; any offsite provision should meet the accessibility criteria for a Neighbourhood 1 site in the Council’s Open Spaces strategy, i.e. no more than 800 metres from the site (to reduce car use). In addition, where there is a current excess of demand over supply for allotment space within a community (as is currently the case in Penzance civil parish), a S106 contribution should be sought in order to fund the creation of additional allotment space for broader community use. This two-tier approach (allotment provision for residents on new development, plus a contribution to expanding allotment provision for existing residents) has already been adopted in some development plans (e.g. the Thame Neighbourhood Development Plan). Finally, any location proposed for allotments, whether on or off site, should be subject to (i) a soil assessment to ensure it is free from contamination and subsidence risk (as in a recent case in Illogan Parish, where land set aside for allotments associated with a new development proved unfit for purpose due to contamination from past mining activities) and (ii) a drainage assessment to ensure it is not prone to waterlogging or flooding. Policy C1.10 (light pollution): it would be helpful to include in this section a reference to Dark Sky Reserves, such as that currently proposed for West Penwith, and to the need for dark sky compliant lighting layouts in and around such reserves, to protect their value for biodiversity, local amenity and the visitor economy. Policy C1.10 (water pollution): there is no mention in the DPD of policies to tackle foul water discharge. This is already a major issue given the number of combined sewer overflows in the county (for example, when Storm Ellen hit Cornwall on 20 August 2020 – at the height of the tourist season – pollution warnings were issued for 20 beaches in the county). Development proposals must be assessed with reference to the existing capacity of the foul drainage system (including combined sewer overflows), taking account of the effect of extreme rainfall events beyond the conditions for which the system was originally designed. Policy C.1.11 (carbon storage): for development proposals on greenfield sites, the existing embodied carbon storage capacity of the site should be taken into account. This should be based


on actual in-the-field observation, over and above desk-based analysis or modelling, so as to take account of the actual conditions on the site. 4. In general, we feel the approach in Policy C1 is a very positive step by the Council towards ensuring that development does not impair our net zero ambitions. However, it fails to address the biggest threat to net zero in Cornwall: the excessive housing targets imposed by central government (which are about to get much worse if the proposals in “Planning for the Future” White Paper are implemented). The foreword to the DPD states that “we will need to continue to house our residents”. If new residential development was indeed limited to the need to house our residents, net zero would be more achievable. But building way beyond local need to meet demand from elsewhere in the UK will take us in the wrong direction. Each net inward migrating household puts more cars on the roads and more strain on scarce resources (from healthcare to water supplies and sewage disposal), over and above the carbon footprint of building the new properties."

056 1. The principles set out in C1 are good but they do not indicate we are in a climate emergency, as declared by Cornwall Council. They do not create a context for the level of change required for Cornwall to achieve net zero by 2030, or even meet the Climate Change Act legally binding target of net zero by 2050. Section 13 of the Climate Change Act 2008 as amended 2019 and a chain of related policy including section 19 of the Planning and Compulsory Purchases Act requires the preparation of policies to enable the 2050 net zero and interim carbon budget targets to be met. Planning policy must, therefore, be designed to achieve net zero, not ‘do what we can’ or ‘be heading in the right direction’. Policy C1 should include a fundamental guiding principle of local carbon reduction targets at least in line with the Climate Change Act, establishing viable pathways to achieving them, and monitoring performance on an annual basis. All planning policy should be designed to achieve these targets. Policy C1 does not establish a principle of the net zero transition, including the planning policy framework required to enable it, being citizen-led through citizens assemblies and similar processes. This should be added. Policy C1 does not sufficiently establish a principle of the transition being an economic opportunity for Cornwall and that policies should be designed to maximise the economic benefits for Cornwall. This should be added. comments noted - further advice has been sought on these points and will be incorporated into further iterations.

189 3. Draft Policy C1 refers to sustainable development but the wording then focuses entirely on environmental aspects of sustainability. Sustainable development has three components; economic, social and environmental (as noted later in Policy RE1). Whilst this policy and the DPD overall may be about environmental issues, the other aspects (economic and social) must be acknowledged and reference made to other documents and policies as necessary. Proposed Policy C1 provides a clear set of climate change principles for development in Cornwall to underpin the Council’s step change in response to the climate emergency. The importance of setting out a set of clear principles is supported and its scope is rightly wide-ranging. However, it is vital that the principles in this Development Plan Document are achievable for every development. Without this, they would quickly become unworkable which may cause significant challenges for the Local Planning Authority and Council. Firstly, the emerging policy states that proposals must contribute to and achieve the …objectives (our emphasis). It is suggested that these principles cannot be achieved on every development. In setting a policy that requires such a threshold it is likely to be difficult (or even impossible) for every development to meet all of the 12 criteria listed. Securing the aspiration is absolutely the right approach but it is necessary for the policy to also be deliverable and, in due course, meet the tests of soundness set out in the National Planning Policy Framework. Secondly, there is no information provided that helps to understand how these principles can be demonstrated and or whether there is a threshold that will be set in the future – something that we suggest should be avoided. Further, some of the criteria could be extremely onerous for smaller developments, even for smaller scale major developments. This would make the information requirements disproportionate to the development. Overall, it is important to present


a clear understanding of how these principles will need to be demonstrated in order to secure an informed response to this draft policy. Thirdly, Cornwall is a large and diverse area. It is important that the policy objectives are appropriate to all areas and types of development in order, once again, for it to be achievable. There are some principles that would not be relevant to the development and may not be achievable for the location. For the reasons above, the start of the draft policy should be reworded to recognises these limitations: “Development in Cornwall must represent sustainable development and manage our natural and cultural assets wisely for future generations. Where relevant and feasible, proposals must contribute to and achieve the following objectives:”

424 In this context Policy C1 is a good policy. It could be improved by the adoption of the emerging concept of regenerative development. Sustainable development is a failed concept as in the nearly 30 years since the Rio Summit we did not pursue ‘development that meets the needs of the present without compromising the ability of future generations to meet their own needs’ as we exceeded our own needs and have left future generations potentially being unable to meet their own needs. Regenerative development recognises this and that we now need to rebuild and replenish the natural world in order that future generations may be able to meet their own needs. The policy could also be improved by setting out some metrics for the objectives is sets out. All of them are important, but ensuring that sufficient change occurs is vital. Thus requirements for energy use, sequestration, modal split, biodiversity increase, local food production etc. would be useful in places to drive change more forcefully.

019 4. Historic England welcomes the acknowledgement in Policy C1 that Cornwall’s cultural assets should be managed wisely for future generations as part of achieving sustainable development. We also strongly support objective 9). However, we consider that this policy should also include the positive contribution that the historic environment (individual designated and non-designated heritage assets as well as wider townscapes, landscapes and seascapes) can make to understanding, mitigating and adapting to climate change. One notable example is the substantial contribution that retaining, reusing, refurbishing and retrofitting historic buildings can make to reducing carbon emissions (by more than 60% by 2050). There is a lot of information on Historic England’s website.

168 4. Wording of point 4 is odd: Contribute positively to environmental growth, protecting and increasing the ability of natural systems nature recovery networks and and ensuring a net gain for biodiversity; Suggest: 4) Contribute positively to environmental growth, protecting and increasing the ability of natural systems to provide natural solutions for climate change whilst ensuring a net gain for biodiversity as part of a nature recovery network;"

144 1. These are fine words but much too vague. They add little to the original climate change plan the Council produced back in 2019. It is difficult to see the point of being consulted on a document that shows such an apparent lack of understanding of the ‘emergency’ aspect of the ‘climate emergency’ and the absolute necessity for swift and radical action. 2. The representations that many of us made in the consultation on the scoping document – to include tourism, strategic housebuilding targets and aviation - have been entirely ignored. Any ‘plan’ that makes no mention of the carbon costs of continuing with the Council’s current strategic policies is flawed and unfit for purpose. Policies on housebuilding, roads, aviation and tourism are not ’green’ in any sense of the word and the opposite of ‘resilient’. Furthermore, this DPD lacks the ‘innovative’ policies that are required but merely tinkers with policies that will do little or nothing to achieve zero carbon by 2030. That’s less than ten years. If this an emergency we need urgent action, for example close Newquay airport, car-free days, increase parking fees, no licensing of any event that attracts people from a wide area, demand immediate moratorium on speculative housing schemes etc. 3. Lobby the Government for a carbon rationing scheme as a matter of urgency.


4. Sadly, this plan is so feeble and lacking in context that it is a waste of time commenting on it in detail. It’s just moving the deckchairs around on the Titanic. An apt metaphor if only there were some icebergs left to crash into.

428 1. Management of land for food, fibre or fuel can help to deliver environmental growth and bio diversity net gain. Its not always an either or and this should be recognised. 2.Surely the DPD should support an increase in "sustainable food production" and enable a better understanding on how to "minimise the impact of the production process”? 3. Much (not all ) of our natural, historic and cultural environment is in rural areas and is on land managed by farmers and landowners. Whilst I can see a need for a policy around the built environment and multi-functional green infrastructure (beyond that provided/managed by farmers and land managers already) separating the natural environment from farming provides an artificial divide that policies should not re-enforce. 80% of our land mass is managed in some way (either for food, fuel, fibre or environmental objectives) so this should be recognised. 4. Linked to the point above do we have a natural environment? If 80% of the land is managed in some way then I would say we have a managed environment. How it is managed is then a decision for the manager of course. • Pre submission question 1 – in general yes but the artificial divide between the environmental management of land and the commercial management of land (which could be for environmental objectives) is unhelpful. In addition I do not think the policies consider the requirement to maintain and enhance sustainable food production enough especially when considering resilience. Whilst as a society we can throw away less food, eat less, change diets (NB: I am not advocating a plant based diet by the way) we still need to eat and we need productive land to do that."

5. Proposed Policies Natural Climate Solutions

Policy G1 – Green Infrastructure Design and Maintenance Policy G2 - Environmental Net Gain Policy G3 - Cornwall Nature Recovery Network


1. Do Policies G1 – 3 pick up the right issues and principles – is there anything you would add?

2. Is there anything else that should be included in these policies?

3. Do you have an alternative approach to policies G1 – 3 that you think the council should consider?

4. Do you think further clarification or advice on the interplay between green infrastructure design and green space factor (Policy G2) is required for minor developments?

5. Policy G2 requires the provision of Canopy Cover (trees and hedges) as part of biodiversity net gain. Given the Council’s commitment to tree planting as a part of the Forest for Cornwall, should this be a separate policy?

6. Or would it be better having a policy requiring a specific proportion of tree provision with a policy setting out a requirement for Biodiversity Net Gain specifically for trees?


7. The mandatory minimum 10% Biodiversity Net Gain figure is specified by DEFRA as being necessary to reverse the decline of natural capital and allow a sufficient buffer to ensure that real net gains are made.

8. There is no legal reason why Cornwall Council could not set a more ambitious local target of 20% but a larger requirement could impact on the amount of developable land on sites or increase the financial contribution required and must be balanced against financial viability. In your opinion should the target be 10% or 20% or another percentage target and why?

9. Metrics are being developed to measure the wider impacts of development on natural capital and eco-system services, such as flood risk and carbon soil storage. Do you agree that a requirement should be made through policy requiring that major developments are accompanied by a basic form of ecosystems metric?

10. There are different potential policy options to increase tree cover including building in requirements to the net gain policy (as per Policy G3) or setting out a separate requirement. How do you think this requirement should be expressed and made simple to understand and implement?

11. Any further comment?

URN Comments

352 2. G1 - In addition to 13.6 involvement of AONB would be desirable. 3. G1 (10), 5th bullet of 13.5 and g2 (2) - How will this be mandated and policed?2nd bullet of 13.6 - Work in Progress - how to fund completion? 4. Yes – this will be challenging to interpret for householders. 5.Yes 6. No 8. 10% 9. Yes 11. The status of the Lagas Nature Recovery Network map needs to be under constant review. Right now it seems to be merely a ‘work in progress’.

355 1. Yes very supportive of policy G1 which picks up on the main issues and principles. The change that has taken place already over the past couple of years with parks and verges having a focus on wildflowers and trees where possible is positive and makes Cornwall a better place to live. It is a visible example of work to increase biodiversity and which also offers tangible opportunities for individual residents to participate. All new developments should live up to the highest environmental standards and have built in green spaces which will make them better places to live. 8. 20% would be better – we need to do more than just ‘stem the decline of biodiversity’ if we are to flight climate change and biodiversity loss challenges over the coming years and decades. 9. Yes absolutely. 10. Yes better to be clear. Trees may not always be the most appropriate form of nature (some areas are better suited to scrub/meadow so important that we don’t make the policy too ridged in terms of the type of net gain we are encouraging.

358 1. Yes, nothing to add


2. No 3. No 4. Yes 5. No 8. 15% to strike a viable balance. 10. Don’t know 11. Ensure no wriggle room in G4 – offsetting and suitable location

359 2. Not that I can think of – appears comprehensive

360 2. Why is it that with some new developments hedges and tress are being removed or destroyed. These features have taken many years to become established and yet are removed. Should it not be made that any new developments have to work around these features. This may of course mean lesser buildings on the site but may be better received. It is of no help to anyone to impose a fine if this is done as the features damaged will take years to become established again. 3. Any site used for renewable should be where the impact of the site doesn't affect local communities. In the past very little consideration has been given as to the health and well being of local communities when granting permission for the features. 5. This policy must be adhered to and enforced. It has been possible in the past for developers to ignore these conditions and damage the infrastructure and get fined for doing so. The amount they gain is outweighed by the small fine so should be strictly enforced. 6. Again more consideration must be given to communities. In the past their objections have been ignored. I believe this has been done because of financial rewards for installing renewable features. 11. In the past developers have agreed to supply and maintain these areas but when the development has been completed it falls on the Parish council or Cornwall council to maintain these areas. The developer must be held accountable.

362 "13.5 Policy G2 - Environmental Net Gain • For all major planning applications and all CC development schemes (including highways and infrastructure) a Biodiversity Net Gain calculation will be performed and assessed by a qualified ecologist as part of site surveys. This will ensure net gains for biodiversity are provided on site, or, as a last resort, offsite, as part of a formal offsetting scheme. The problem with this policy is that the finest field biologists are rarely qualified ecologists. It is undoubtedly the case that the majority of the most skilled field botanists in Cornwall, past and present, are/were not qualified ecologists. It is also true that most qualified ecologists are not skilled enough to perform a high quality site survey. Invariably it is not something that they have been taught as a part of their ecology degree. This is a significant problem, as ecologists who cannot accurately identify the plants that are found in a particular habitat cannot fully understand the ecology of that habitat and so will be unable to perform and assess a Biodiversity Net Gain calculation effectively. What is needed to make such assessments are highly skilled field botanists irrespective of whether they are qualified ecologists or not. 13.6 Cornwall Nature Recovery Network


Whilst this policy is laudable, the reliance on the Lagas Nature Recovery Network map is unacceptable given is has been created without using up to date species data. Whilst the Lagas maps are an interesting academic exercise, they cannot be considered a reliable source of information for planning without extensive ground truthing. Such ground truthing is readily available, as a result of the BSBI survey, via the Cornish Biodiversity Network, and is needed to test the modelling and to identify its flaws. For example, the heathland-opportunity-map does not show all the existing heathland and because it has not incorporated the real data from recent complete survey of Cornwall, it fails to identify all the heathland opportunity areas. So, whilst it is a potentially useful tool, it needs refining with real, up to date, survey data before it can be reliably used for the planning process. NATIVE SPECIES 7) For grass habitats such as verges and amenity grassland, planting should consist of at least 50% insect pollinated plants with a minimum of 10 species and predominantly native species; 9) Landscape bed planting, including ornamental beds, should comprise of at least 50% insect pollinated plants of a varied species mix and including predominantly native species; This is a good policy for urban areas but it necessitates the use of native species that are both native to Cornwall and locally derived, plus are correct for that part of Cornwall, and are suited to that particular habitat and subsequent management regime. All too often what is actually planted are non native species as well as native plants that are not only wrong for that part of Cornwall but are not locally derived. Furthermore, arable weeds are often planted which provide a flush of colour for a single season but soon disappear being unsuited to the habitat where they are planted. There are many recent examples of inappropriate planting which can be cited like the central reservation along the main road near Treliske and the road improvements along the old Redruth bypass by Tolgus School (Redruth School). The existing advice Cornwall Council gives regarding native species on its website contains errors and is hopelessly out of date. As it states it is largely based on A Review of the Cornish Flora 1980 by Len Margetts. Our knowledge of the Flora of Cornwall has massively improved since 1980. Having a policy about the use of native species will necessitate Cornwall Council finding out what are Cornwall's native species and which ones are appropriate for specific areas of Cornwall, as native species are not uniformly spread across the landscape. The planting of grass habitats and landscape bed planting should be restricted to urban areas. Let nature do the work in rural areas!"

363 1. 11 Policy G1 is not a policy it is a set of assertions about green infrastructure etc etc. 12 Policy G2 does not define what a major or minor site is. This is CIL and s106 all over again, just a different colour 13 Off site biodiversity gain is a very poor substitute and so should be double the area of onsite gain. 14 Policy G3 Cornwall Nature Recovery Network sounds weak. Look at the AONB in Cornwall a whole load if sites labelled as one and as a result a nightmare to manage and control.


15 Most important policy regarding housing is to make sure that the numbers relate to the numbers of people who actually live in Cornwall not as an attractant to cause inmigration. The consequence is that people must have sufficient incomes to buy the properties not that the properties must fit the miserable incomes currently available (less than70% of national average) and bear in mind a lot of people will be out of work as a result of Covid and a lot more when Brexit bites in 2021! If incomes were higher there would be less housing stress as people could afford to buy the houses already available!

364 1. G1-3 Stop building plastic houses. Re open all the old rail network, this was stolen from us by the oil industry for more roads for their cars. G2 Shut all out of town shopping centres, do not allow any more to be built anywhere. They are a menace. These crooks could not care less about biodiversity, or the environment, all they care about is money in their pockets. If let to stay open they must be made to pay a very large amount of council tax to make up for the money they are taking from towns, as the towns need the money, for the facilities that they are providing for all the people. We need a lot more tree cover in Kernow at this time.

367 1. I believe this Policy covers important issues and principles. Members of the Public would like I believe to see clearly the chain of accountability, monitoring and responsibility for explaining how policies are monitored and put into practice

374 1. Nothing to add 2. G1 - In addition to 13.6 involvement of AONB would be desirable. 3. "G1 (10), 5th bullet of 13.5 and g2 (2) - How will this be mandated and policed? 2nd bullet of 13.6 - Work in Progress - how to fund completion? 4. Yes – this will be challenging to interpret for householders. 5. Yes 6. No 8. 10% 11. The status of the Lagas Nature Recovery Network map needs to be under constant review. Right now it seems to be merely a ‘work in progress’.

029 1. Policy G1 -8 that seeks to integrate street trees is laudable but much of the existing built environment around our towns is of narrow streets and close together housing such that introducing a small new development with wide streets and street trees would be out of character with the neighbourhood and not locally distinctive. There needs to be some give and take on these issues. 2. Not that we can think of. 3. No 4. No 5. Yes 6. No 8. We believe the target could be 20%, as Cornwall could easily take more trees and has the land space to accommodate this, while 20% would seem to keep the financial viability reasonable. 9. Not sure at this stage that these metrics would provide anything meaningful, it could be another expense and complication in the way of achieving much needed homes. There are already requirements for flood risk assessments and SuDs assessments.


10. We would prefer to see the potential policies and options set out for us to comment on, as opposed to us trying to think of them. 11. No

032 Policy G1 – Green Infrastructure Design and Maintenance - It would be helpful if “major developments” are defined: is the now near-universally accepted level of 10 or more units appropriate? Also, to avoid doubt, it should be stated that this – and other relevant policies – will be applied to all affordable housing and other social housing schemes. 7. “For grass habitats such as verges and amenity grassland, planting should consist of at least 50% insect pollinated plants with a minimum of 10 species and predominantly native species”. Will there be flexibility to this as may be dictated by good management practice? For example, cutting schedules to roadside verges at junctions may require frequent cuts to keep visibility lines clear and recreation areas may also need frequent cutting to be fit for purpose. 10. Is it possible to insist that gardens of this size are retained in perpetuity? That is, can owners’ GDO rights to build extensions be removed (by a county-wide Article 4 Direction, for example)? Or, rather extreme, by seeking to prevent decking or paving beyond a certain area? 11. Green infrastructure within a development will not be adopted by the local authority then along with other associated infrastructure? This will result in a perpetual service charge on house owners/residents within the development. What will happen if the developer goes bust or dies? We have seen in the past that this can result in “green” areas such as visibility splays and recreation areas being effectively abandoned. The monitoring and enforcement of post-development undertakings has been a consistent weak link in the planning process: particularly the alignment of expediency and cost. In practical terms, green infrastructure within developments should be adopted by Cornwall Council and an appropriate fund secured from the developer to meet ongoing maintenance costs. Policy G2 - Environmental Net Gain This policy seems fine except for 4. If a developer claims to be unable to provide onsite gain, is this to be validated by reference to the physical nature of the site (in which case build less or somewhere else) or because it suits him financially (let’s maximise units in Padstow and provide environmental gain on the outskirts of Bodmin)? If net gain is provided off site, how will it be managed, and will it be managed properly? Our experience of both the desire and ability to press enforcement of s106 Agreements suggests this will not work. It is only by physically incorporating the net gain land within the development site, as a whole, can its future (either through a residents’ management company or by adoption) be guaranteed. If net gain “has” to be provided off site, will the justification be open to public scrutiny with the planning application and the terms of the offset gain?" Policy G3 - Cornwall Nature Recovery Network Seems acceptable.

378 1. The wording needs to be stronger. Any land which has the potential to form part of the habitat interconnection network should be identified and any planning application which reduces this potential should be refused.


1-3 Planting trees will in the short-term act as a carbon sink however it must be made clear that in the long-term the planted areas will be in equilibrium and no longer remain a significant carbon sink. 4. As the sum of all minor developments will have a considerable impact, it would be useful for specific guidance to be available. 6. Yes. Cornwall Council should develop a woodland management scheme which aims to achieve an open woodland landscape with woodland glades which imitated the open glades in the ancient greenwood which were biodiversity hotspots. Consideration should be given to encouraging the development of wood pasture. Trees growing in open habitats are significantly longer lived than those planted more densely. 7. Biodiversity is a complex and highly interconnected issue. There should be one overarching policy to reflect this complexity. 8. The more ambitious target of 20% is a useful aspiration to aim for as resources permit. 9. Yes; appropriate metrics are a useful guide to the effects of developments and their environmental mitigation. 10. Policies need to include a clear woodland management plan (see answer to question 6) and ensure it is clear that land which already contributes to the interconnected network of habitats and that which has the potential to do so is preserved from adverse development.

351 Policy G 1 Start tree cover on moors, on slopes to prevent land slips and around motorways and clay and incinerator to filter out toxic gases and particles. Bring soil to clay country to nourish planted trees . Encourage airfiltering driven by renewable energy alongside roads, motorways and dirty living like clay and incinerator areas. Stop motorists speeding down rat runs where people dare not back out of their drives, for lunatic drivers. This goes on all over Cornwall, where speeding limit should be 15 mph. You totally ignore this problem 14.4.8. Forestry Plant many more trees than you have planned for. Plant green covering on balconies and sides of flats instead of plastic. Cover roofs of both old and new buildings with either solar panels or greenery and small shrubs. Supermarkets, bus shelters , do likewise Policy AG1 Do not allow sewage waste from any country to enter Cornwall. Disease lurking within the sewage and excessive manure treatment will tip soil from being that of under humus content to soil overburdened with nutrients, to a degree of becoming a poison. There are also toxic chemicals in sewage. 14.6 Ensure that self build Housing organisations are permitted to flourish Ensure composition of concrete building blocks are comprised of insulating materials like hemp which grows in this country, human and animal hair which can be sourced from hairdressers and farms. Palm Tree leave and grasses can be used.

053 1. Policy G1 - Green Infrastructure Design and Maintenance We recommend adding 'GI must be considered from the earliest stages of development' We suggest adding a reference for food foraging for food growing (e.g. under principle 3)


• We welcome the clear requirements for native and insect pollinating grassland and bed planting. We note there are no requirements around tree species and urge that the policy indicates a preference for an ecologically appropriate diversity of species native to Cornwall (acknowledging other species selections may be more appropriate in some cases, e.g. in urban environments). • We would welcome a requirement that trees are sourced and grown in the UK, or more locally where possible, to support local nurseries and help avoid the spread of disease.

383 1. Policy G2 - Environmental Net Gain: • We strongly welcome that 'Development should not result in any net loss of canopy on site by means of the retention of existing canmopy (including trees and hedges) and the planting of new canopy in the form of trees and hedges as reinforcement of existing hedges and woodland, street trees and other planting'. Per NPPF para 175c, ancient woodland and veteran trees are irreplaceable (we note that Cornwall's adopted Local Plan Policy 3E does not emphasise the exceptional circumstances test) - we suggest this is emphasised here. We welcome the emphasis on first retaining all existing trees and hedges. • We highlight that Biodiversity Net Gain (BNG) addresses biodiversity and not carbon. We urge that Cornwall considers developing a tree replacement policy over and above BNG requirements that considers the replacement ratio needed to restore the carbon store within a reasonable timeframe (which will often make the case for retaining a tree), which also relates to Policy SC2. We welcome exploring this further with the Council. "Policy G1- Green Infrastructure Design and Maintenance From a designing out crime view the creation of green spaces and routes in new developments is supported in principle. Indeed such spaces can help create defensible space in certain situations. However care must always be taken with the detailed design of such schemes and there are certain these which crop up within most schemes. Green space should not be located so as to potentially undermine the security of dwellings or other buildings or so as to adversely affect the wellbeing of residents or users of such. Obvious bad examples might be play spaces or green routes located behind dwellings or buildings with poor natural surveillance. How will the green routes actually be used is a question that must be asked for every site. For example if is just a leisure route this may present no major issues but if likely to be a school route for example then how safe this will be and importantly also how safe it feels must be fully considered. Will the routes proposed be overlooked and properly lit are obvious questions. The creation of green spaces must consider what type of planting is used in terms of possible impact on natural surveillance. For example the type of tree species used may over time affect natural surveillance of the street from dwellings or


indeed the effectiveness of street lighting itself. Similarly planting in certain places must be careful so as not to create possible hiding places such as close to footpaths

034 13.1.1. Mention must be made of landscape, which is a key element of Natural Capital, not least because it provides natural shelter against weather systems to create the environment for biodiversity. Landscape protection is essential for the environment, for biodiversity, for recreation, for tourism and of course for food production. Consideration should be given to extending protection to local landscape designations such as AGLV as part of environment/climate planning policy. "It would be helpful if “major developments” are defined: it is suggested that 10 or more units would be appropriate. Also, to avoid doubt, it should be stated that this – and other relevant policies – will be applied to all affordable housing and other social housing schemes. 7. “For grass habitats such as verges and amenity grassland, planting should consist of at least 50% insect pollinated plants with a minimum of 10 species and predominantly native species”. Will there be flexibility to this as may be dictated by good management practice? For example, cutting schedules to verges may require frequent cuts to keep visibility lines clear and recreation areas may also need frequent cutting to be fit for purpose. 11. Green infrastructure within a development will not be adopted by the local authority then along with other associated infrastructure? This will result in a perpetual service charge on house owners/residents within the development. What will happen if the developer goes bust or dies? We have seen in the past that this can result in “green” areas such as visibility splays and recreation areas being effectively abandoned. The monitoring and enforcement of post-development undertakings has been a consistent weak link in the planning process: particularly the alignment of expediency and cost. In practical terms, green infrastructure within developments should be adopted by Cornwall Council and an appropriate fund secured from the developer to meet ongoing maintenance costs." "Policy G2 - Environmental Net Gain This policy seems fine except for 4. If a developer finds himself unable to provide onsite gain, is this to be validated by reference to the physical nature of the site (in which case build less or somewhere else) or because it suits him financially (lets maximise units in Padstow and provide environmental gain on the outskirts of Bodmin)? If net gain is provided off site, how will it be managed and will it be managed properly? Our experience of both the desire and ability to press enforcement of s106 Agreements suggests this will not work. It is only by physically incorporating the net gain land within the development site as a whole can its future (either through a residents’ management company or by adoption) be guaranteed. If net gain “has” to be provided off site, will the justification be open to public scrutiny with the planning application and the terms of the offset gain? It is suggested that if net environmental/biodiversity gain has to be provided off site then this should be on land of low agricultural value and of relatively low landscape value. Cornwall has numerous areas of land, of many different sizes,


which are unsuitable for agricultural use. These may be scrub or may be mineralised soil from old mine workings. These offer great potential for improvement through tree planting or other wilding schemes to uplift biodiversity and environmental quality. Seems acceptable.

348 1. Vistry Group support policies G1-3, however we would welcome a further discussion with Cornwall Council to ensure that the policy do not negatively impact in the delivery on the delivery of affordable housing in areas of high need. A site-by-site approach could help to mitigate against any such impact. 2. Is there anything else that should be included in these policies? 3. As set in in Q1. above, we would welcome a further discussion with to ensure that the policy do not negatively impact in the delivery on the delivery of affordable housing in areas of high need. A site-by-site approach could help to mitigate against any such impact. 4. The design response needs to be proportional to the size of the development, taking into consideration its context in terms of; location, density, tenure and other mixed use, e.g. local retailers. 5. Vistry Group are in support of enhancing the environments in which we build and support the principles of G2. However, in respect of G2.3 and the suitability of all major developments to accommodate 15% Tree Canopy Cover, the nature of the climate and exposure to the elements in some parts of Cornwall could result in this being difficult to achieve. Other available Net Gain methods that might be more suitable for the local landscape context e.g. it might be more appropriate for us to provide wildflower meadow or species rich hedgerow based on the ground conditions and prevailing weather conditions. We believe it would be more appropriate to include trees within the Environmental Net Gain Policy. This can then be inclusive of tree coverage and any tree lost/mitigation requirements. " 7. Vistry Group are aware of the emerging national Biodiversity Net Gain requirements. 8. We believe that Cornwall Council’s policy should be aligned with DEFRA’s target of 10%. In 2019 Spring Statement, the Government announced that it would mandate net gains for biodiversity in the forthcoming Environment Bill. This legislation will require development to achieve a 10% net gain for biodiversity. It is Government’s opinion that 10% strikes the right balance between the ambition for development and reversing environmental decline. 10% gain provides certainty in achieving environmental outcomes, deliverability of development and costs for developers. 10% will be a mandatory national requirement, but it is not a cap on the aspirations of developers who want to voluntarily go further or do so in designing proposals to meet other local planning policies. The Government will use the DEFRA Biodiversity Metric to measure changes to biodiversity under net gain requirements established in the Environment Bill. The mandatory requirement offers developers a level playing field nationally and reduced risks of unexpected costs and delays.


The 10% target is a new and significant challenge for the sector to meet and further increasing this risk without testing delivery against 10% first could adversely impact on development across all tenures." 9. Vistry Group believe that developing an eco-system metric within Cornwall’s policy is less favourable than adopting the emerging national policy. Aligning with national policy will ensure certainty and in turn maintain delivery of homes of all tenures. 10. As set out Q5. above, we believe tree cover should be provided for within the Environmental Net Gain Policy.

6. Proposed Policies Whole Estate/Farm Plans and rural development

Policy AG1 - Whole Estate/Farm Plans and rural development Policy AG2 Regenerative, Low Impact Development Policy AG3 - Air and water quality improvements Policy AG4 – Rural Service Development


1. Do Policies AG1 – 4 pick up the right issues for rural areas – id there anything more that you would add? 2. Are the policy approaches that we are suggesting in policies AG1 – 4 about right – is there anything missing? 3. Do you have specific comments to make about the content or intentions of policies AG1 –

4?

4. Policy AG1 adds to types of exceptional development in the countryside that support the

aim for Cornwall to be carbon neutral and provide public goods such as carbon

sequestration, flood protection or increases in biodiversity. Should this include allowing

small numbers of housing to meet local needs, particularly of the estate and how should this

be tied to enabling land management improvements and delivery of our sequestration or

biodiversity aims?

5. Policy AG2 adds a further exception for new housing in the countryside based on the creation of zero carbon homes and restorative low carbon agriculture – do you support this exception, and do you think that the policy provides protection against unnecessary development in the countryside? 6. Policy AG4 increases the development types that may be permitted on rural exception sites to help create more sustainable communities. This policy could potentially impact on the ability to delivery affordable housing on exceptions sites. Would you support this approach? 7. Do you have an alternative approach to AG4 that you think the council should consider?


8a: In addition to low impact development in Policy AG2, would you support a policy that encourages the development of low carbon co-housing schemes within or adjacent to existing settlements? 8b. Should a policy allow for co-housing to be developed on exception sites that would normally be used only for affordable housing where a mechanism for controlling future residents and price can be provided? 9. Any further Comment?

URN Comments

352 The criteria for OPD in Wales include the requirement that “65% of all subsistence, or 30% of food and 35% of livelihood, come from the land. How to measure and certify this? “ecosystem links” are not defined Housing should be the subject of distinct policies not traded off against other criteria. Policy AG2 Not supported Policy AG4 No – affordable housing does not satisfy the need (i.e, it’s not affordable) social housing should be the only criteria for exception sites. 8a Once more this should be part of housing policy. How will carbon sequestration be assessed?" As per 6 above Development in the open countryside should be incorporated into allowable and monitored development. Temporary homes should be subject to planning permission, timescale - local impact, etc.. I worry that AG2 will encourage a 'free-for-all' on otherwise protected land. AG4 - New premises should be accessible by public transport. FTTP should be encouraged. "

355 It is not very clear what policy AG1 is proposing. The principles sound fine, but the detail is lacking. 5. Policy AG2 adds a further exception for new housing in the countryside based on the creation of zero carbon homes and restorative low carbon agriculture – do you support this exception Potentially no. It is important to have some areas/zones where no new house building is allowed. The ability to develop work hubs in rural areas needs to be considered carefully. Remote working will be much more prevalent going forward and a balance needs to be found between developments of this type which will breathe life into rural settings without opening the door for a large number of new developments that will negatively impact on the nature/biodiversity of the areas they are situated in. Setting a target/upper limit on these types of developments and having a Cornwall wide coordinated approach to work hub developments will be important.

358 1. Do Policies AG1 – 4 pick up the right issues for rural areas Yes, but mindful of increased road use on single track roads Impact of increased traffic on single track roads 4. Policy AG1 - Limited to local use now and in the future, price controlled Policy AG4 Would you support this approach? Yes Would you support a policy that encourages the development of low carbon co-housing schemes within or adjacent to existing settlements? No due to commonly poor road links 8b. Should a policy allow for co-housing to be developed on exception sites that would normally be used only for affordable housing where a mechanism for controlling future residents and price can be provided? Yes


Mindful of additional vehicular movements to and from sites regarding business activities. 360 A.G.1. Many farms have a large roof area. This could supply, if encouraged, a

supply of rain water, which could be stored. Also would it not be possible to encourage Solar panels to be installed on these roofs? With facilities to store this power generated this could also help reduce the farms outlay. AG2. Modern farming and land management doesn't seem to encourage deep ploughing of fields. This I believe creates a solid ground pattern the doesn't allow natural absorbance of rain water and leads to rain water running off the ground taking the top soil with it. This leads to drains and other natural means of drainage becoming blocked. AG3.This policy needs to be enforced as in the not too distant passed farmers were encouraged to install renewable projects with little or no consideration to local communities or the environment. The main driving force for this was government subsidies. AG4.If we are to encourage less travel then installation of an efficient internet service must be provided. If accommodation is provided to reduce travel it must carry a restricted placed upon it that this must be the sole use of the residence. Too often after these buildings are installed it is followed by a request to remove the restriction.

363 "1 Policy AG1, this surely is a mechanism to allow owners to plan for building on agricultural land under the guise of whole estate planning especially under the new scheme D Johnson is touting around the place. NO! See my comments in the para above. Make jobs pay better and houses become more affordable and so the speculative element of inmigration and ever higher house prices falls aside. This could include wind turbines, industrial estates and everything in between. It is a neighbourhood development plan for an estate and so seeks to get away from council control of development. Meanwhile what constitutes an estate? 10 hectares? 10 000 hectares? 2 Policy AG 2 Regenerative low impact development. The first requirement is to ensure that any development takes into the comparative advantage of the proposed site compared to alternatives. This is an economists tool for ensuring that the available resources are used to best advantage. If the comparative advantage for growing potatoes, vegetables, flowers and the like is greatest in Cornwall then focus those activities in Cornwall. The analysis needs to take into account the physical resources (eg land, climate, soils, proximity to markets and transport) as well as economic advantages. Thus do not consider just the slope and soil type of land but also look at the number and type of crops which it can produce and their value. Three crops of potatoes and some flowers are worth more than one crop of late potatoes produced on heavy clay soils in Lincolnshire. Look also at the job creation potential both numbers and the value of the jobs, do they generate incomes sufficient to buy a house where they function? Beware of temporary structures and differential job conditions to improve viability it is like the infant industry arguments of old, a bad thing. If it cannot stand on its own two feet without special measures will it ever stand on its own two feet? Look at the planning consents given for three years to demonstrate viability. How many extenuating circumstances have been argued for extensions and extensions of


extensions until these things somehow morph into permanent structures with no supporting business and lo and behold a dwelling is permitted in the open countryside which should not be there! However, this must not derogate from the principle of distributed development and settlement which already prevails in Cornwall. The settlement must be driven by the economic development so if there is fishing then a fishing settlement, mining, a mining settlement and so on. If there is a lot of horticulture as in West Cornwall needing a lot of labour then settlements are justified. However note that there must be a level playing field for labour, not cheap labour exploited from Europe or Turkey or India paid low wages and provided with poor conditions. Not just settlement in urban areas because they are there and then scratch round for jobs to make them pay. See my comments above about SUDS, Vetiver Grass, anaerobic digestion and the like. Ultimately the key measure for any economic development is the rate of return per £ invested. If that is less than 1.5 don’t do it. 3 Policy AG 3 air quality. Cornwall Council needs to do a lot more air quality monitoring, probably every Parish and Town Council should be equipped with the machinery both physical and human to measure and report on air quality quarterly and the particles need to be down to 2,5. The example of St Dennis and the incinerator is a disgrace to the Council which has ducked and dived all over the place and given itself a bad name into the bargain rather than monitor the air quality. Waste water, see anaerobic digestion costs and benefits thereof. See also the parlous state of the various reservoirs which SWW are neglecting allowing weed to grow across them and taking no action. They hide behind SWLT which is in fact owned by SWW and used as a dodge to off load their duties of care onto a charity so that it obtains tax and grant aid advantages and evades doing the work which it should be undertaking to ensure water quality and security. Apply conditions to planning consents to leverage this. 4 Policy AG 4 This is skinny stuff. Every settlement needs a post office every day of the week. It needs a reliable and efficient postal delivery service for letters and parcels the latter driven by internet commerce. Delivery vehicles need to be battery or preferably fuel cell operated, (you can extract hydrogen from biogas), dispensing rural surgeries are vital in every large village. Busses are not viable as the days when large numbers of people worked at one place on the same shift like Holmans,mines, Falmouth Docks or even Heathcotes are long gone. Travel pattern are too diverse. Post busses have long served in Europe to provide for the elderly or infirm and could operate here. Reducing the need to travel can be assisted by improving the PRoW network not actively allowing it to disintegrate and fall into disuse as is happening now. Maintain every footpath bridleway and BOAT. Make sure parish and town councils get rates per length maintained which make it attractive to improve them. How many are wheelchair usable for instance? And, importantly, expand the rural gas network!!! Gas does not have to be a fossil fuel it can be biogas derived from sewage and other putrescible waste and is already significantly cheaper per BTU than other fuels. Just put conditions on planning consents that any site of ten dwellings or more must have mains gas network access which will bring gas to many villages deprived of it by the current system


whereby potential customers have to gift the capital cost to the gas companies and then pay prices which give them profits on the investment (the water people have the same game plan) which is grossly inequitable."

364 "AG1 to 4 AG1 We should not be building on good farm land, we need food to be produced in this country and not waste money bringing it in from farms that are run by unpaid slaves in the EU. AG2 Farmers need to be living on the land that they are farming. BUT this property should by law not be permitted to then be sold as any type of second or so called holiday home. AG3 Small Anaerobic digesters should be encouraged, for farm waste, but, not be permitted to use crops that are grown miles away from the AD unit. This is unnecessary road travel for no actual purpose. AG4 This looking at getting new towns again. Not good. "

367 I believe these Policies cover important issues and principles. Members of the Public would like I believe to see clearly the chain of accountability, monitoring and responsibility for explaining how policies are monitored and put into practice

374 The criteria for OPD in Wales include the requirement that “65% of all subsistence, or 30% of food and 35% of livelihood, come from the land. How to measure and certify this?" “ecosystem links” are not defined Housing should be the subject of distinct policies not traded off against other criteria. 5. Policy AG2 Not supported and No. 6. Policy AG4 No – affordable housing does not satisfy the need (i.e, it’s not affordable) social housing should be the only criteria for exception sites. 8a Once more this should be part of housing policy. How will carbon sequestration be assessed?" Development in the open countryside should be incorporated into allowable and monitored development. Temporary homes should be subject to planning permission, timescale - local impact, etc.. I worry that AG2 will encourage a 'free-for-all' on otherwise protected land. AG4 - New premises should be accessible by public transport. FTTP should be encouraged.

029 AG1 - Yes to providing small numbers of housing within an whole estate. Carbon sequestration could be imposed through some metrics to be achieved by the development, but land management and biodiversity would seem more subjective. Ask the developer to state how he would achieve these as improvements and how that could be monitored? AG2 We would want to see that this policy was not applicable to designated land e.g. within an AONB. There is also the question of whether the houses would have to conform to building regulations and be checked for safety, and we assume they would be liable for Council Tax. We also see the protection against unnecessary development as being significantly more dependent on the effectiveness of a monitoring and management system than on the wording of the policy. This is a policy that could quickly become abused without strong controls. We are not confident that Cornwall Council would deliver the required level of management or have the funding for this. AG4 - Yes because we see more local employment and sustainable communities as just as important as affordable housing.


8a, Yes where these conform to the Local Plan and Neighbourhood Plan on development in the countryside. We assume that the housing itself would be subject to planning and building controls.

032 "14 Agriculture and Rural Development 14.1.2. In a policy document of this nature it is important for terms to be defined. This applies to “regenerative land management”. Regenerative land management is more of a philosophy or approach to farming than a practical, measurable system which is subject to verification, such as organic farming, or public understanding, such as Red Tractor Assurance, or RSPCA farm welfare assurance. Many of its threads, if not most, are naturally employed in traditional Cornish farming practices: the areas of mono-culture farming such as is seen in the cereal lands of East Anglia where soil degradation is a common problem are more needing of its philosophy. That is not to say that all Cornish agricultural practices are compatible with maintaining soil health, and encouraging carbon sequestration through photosynthesis: for example, deep ploughing for potato growing, and research suggests that carbon is not sequestered by the original plant growth in maize (www.agcanada.com/2020/07/looking-for-carbon-sequestration-answers), nor has there been conclusive research for miscanthus. But there is little evidence to support the concept of “regenerative land management” through the planning system unless and until its methodology is both defined, proven, and capable of measurement/verification. “Integrated farm management” is a much more specific term and has, in LEAF (Linking the Environment and Farming), an established audit protocol, a recognisable certification logo, and its founder and CEO, Caroline Drummond MBE, lives and farms in Cornwall. In addition, does “agricultural diversification” have the same meaning as “farm diversification”? The latter term is universally known to mean creating income streams to the farm from activities other than agriculture: for example, holiday accommodation, farm shop, food production. From the examples of “agricultural diversification” it seems as though environmental projects are in mind – for which there would be no income stream. It seems strange for this to be highlighted in a planning document. The highlighting of “reestablishment of hedge lines” is similarly strange. A report from the Cornwall Wildlife Trust in 2019 raised concerns that the Cornish Hedge is being lost, but due to the construction of housing estates and industrial development: that is, these loses are at the door of the planning officer rather than the farmer and cannot be “re-established”. At a cost of over £100 per metre any move to see old hedge lines reinstated would, in any event, be economically and environmentally unsound. 14.1.13. Comment on “one planet development” is given further on. 14 2. Policy Context It is frustrating and disrespectful that this policy document fails to make any positive reference to the forms of farming and food production which are being carried out in the county at present. The context is all about the need for change and growth. For the sake of the environment, that is probably exactly what we don’t need. In most cases, the best decision is to preserve and conserve what we have. Change and growth in agriculture and land use is fundamentally brought about by the increase in population and urban growth which demands more and cheaper food and drink. Most in farming would like to take their foot off the pedal – but this does not seem to be a policy aspiration. The massive contribution that agriculture plays in food security, environmental conservation, and Cornwall’s economic wellbeing deserves recognition. As it is, this seems to count for little in the face of what one distinguished Cornish farmer and environmentalist terms “hippy dippy” ideas." Policy AG1 - Please define a “large farm” and an “estate”. They have no meaning in Planning law as far as we are aware.


14.4.3. says the Whole Estate Plan “consists of a plan prepared by individual land-owning estates that may justify exceptions to usual planning policy”. Proposed Policy AG1 seems to go further than this. We wish to know whether a Whole Estate Plan is needed to back up all planning applications or just those which are exceptions to usual planning policy. Further, will they be required for approval to Permitted Development Rights for farms and farm buildings? Any business or management plan, even Cornwall Council’s, is subject to change according to changing circumstances. It is not set in stone nor does it have a fixed term life. What happens if the “approved” Whole Estate Plan needs to be changed: does change require approval? What happens if a delay in change causes serious financial or environmental losses? Is Cornwall Council seeking to restrict or interfere with the estate or farm management function? Is this not outside the true planning remit? What costs are involved? Is a Binding Estate/Farm Plan a restraint on trade? Investment and government support of R&D in agriculture technological advancement could be counter-productive with the imposition of a new level of bureaucratic control. Is the planning authority setting itself up for a large number of Appeals? If an estate or farm is spread over a wide area with many plots of land or farms do they all need to be included in the Whole Estate Plan: for example, an estate could encompass three farms each 10 miles distant from the other. If a building is needed on Farm A, would a Plan be required for B and C also? And, if so, what is the justification in PLANNING terms? Will these Plans be open to public inspection? Inevitably, they will contain commercially sensitive information. How will the Plans be monitored? Will they be enforced? Policy AG3 14.7.1. It is wrong to discuss emissions without considering net emissions (that is, less sequestration and offsetting). Cornwall Council’s quoted range of agricultural GROSS emissions is from 18 – 20%. In the context of seeking carbon neutrality the understanding and measurement of net emissions versus gross emissions is essential to any rational policy. The Duchy College Farm Carbon Calculator programme takes this fully into account. In addition, the new methane metric developed by Oxford University and now applied by most, if not all, academic scientists including Duchy College and Plymouth University, has discarded CO2e in favour of GWP* (Global Warming Potential which takes into account the short life of methane versus CO2 and N2O). This will generally halve or more the agricultural emissions figure for a farm with livestock. It is absolutely essential that policies are rooted in best scientific applications and measurements continually monitored. The more inaccurate we are the less likely we will know if and when carbon neutrality is achieved. By basing policies on net emissions a true picture will emerge and there will be a shift in the relative responsibility for greenhouse gases. This may disturb the political narrative. It is difficult to comprehend the PLANNING need for a “binding farm plan” when it comes to seeking planning permission for renewable energy proposals. Addendum to Rural Matters There is increasing evidence of farmland and open countryside being “lost” to “horsey culture”, allotments, small “Good Life” parcels of an acre or two, storage containers and old vans being used for storage and other activities whose environmental and biodiversity effects, carbon emissions and travel generation are unknown/unrecorded. Most of these activities are outside planning control or deemed not sufficiently “harmful” to warrant enforcement action. 14.8 Rural service development 14.8.1. Cornwall has a largely dispersed population at 55% rural and 45% urban at last count but new development is taking this rapidly to a 50:50 split. The core policies of the Local Plan are founded in strengthening the economic and social role of the major towns.


In addition, the generation of out-of-town retail and industrial/retail parks sited for easy access with free parking have both been prime movers in undermining village/rural life and services with most villages now taking on a dormitory function for the towns. To change this, a radical shift in planning policy is required. The effects of Covid on retail and working patterns have been profound but may be short-lived. The government and Cornwall Council are pumping large sums of money into town centres to return them to their pre-Covid position. Efforts to see such funding diverted into the villages has received very limited success. Whilst we may be cheering the prospect of an uplift in the economy of the village such as is described here, does it form a radical departure from the Local Plan and if so, does this part of the DPD have conformity? What is the evidence base for developing policy which assumes increased working from home? Cornwall has a long tradition of self-employment but that often requires travel away from the base. In this context, to what extent will that pattern of work persist and develop and to what level (numbers) is it realistically anticipated that people such as office workers will now work (entirely or substantially) from home? What supports, other than broadband, are they likely to require within their immediate community to deliver the emission savings desired? Can the planning system help provide those supports? Rather than instinctively embrace on-line shopping, has any modelling be done on the medium – long term effect of the gains and losses from on-line shopping on the environment, towns and villages? In particular, “sourcing local” as an environmental/climate change goal? AG4 - Policy AG4 – Rural Service Development This policy seems generally OK if the preamble is tidied up. The preamble/justification is important because it will often be referred to in planning applications and appeals. Not least by the Inspector. Is the policy confident in ensuring local employment (how “local” is local?) and reduced travel? Co-housing should either meet the needs of local employment, local disabled or elderly people and their supporting families or carers.

378 "Answer 1.Developments within policies AG 1-4 should be implemented only with the support of the local community. The scope within each civil parish for these policies to be implemented should form part of the relevant Neighbourhood Plans so the local community is fully involved in decision-making. NPs will need updating in the light of these and other policies being developed nationally and within Cornwall. 2.See answer to 1 above 3.As the proposed Estate Management Plans are intended to be of benefit of the local community, they should be implemented only with local community support. As above, general principles concerning Estate Management Plans should outlined in updated Neighbourhood Plans. 4.The definition of a Rural Exception site should continue to determine where affordable housing development takes place. This policy should not result in extending the definition just because delivery of public goods is involved. All affordable housing developments should be required to deliver the public goods referred to in the policy. 5. It does not provide sufficient safeguard against unnecessary development in the countryside. See response to question 4 above. 6. Yes, but only within the context of our response to questions 4 and 5 above. Whatever affordable housing is developed should be in response to well-evidenced local need for affordable housing.


7. The need for and the location of such developments should form part of updated Neighbourhood Plans. It is vital that the local community is fully involved in and supports such developments in its area. 8a. Yes, providing the present definition of Rural Exception sites is retained and there is well-evidenced local need. 8b. Yes, as response to 8a above."

7. Proposed Policies Town Centre Development Principles

Policy TC1 - Town Centre Development Principles Policy TC2 – Place Shaping Vision and Priorities, including Town and Town Centre Renewal

Priorities

Policy TC3 - Diversification of Uses in Town Centres Policy TC4 – Density of Development in Town Centres


1.Do Policies TC1 – 4 pick up the right issues for rural areas – is there anything more that you would add? 2.Are the policy approaches that we are suggesting in policies TC1 – 4 about right – is there anything missing? 3.Do you have specific comments to make about the content or intentions of policies TC1 – 4?

URN Comments

352 1. Unique conditions of traditional mining and fishing villages need to be addressed. Offices into homes are a worrying development, potentially generating unsatisfactory accommodation and conflict with other policy requirements for new housing. References should be added – e.g., to town centre topic paper; Grimsey and Portas Reviews. 2. Perhaps there should be an equivalent to SC1? Many pundits argue for town centres to offer ‘experiences’ and events. Whilst laudable, these suggestions may prove disruptive to residential aspirations. There have been various ‘town centre review’ exercises include by Cornwall Council to which reference should be made and a consultation organised." 3. Hostage to fortune?

355 1. The policy focuses on towns not rural areas, but it does pick up the right issues for towns. Important that cycling and walking is not just promoted but facilitated by better infrastructure and enforcement of traffic rules for cars (so avoid cars parking on pavements/cycle lanes blocking pedestrians and cyclist from using the infrastructure safely).


358 1.2.3. Considerations to prioritising youth, family, senior citizens activities. No increase in alcohol selling premises. Activities/premises which cause anti-social behaviour, lawlessness should be discouraged.

360 1. TC1. Town centres seem to be being neglected and major retail sites out of town encouraged. If people are to visit town centres parking is a major barrier as the price to park is high. Yet out of town no charges. Town centre shops, I believe, pay more in rates yet with the development or retail parks these shops are being used less. A level playing field so that they can compete should be used. TC2. 1. To save all empty shops being used by charities there could be a scheme that will support new ventures, for a limited time, to help regenerate town centres. 5. Many sole traders don't need a full shop couldn't small ""hubs"" be developed that could be rented out to small businesses there by encouraging growth. This would give the chance to some start up schemes. TC3. Good access to town centres by reasonably priced public transport and reasonably priced short stay car parks would also seem to support any development. People must feel safe in these areas. In some town centres you could feel intimidated by badly managed street traders or people begging. This should be better controlled. TC3. New development in and around town centres using empty or un used buildings should be encouraged. This alone will not generate growth. People must feel that the town centres are a clean and safe place to go to. Businesses that can show they have what the public want in the way a services and supplies should be supported. Local residents should be allowed, by way of surveys, to show what they want from the town centres.

363 1. TC1 to 4 Town centres should be encouraged. At this time they are being priced out by having to pay too much rent and council tax. Tax the out of town centres which are owned by a gang of crooks. Buying on line is a phase which will pass. As people like to see the products that they are putting their money into. You wish to have less cars on the roads but at the same time encourage out of town shopping centres. Cars do not have to pay to park in these. This has to be wrong. But they have to pay a heavy price to park in a town car park. TC4 High density, property built of plastic is very dangerous. Whole areas will be burned down in minutes. I can not see how the insurance industry is allowing it.

367 1. I believe these Policies cover important issues and principles. Members of the Public would like I believe to see clearly the chain of accountability, monitoring and responsibility for explaining how policies are monitored and put into practice

363 20 Para 15 1 2 and Policy TC1 There are also a lot of other settlements of varying size which if you look back all came into being because there was economic activity there of some kind usually driven by natural resources. Look at Mousehole, St Day, St Agnes, and so on. Towns are not the be and end all of everything! Why have town centre first policy? It is just politicians looking at the concentration of votes easily gathered in. Fallacy, provision of a range of dwellings on under used or redundant space. This supplying where no demand is shown to exist. Economic folly of the worst political kind. Complement the local character? You must be joking


looking at most of the terrible units already inflicted on Camborne, St Agnes, Truro and other settlements. 21 Policy TC2 Sustainable spaces. Sustainable in what sense of the word? Economically? Socially? It is difficult not to conceive these places as warehouses for people of limited economic means so that better housing and places are freed up for those with more economic clout to enjoy? 22 Policy TC3 How much of this will ever materialize? IN the current environment with covid here and Brexit due on 1 1 21 the economic wasteland is surely going to expand. How long before British people are looking for work in Ukraine or Poland harvesting apples or digging ditches? 23 Pre submission question; Do TC 1 to 4 pick up on the right issues for rural areas. I assume this is a typo and should say urban areas as the policies are about urban areas, town centres. Most town centres are being destroyed willfully by planners encouraging out of town shopping which, largely because you can park at such places easily, find favour. No car parking charges and lots of space gobbling up green fields to park cars. Perhaps we should plough up main streets and plant crops there? If you want to revitalise town centres make them car friendly so people can park within easy walking distance of shops. No the answer is not out of town park and ride schemes, the fields are being gobbled up and the inconvenience and cost of bus journeys in and out of town added on top carting your shopping. We are not all bionic enough to do that at all regularly and, like government with excise duty and the tax on drinks and cigarettes, councils are addicted to car parking revenue to make up the grants which HMG no longer make (just like hospitals, what a disgrace that is! And I would not think of voting UKIP! Or Tory for that matter)

374 1. Unique conditions of traditional mining and fishing villages need to be addressed. Offices into homes are a worrying development, potentially generating unsatisfactory accommodation and conflict with other policy requirements for new housing. References should be added – e.g., to town centre topic paper; Grimsey and Portas Reviews. 2. Perhaps there should be an equivalent to SC1? Many pundits argue for town centres to offer ‘experiences’ and events. Whilst laudable, these suggestions may prove disruptive to residential aspirations. There have been various ‘town centre review’ exercises include by Cornwall Council to which reference should be made and a consultation organised." 3. Hostage to fortune?

029 3. TC 1 third paragraph needs rewording. As written it does not make sense.

032 1. Are the “Place Shaping Vision and Priorities” on which the Local Plan is founded still relevant or desirable in the context of the DPD’s argument? Which begs the question: what discussions are being mooted now as the Local Plan is under review and will, in particular, areas with an NDP be included in those discussions?" 2. For town centres to work they need certain fundamentals which do not seem to be mentioned or addressed. Car parking: there has to be sufficient car parking to compete with that provided (free) in out-of-town retail and service centres. Free parking is an obvious solution: even if only for short-term parking. Car parking could be free to electric or hybrid


vehicles. Public cycle racks are a must – particularly for electric cycles which are very valuable. All public car parks could have charge points for electric cars. Non-retail Businesses: office use should be prevalent in all town centres (it needs to be accepted that working from home may end up being less popular in the medium term). This keeps the centre active during the day. Diversification: The necessity for travel will be reduced, and the share of business increased, if all towns aim for diversity in what they offer rather than plan to specialisms which may be constraining their appeal or simply be outmoded. There is a potential divergence from the aims of the Local Plan here. 3. This Policy is well supported. 4. Again, this looks good. A question though: will Cornwall Council consider the use of compulsory purchase to generate town centre development (including residential) where buildings have been left empty for long periods and show signs of disrepair which blight neighbouring businesses?

378 1. Great care needs to be taken if the intention to both increase town centre density and retain/increase the green-space area. Experience in high-density development in cities showed that communal green spaces shared by high-rise blocks became blighted. It was found to be much more conducive to health and well-being for each house to have its own garden. Population density similar to that obtained with the combination high-rise and communal spaces was achieved. 2. If retail premises are vacated, every effort needs to be made to provide for alternative retail or community use before allowing them to be converted to residential use. It is essential to the viability of town centres that car parking spaces are provided for the number of cars likely to be used by occupiers of premises converted to residential use. The lack of parking facilities can effectively destroy town-centre businesses as potential customers are unable to park and patronise these businesses.

053 We welcome under Policy TC2 for 'improved public realm through green infrastructure provision, including street trees, pocket parks 8nd biodiverse public spaces.' We urge Cornwall to consider how to best identify and support urban nature recovery networks.

383 1. Policy TC1 Town Centre Development Principles I note and welcome the references to ensuring development will be designed to provide safety and security. The security of cycles is essential but they must be easily accessible to encourage use (follow the principles as outlined in Building for a Healthy Life – Homes England July 2020). Pedestrian routes must be well lit (where appropriate) with wide paths to encourage social-distancing, taking a direct route to where people want to go avoiding the creation of unwanted desire lines 2. Policy TC2 Place Shaping Vision and Priorities, including Town and Town Centre Renewal Priorities


Again note and support the reference to community safety, security and secure cycle parking and storage. It states in bullet points ‘support community safety or security’ but surely this should be ‘and’ not ‘or’? This is essential in all new developments as there is a great opportunity to reduce carbon by reducing crime by following SBD principles. Cycle parking must be secure to encourage use. Consider overlooking, CCTV coverage and located in places where people want to use it. For physical security should reference SBD cycle secure stand options (see www.securedbydesign.com for detailed guidance)" 3. Policy TC3 - Diversification of Uses in Town Centres Again note and support the references to security and safety under in 2 (f) Very important point is made within point 5 “ ensuring that residential amenity is provided for, ensuring that they do not lead to conflict with existing permitted uses or premises in the area” Having residential homes alongside in particular premises concerned for example in the night time economy must obviously be carefully considered. Such premises are always likely to generate greater incidents of noise, anti- social behaviour and crime especially later at night. The needs of both residents who may be affected but also those who may be lawfully using or running such businesses must be fully considered as identified in point 15.7.4 on page 40

034 Are the “Place Shaping Vision and Priorities” on which the Local Plan is founded still relevant or desirable in the context of the DPD’s argument?

348 1. Vistry Group agree with the proposed TC1-4 and that they address all the key issues. 2. The policy is comprehensive.

122 The only towns within the area of our concern are Camelford, Padstow and Wade bridge. Our concern is if development of any of these towns affected the hinterland, particularly the AONB. We have no comment on this section. The development of towns themselves is outside the remit of the Society.

388 1. This is an opportunity to add policy supporting the ‘transitioning’ of families/individuals between towns and their rural hinterlands. Looking at the demographic profiles around Helston and PZ for example we have many older couples/individuals who at the moment live in large houses and gardens who ‘should’ be planning a move into a locality with closer support. Is there an innovative way of encouraging greater fluidity of younger families moving out into the adjacent villages and becoming more ‘food self-sufficient’ and the older generation moving into town in accommodation that retains some of the benefits of, or links with, rural life – shared gardens/allotments – without the towns becoming old peoples’ homes.

389 The DPD should be clear if it means ‘rural areas’ or towns. The DEFRA definition is that anything settlement with above 10,000 population is ‘urban’ but this is not really reflective of the actual situation in Cornwall. Change in town centres needs to be facilitated by tax breaks. Again, without devolution to Cornwall (the power to set and vary business taxation) then business


rates (which directly support Cornwall Council services) will accelerate as a drain to business and town centre viability. Again (TC2) the ‘decision making framework’ is about devolution, it also requires inclusivity to ensure that this is not just down to business leaders or other influential figures

393 1.The policies do cover the right issues for town centres. However, if more people are going to be living and thriving in towns it is imperative that cars are restricted (except disability). At present I feel towns are places for cars to live not people. 2.They are about right 5. We feel we should be looking forward and planning towards a future with far fewer private cars. Any private cars should be parked outside of town centres and linked to the centre with public transport, walk and cycle ways. This will lead in eventually with the take-up of autonomous electric vehicles (taxis and buses) in the not too distant future.

394 3. All Members felt that the introduction of high quality housing in town centres should be encouraged. Some Members felt that there needed to be a limit on housing for people with complex needs to ensure that community safety and security can be maintained which are essential to the continued sustainability of town centres. Some Members felt that this was not a matter for the Climate Emergency DPD but should be dealt with in other planning documents.

395 Needs to be reassessed after the full effects are known of Covid-19.

192 1. Policies TC1-4 are focused on urban areas exclusively, so this seems a really odd way to pose the question. There is very little on public transport, and apart from bringing community services right into town centres, and a brief mention of markets, virtually nothing on how to encourage rural residents to visit town centres. 2. Since walking is at the top of the sustainable transport hierarchy, we would expect to see pedestrianisation featured in this section. Similarly, there is no mention of charging points for EV’s in this section. Although there is provision to convert unused commercial units to housing, there doesn't seem to be any explicit recognition that the opposite may need to happen at times (such as to help with a long-term plan of pedestrianisation)." 3. We hope that a good editor will be asked to look at this section. The wording of the policies is obscure and in places meaningless. They need to be rendered in plain English, avoiding phrases that may have an established meaning in the world of planning, but are incomprehensible to anyone else. e.g. ‘meanwhile use’. There are also references to external guides and policies without any links; this adds to the difficulty of evaluating anything. Here are some specific observations: 15.1.1: We would suggest that this section would be supported by precluding proposals for out of town retail developments. 15.2.4: Why does increasing economic activity reduce the need to use cars? Is there a basis for this claim? More housing in town centres enables a night-time


economy? Doesn't this depend on where you put the housing? Very few people want to live near a busy pub. 15.2.5: What are “place visions”, “towns role characteristics”? This needs to be rendered in plain English. 15.4.1 and TC1. An explanation of ‘meanwhile uses’ would avoid having to look up a planning glossary. TC2 section 5. Poorly written again. “Create diversity” supports “diversity of offer”? “Supporting distinctive clusters of uses” supports “supporting transport”? What kind of transport are you trying to support? All transport? Private vehicles? Diesel cars? HGV's? How do “distinctive clusters” support “health and wellbeing”? We feel you should show some evidence for this, or at least provide a chain of thought. This just reads like unconnected words. “Pocket parks” appears to be another planning-specific term that needs explanation. TC3 seems to simply replicate and expand on section 5 of TC2, regarding clusters. 15.7.4: The first ""form"" should read ""from"". 15.7.5: What is the “green points system”? It would clarify your meaning if there were a pointer to the TCPA page on the subject: https://www.tcpa.org.uk/the-green-space-factor-and-the-green-points-system TC4: We cannot find a reference to the “Cornwall Green points calculator” anywhere. Does such a thing actually exist?"

297 The third para in this policy refers to a ‘green points calculator’. Further information on the green calculator is sought. Will this be prepared as evidence to support the plan or a supporting supplementary planning document?

397 1. About right. We do need to keep our existing town centres and accept that diversity is key but living accommodation and town centre type businesses can go hand in hand. The bigger the footfall, the less the crime

253 "TC1-4 Qs1-3 These include the right principles and we would like to see these applied and extended further in town centres with appropriate innovation. For example: TC1 – 4 lists principles that aim to deliver more sustainable streets by making it easier and more attractive to walk or cycle. Some items may not be specifically the remit of planning but an integrated and coherent approach is essential. •This requires a change in mindset between towns being designed around the car and towns designed around residents This audit should include recommendations for maintaining a clean and welcoming environment •Greening of town centres needs to specify as compulsory street trees, parks, etc in addition to the private green space recommendations •To allow easier reduction of speed limits, This both saves fuel (and carbon) and is a good safety measure on many roads •Repurposing of parking bays for secure cycle racks •Changes to junctions to prioritise cyclists •All parking areas, whether private or council maintained should be constructed with a permeable surface to aid drainage and thus prevent flooding • support of electrification is essential for carbon reduction but also, and possibly most importantly, to reduce air pollution


Covid-19 has demonstrated that it is possible to significantly change the emphasis in urban areas between the car and the pedestrian. Specifically to close streets, widen pavements, increase pedestrian areas and cycle lanes. This process needs to be extended, starting with a pedestrian/cycling audit in both existing and new developments. Any policy to extend pedestrianisation needs to take into account the specific requirements of disabled, young families, the elderly etc for easy access. TC2 lists principles that aim, amongst other things, aim to create strong, lifetime neighbourhoods, enhance the vitality of the town, include the development of high-quality housing for a variety of residents, create diversity in town centres, and support a sense of place and local identity. Specifically this could include: • Setting a base line for all new town centre development in line with renewable principles: • e.g. solar panels on all roofs, buildings designed/redesigned for solar gain, utilising heat generated in public areas, promoting local district heating systems - air/ground source. • Expanding the policy of retrofitting homes to improve energy efficiency • Favourable planning decisions and council support for small enterprises that bring distinctiveness to a town, making it a specific destination for certain services and products. • re-purposing of buildings for the above • flexible planning decisions for short term art/theatre/music installations TC3 refers to the delivery of higher density development in town centres. • This must be appropriate. Higher density development may work in city centres where there is a young, working population happy with apartment living but most Cornish towns are lower level and with a distinctive character of their own which needs to be preserved and enhanced. Any development must respect this. • Limiting development to one or two storeys above shops where access to green space at the back of the building is available is preferable. • Development must take in to account the green infrastructure recommendations to reference, reflect and enhance the local environment and promote health, wellbeing, community cohesion and active living. • Offsetting as a policy may actively mitigate against achieving this in urban areas. • The document currently states that street trees and greening should be integrated into street design ‘wherever possible’. This final phrase again mitigates against achieving this. • ‘High density’ must not sacrifice green spaces within the developments. Existing planting, trees, etc must be retained and added to with atriums, green courtyards, green walls, green roofs on bus stops, cycle stores etc for biodiversity gain, carbon capture, urban cooling and improved air quality. • Interacting with nature also has significant benefits for mental health and well-being


• Minimisation of waste - This also requires a mindset change from ‘waste’ to ‘by-product.’ All developments should be required to include full recycling support, including the recycling of water. "

064 3. Provision should also be made for local renewable energy developments to support the principle and objectives of the policies including the opportunity of developing local geothermal projects in close proximity to market areas (large heat users or district heating networks) to minimise disruption from the construction of associated supply infrastructure areas. Geothermal energy production has a small land footprint and has a low visual impact or can be easily landscaped and screened. Given the geology of the area, production sites can be sited close to energy users or in close proximity to existing infrastructure such as district heating networks.

404 LiveWest supports any approach which seeks to create sustainable, attractive and well-functioning mixed-use centres that have existing public transport infrastructure already in place and have active travel opportunities. This mitigates car use and makes transport unnecessary in terms of the car and/or provides more users of public transport thus making it more viable and regular. Housing mix should respond to the local market and local need and we would encourage student accommodation to be targeted where it is most required and not alongside other forms of housing where this may create conflict.

163 As used elsewhere throughout the document, I think there should be a hierarchy of preferred uses in town centres – business use first, then community use, and then finally residential. I am concerned about the focus on use changes in this section. I live in Penryn and to see the further reduction of any shopping area would not be beneficial to the environment as it would drive people to travel to Falmouth. Businesses and community services should be encouraged in the place where they are needed so that people don’t have to travel further. I think there should be support for local councils to produce place shaping visions. Town and Parish Councillors are volunteers and may lack the training, knowledge and a diversity of experience. There should be specific support and a framework ideally to support the development of local place shaping visions. Where appropriate developments should contribute to the planting of street trees and the creation of pocket parks.” – Any pocket parks should be well-connected by other vegetated access routes. "

280 Policies TC1, TC2, TC3 and TC4 - approve of all There should be a moratorium on out of town retail.

109 The protection and policy requirements already afforded to designated landscapes must not be diminished by this.

407 1. We need to ensure that we are not creating “wealth ghetos” as only the wealthy can afford the types of developments potential created by these policies. 2. There should be a policy that prevents higher density policies resulting in substandard domestic accomodation.

329 1. I would prioritise the focus on green spaces and ensuring there is a commitment to forest gardens, orchards, community growing spaces and spaces where nature based projects can be delivered such as Forest School, Nature connection for health and wellbeing, etc for the benefit of the local community


276 2. Will turning retail units into housing in the centre of towns create an adverse effect?. Obviously these empty places need to be used and I agree there is a lot of office space etc above these shops that can and should be redeveloped, but if at street level these shop fronts are changed to residential it will be hard to ever claim them back as retail units in the future. We need to think about how to help our towns become bustling with people again. We need to invite adaptable business into the towns. Prehaps look at new types of business rather than usual shopping. Electric bike shops or ‘How to live off grid’ initiatives. More community based hubs need to spring up. These could be information centres paid for by eco business and supported by the council? Storage for electric bikes is imperative. My electric bike cost more than my car did. There needs to be secure lock ups for people to feel comfortable riding, parking, and shopping. Regarding Policy TC3 can you put the community institutions such as schools, clinics etc (mentioned in point 4) into the larger retail units that you highlight in point 3?"

413 2. changing from commercial to residential will increase the requirement for off-street parking. 3. CTC regrets the loss of the protection for retail & commercial sites, conditions of

marketing for 1 year before change to housing. The greater the density of housing; the more social conflict occurs.

264 1. Cornwall CLT welcomes and supports the proposals 3. While the intensification of development in Towns is understood, the policies need to recognise the pressure on existing open spaces within Towns. We should not see informal spaces being lost to cope with parking issues.

095 This is a good plan. We have made specific comments for cohousing in existing country buildings. There should be similar policies for new-build cohousing communities in brownfield sites in towns, and for the development of abandoned building in towns for co-housing.


416 3. In respect of the Town Centre Design and density, HTC supports the ethos and proposed parameters of the four proposed policy areas • TC1 Town Centre Development • TC2 Place Shaping Vision and Priorities, including Town and Town Centre Renewal Priorities • TC3 Diversification of Uses in Town Centres • TC4 Density of Development in Towns • TC1 Supporting the diversification of town centres (TCs) particularly with underused properties. HTC will support the a for change of use but would like more detail as to the interpretation of ‘when it is comparable with other uses and enhances the vitality’. Where retail demand no longer exists then alternative use will be supported. HTC would like more clarity on the interpretation of ‘high quality living environments’. • TC2 HTC are actively supporting community focused locally led place shaping visions and priorities in areas of the town at present. Included within the developing proposals is recognition of the need for sustainability through the use locally produced goods and services as well as valued community assets including


pubs and social facilities. HTC are actively supporting proposals that include access via walking, cycle and public transport whilst maintaining the distinctive view of the town centre. • TC3 HTC support this proposed diversification of uses of buildings and drive to increase the residential units available. • TC4 HTC support the approach of not reducing green space and increasing the opportunities for green space infrastructure.

417 The DPD’s approach to Town Centres, Design and Density is supported. The JLP Councils agree with the aim of introducing greater diversity in town centres, and emphasising the importance of community facilities in policy. A local town centre ‘Place Shaping Vision and Priorities’ document will provide a useful framework with which to consider proposals, and encourage engagement and ownership within the local community

3. Generally, in support of the plan. Specific comments about using existing country buildings for cohousing made earlier. There should be similar policies for new-build cohousing communities in brownfield sites in towns, and for the development of abandoned building in towns for co-housing. Also, Cornwall Council should move towards more stringent requirements for newbuild dwellings and other buildings, such as Passivhaus or at least the AECB Building Standard. A general policy of discouraging car usage wherever possible should be enated in all relevant specific policies."

019 1. Historic England welcomes much of the text in the Introduction. Brief reference could also be made in paragraph 15.1.2 to the additional challenges faced by towns and high streets in recovering from the impacts of COVID-19 as well as a summary of Redruth’s High Street Heritage Action Zone, which was recently launched. The Redruth HSHAZ brings together a series of regeneration schemes for historic buildings on and around the town’s historic Fore Street either associated with community use, arts and creative industries or residential conversion. It follows in the wake of the opening of Kresen Kernow, Cornwall’s new archive centre, and in advance of new development around the town. It will help to unlock the potential of Redruth’s heritage to invigorate the high street and improve Fore Street’s connection with the rest of Redruth’s historic core through a programme of public realm enhancements including from the station. There are also many heritage-led regeneration schemes in Cornwall’s towns, including Townscape Heritage Initiatives and Heritage Economic Regeneration Schemes. Further information can be found on Cornwall Council’s website. This should also be mentioned, as should the Council’s historic shopfronts and signage guidance. The Introduction and Policy Context should also reference the historic character and local distinctiveness of Cornwall’s historic town centres and high streets and relevant Local Plan and Neighbourhood Plan policies and related provisions. For example, in addition to individually designated heritage assets, such as listed buildings and scheduled monuments (see NHLE), most of Cornwall’s towns have conservation areas, which should be acknowledged, and many have conservation


area character appraisals and some also have management plans, which will contain relevant information and recommendations related to this section. There are also many non- designated heritage assets located within Cornwall’s town centres and high streets and further information can be found in the Cornwall and Scilly Historic Environment Record (HER). Policy TC1: In respect of Policy TC1, we welcome the general intent of this policy and in particular the requirement for developments to complement local character and cultural heritage, enhance host ‘historic buildings’ and the public realm, improve green infrastructure and open space, and bring underused and redundant space into use and maintain active ground floors. However, we consider this Policy needs to go further to positively encourage the retention, conservation and enhancement of designated and non-designated heritage assets in town centre development proposals and to. 2. In respect of Policy TC1, we welcome the general intent of this policy and in particular the requirement for developments to complement local character and cultural heritage, enhance host ‘historic buildings’ and the public realm, improve green infrastructure and open space, and bring underused and redundant space into use and maintain active ground floors. However, we consider this Policy needs to go further to positively encourage the retention, conservation and enhancement of designated and non-designated heritage assets in town centre development proposals and to encourage development that addresses heritage ‘at risk’. We would like to see amended policy wording that reflects this. 3. We support the intent of Policy TC2. However, we consider that definitions of ‘locally led Place Shaping Vision and Priorities’ and ‘locally produced town centre strategies’ are needed. For example, are these the same thing? Would they include existing town centres and high streets where there are adopted conservation area character appraisals and/or management plans with relevant recommended actions? Would it include any adopted masterplan, concept plans, development briefs and/or regeneration plans, etc.? What about ‘made’ Neighbourhood Plans and any specific policies and/or projects? If these are not captured by the definitions, what is the intended relationship between them and Policy TC2? While we support criterion 5) in its support for various matters related to the historic environment in town centres and high streets, it wording is a bit confusing. We query if criterion 5) should be confined to matters related to clusters of uses and the second half of the criterion becoming a new criterion. We also consider that this new criterion should include a new bullet point to encourage the conservation and enhancement of heritage assets and their settings in town centres and high streets and development that secures the future of underused and redundant historic buildings and heritage at risk. 4. Historic England supports the intent of Policy TC3, which could assist with the adaptive reuse of underused and redundant historic buildings, including heritage at risk. However, we are seeking the introduction of a new criterion that seeks the conservation and enhancement of heritage assets, including their settings in town centres and high streets and development that secures the future of underused


and redundant historic buildings and heritage at risk. An acceptable alternative would be to introduce appropriately worded new sub-criteria to criteria 2), 3), 4 and 5). 5. We note the intent of Policy TC4. However, we are seeking the introduction of new policy wording that encourages new residential development in town centres that conserves and enhances heritage assets, including their settings, and development that secures the future of underused and redundant historic buildings and heritage at risk. Finally, Policies TC1-TC4 include reference to the provision or enhancement of green infrastructure, including planting street trees, and/or urban greening. We advised in our previous comments on the Scoping Report that trees have never been a significant feature of Cornwall’s distinctive landscape or its historic settlements. We seek assurance that there will be careful consideration of the impacts on the character of Cornwall’s landscapes, seascapes and townscapes in respect of tree planting, which will need to be informed by appropriate research and historic environment/landscape character assessments.

041 1. TC1 Capacity of town centres in terms of waste disposal, sewage and power supply needs to be considered and improved alongside increased residential dwellings. TC1 Developments should demonstrate attempts to adapt current underused and redundant buildings or urbanised spaces before planning in natural or green spaces" 2. TC2 Item 4. Also need to consider waste management with more footfall in towns e.g. more bins in popular areas such as beaches as well as introduction of recycling bins in towns that currently don’t have them. Additional bin collections throughout busy periods (e.g. summer holidays). The council needs to more actively support community clean ups in local towns and villages. Greater education in schools about waste disposal – irresponsibly and responsibly so reuse, recycling and the circular economy are understood by the next generation. Town centres need plenty of accessible free parking to avoid large numbers of cars driving around the town searching for parking which hugely increases emissions and reduces air quality. TC3 Reduced council tax to encourage town centre regeneration. Making sure that empty shops in towns are filled before the creation of new buildings - e.g. Newquay. Supporting local businesses with rent, so that town shops can be filled to help town vitality, jobs and capability over off-season months.

8. Proposed Policies Sustainable Transport

Policy T1 – Sustainable Transport Policy T2 Parking Policy T3 - Safeguarding of Transport Infrastructure Sites and Routes



1. Do Policies T1 - 3 pick up the right issues for rural areas – is there anything more that you would add? 2. Are the policy approaches that we are suggesting in policies T1 - 3 about right – is there anything missing? 3.Do you have specific comments to make about the content or intentions of policies T1-3? 4. Should we develop a policy to encourage the provision of new distribution facilities at key locations where it can be shown that these would help to consolidate freight journeys, particularly those related to home deliveries of food or goods? 5.Should this specify certain typical locations or specific locations at key transport nodes or interchanges?

URN Comments

352 1. Introduction provides good review of issues but policy fails to address the identified conflicts. Please provide ref. for Cornwall & Isles of Scilly Local Industrial strategy 2. Density versus mobility - chicken and egg? Careful and progressive change is required. Guidelines needed. “residential development should be well-balanced in terms of tenure and range of size of unit, high quality and follow the principles set out in the Cornwall Design Guide” - permitted development rights will muddy the waters here. 3. 15.7.4 – conflicts are inevitable – see previous comment re TC1-4 (2).T2, Parking - Completely ignores the fundamental 'tourist' economy of Cornwall. A sustainable 'bring your car and leave it' policy should be encouraged. 4. Yes – but require architectural quality since such buildings are intrusive. 5. Yes – location is important not just for logistics but for countryside protection.

352 1. Yes transport connectivity is important, but greater reference to the current lack of this would be helpful. It is currently very difficult to travel in Cornwall without using a car – examples are many – no direct bus from Truro to the airport, the lack of fast bus connections between key towns in Cornwall making it an unsuitable mode for commuting to work (takes 1h 40 mins to take the bus from Truro to Newquay etc). The lack of ability to bring a bike on trains and busses is a huge hindrance for people to use public transport as a main means of transport for commuting (often the train/bus doesn’t take you to your final destination and walking is too slow). 4. Yes shopping online is only going to increase.

358 1. Yes. Nothing to add 2. No 3. No 4. Yes 5. Preference given to key transport nodes or interchanges

359 1. I fully support polices t1-3. However what is missing is mention of air travel. There should be a specific policy on this which may include limiting the number of flights per day coming over the magnificent Mawgan Porth Bay and disrupting surrounding areas of natural beauty (eg St Mawgan village), with both noise and fuel pollution. Investment should be in more green forms of transport into Cornwall – such as trains


3. I think that there should be transparency about conflict of interests eg interests of Cornwall council in Newquay airport as a point of conflict with its green policy. Schemes which create income for businesses but create highly problematic noise, sight and fuel pollution in rural areas and areas of significant and outstanding natural beauty should be discouraged – for example, using Newquay airport as a landing and taking off training site for large commercial airlines (such as easy jet and others).

360 1. T1. Although car free areas should be encouraged consideration must be given to elderly residence who may not have any other form of transport due to their home location. It will not always be possible to use public transport. Cycling in town centres also needs to be managed as some cyclist do seem to forget that their mode of transport doesn't generate any noise and the first time you are aware of them is when they are right on top of you. If cycling is to be encouraged a means of identifying cyclist must be implemented and educating them as to how they should behave is a must. It may also be argued that any means of transport, be it, eclectic scooter, cycle or electric car must contribute to the upkeep of services and rights of way as these need to be maintained. Public transport must be reasonably priced, regular, clean, must have local stops and people need to feel safe using them. T2.If parking/storage facilities are provided for cyclist will they be charged as the service has to be provided and who will pay? With new residential housing there is provision for two cars. Many people convert their garage to storage of other use and in time any children will also need parking. Can provision be made to prevent garage conversion prevented and must be used for a car. And additional parking for developing families as two places are seldom enough. T3.There are many old and unused railway tracks that could offer others uses. With local involvement this should be encouraged."

364 1. T2 I do not know if all the staff in this department live at the top of Truro. But, I assure you that for a family to do a large family shop on a bicycle is of no use what so ever. It would be impossible for a person to cycle six or more miles up and down hills to buy a large amount of shopping at an out of town shopping centre, and then have to cycle all the way home again. In Kernow one can not survive without a car. Most children from four onwards, live well beyond six miles from their schools they have to have transport to get them there. Most parents are both working today. Many of them can work twenty, or more miles away from where they live. There is no public transport for them.


363 1. 24 Policy T1. Government failed this at the starting post. Even when operated by the same company bus and rail timetables are not even vaguely connected, never mind through ticketed. See my comments above about rural public transport and the patterns of modern life. See also my comments about making railways capable of carrying lorries and busses channel tunnel style to get them off the roads as much as possible while retaining the flexibility of road connections. A roro link from Falmouth


to Ireland and to the continent is long overdue. Links with the Scillies are poor and tending towards monopsony. Whoever allowed the heliport at Penzance to be built on for a supermarket should be shot at dawn every day for a week at least. I have never seen or heard any justification for that decision at all. Perhaps the Scillies should secede and join the EU? Why is there no rail link between Camborne and Redruth? Huge money spent on not very good roads when a tramway of the modern kind could be profitable especially if as in some sensible urban centres, it was free at the point of use. In that vein the old gasworks line from Newham could easily run into Truro Back quay and link across to the railway station and the cattle dock. When will the St Agnes line be reinstated and linked through Perranporth to Chacewater and thus to Newquay? St Erth to St Ives works why not St Agnes Perranporth, Chacewater, Newquay? It would not be hard to reopen Scorrier station and use it to load the waste for the incinerator onto the railway, if you accept that an incinerator is necessary of course which is highly debatable. See my comments above about PRoW’s. Sort out the definitive map first on a parish by parish basis not piecemeal footpath by footpath which is expensive and time consuming. Make waymarking compulsory and any damage or theft of signage an offence. Make mileage rates reflect the capacity of the engine in reverse. Bigger engine, lower mileage rate so bikes get paid the highest rates. See usage rise. Count electric bikes and non electric the same. They use very little electric. Provide parking places and charging points at work places and shopping centres. Do not limit this to new developments, make it obligatory everywhere. 25 Policy T2 see my comments about parking under T1 above. Don’t forget to add places for drying coats etc at work places, colleges, schools, village halls etc. The elf and safety ruling that coats cannot be hung over a radiator still defies understanding. 26 Policy T3. Good idea. Think Camborne Redruth tramway and the Portreath branch line among others like Newham and Tresavean, St Agnes etc."

374 1. Introduction provides good review of issues but policy fails to address the identified conflicts. Please provide ref. for Cornwall & Isles of Scilly Local Industrial strategy 2.Density versus mobility - chicken and egg? Careful and progressive change is required. Guidelines needed. “residential development should be well-balanced in terms of tenure and range of size of unit, high quality and follow the principles set out in the Cornwall Design Guide” - permitted development rights will muddy the waters here. 3. 15.7.4 – conflicts are inevitable – see previous comment re TC1-4 (2). T2, Parking - Completely ignores the fundamental 'tourist' economy of Cornwall. A sustainable 'bring your car and leave it' policy should be encouraged. 4. Yes – but require architectural quality since such buildings are intrusive.

029 1. No 2. Yes, where new developments take place in small rural settlements/villages, providing the new levels of walking and cycling facilities within the development is of no help when the onward connection to town and retail sites from the settlement is along existing narrow rural roads with no provision for walking or cycling. 3. No 4. Yes


5. No. Best leave it to commercial interests to specify the locations.

032 6.1. Introduction It would be difficult to argue with the principles laid out here but in the short – medium term certain realities need to be addressed: People not only use cars for convenience but (sadly) many people have an emotional attachment to their car. Rather than decrease on-site parking spaces, why not increase them but prohibit any parking on-street? Estate roads could then, in theory, be narrower and/or have more curves to reduce speed. 1. There is no objection to this Policy, but it is very “urban” based – perhaps naturally. However, it would be difficult to translate much of this to the countryside. Perhaps this is not a planning matter, but it should be borne in mind that capital investments require provision for maintenance. In the case of off-road walking and cycling (particularly on the Mining Trails) maintenance has not been carried out sufficiently to encourage all-weather cycling and walking as an alternative to the car. Electric cars are also, at this point in time, rather like horses or Range Rovers – economy doesn’t really come into the equation. Experience also shows that where an on-site garage is provided this will often be used to expand living accommodation or for storage with the car being left outside. Are there ways of preventing this? 2. Surely it is better that people keep their cars within their boundaries and not on public land. So, two spaces per dwelling is ideal with no on-street parking. There are frequent instances of gardens being hard surfaced to provide additional car parking space. If this type of development was made subject to control, that could enforce maximum standards. 3. Safeguarding of transport infrastructure sites and routes This seems a good idea."

378 1. Cornwall Council needs to consider very carefully the environmental impact of increased electric vehicle use. Obtaining the minerals used in the batteries results in significant environmental degradation and habitat loss in those countries where they are mined. Before committing valuable resources to encouraging increase electrical vehicle use, Cornwall Council would be advised to research the feasibility of encouraging the use of green electricity generation to sequester carbon dioxide and combine it with hydrogen to produce liquid fuel. The technology is already developed to achieve this. At the same time Cornwall should aim to produce and distribute hydrogen to replace natural gas for heating. See also our response to RE 1-6 response 2. 2. See 1 above 3. The consultation is right in admitting that car parking will be needed for the foreseeable future. It is essential that adequate parking is provided for all residential development. 4. This would be useful if it can be clearly shown that there would be substantial benefit in reduced vehicle miles and emission levels of carbon dioxide and other pollutants. 5. We do not have the knowledge to answer this question adequately.

053 We welcome integration of GI and Sustainable Transport, e.g. at Policy T1 'incorporating high levels of green and blue infrastructure'. We urge that funding for GI is sought from highways schemes.


383 "Policy T1 – Sustainable Transport. Points 3 and 4 (page 45) are noted and supported. For point 3 cycle parking should meet SBD requirements and also those recommended in Building for a Healthy Life. For point 4 should also refer to Manual For streets and SBD guidance re residential parking It is important to re-iterate that permeable routes for walking and cycling should be designed so as not to undermine dwelling or other building security such as enclosed alleyways between units or other buildings. Such routes should seek to be along streets with active frontages and good natural surveillance. They MUST feel safe to use. This last point cannot be over emphasised. People will not use routes however convenient if they are not and do not feel safe. Shared routes are often best practice. Developers should seek advice from Police DOCO and refer to Manual For Streets. Limiting car parking spaces does not limit ownership. As we already see if people need a car they will own one and park it as close to their property as possible even if there is no ‘designed in’ spaces. Also need to consider those that use a vehicle for work i.e plumbers, gas engineers, painter/decorators. There is obviously currently less desire to use public transport due to Covid 19. The issue of lighting of such routes is one that I feel must also be addressed as this is often a principal reason why people will choose not to walk at night. There are conflicting ecological reasons against lighting but if the Council wishes to encourage safe walking/cycling when dark then places must be uniformly well lit as per BS 5489:2013."

385 1. Point 3 is noted. It is noted that parking is stated as should be provided mainly off plot. There are design points made under point 5. The current reality is that very many parking courts are still very poorly designed spaces in terms of natural surveillance, activity, lighting etc. There must be clear and effective guidance on the design of such spaces. If not then they will become problem spaces in themselves in terms of crime and disorder and residents will then not use them thus creating more parking pressures elsewhere and subsequently an untidy street scene. In relation to electric vehicle charging points. Where possible, charge points should be located where there will be passive surveillance from pedestrians, other road users and occupiers of nearby buildings. Charge points should be located adjacent to street lighting where possible and if there is CCTV then to be covered by this The physical security of each charge point must be robust, secure and user-friendly Necessary anti-skimming devices to be installed in each charge point, to ensure criminals cannot access the personal information of charge point users 2. Section 16. Sustainable Transport It is clearly a good plan to promote transport other than individual’s cars and reduce travel by car, this addresses emissions and the high energy cost of actually making and scrapping cars too. However, in very rural areas, such as Pendeen, this will not be the only viable option, certainly in the short to medium term. Cycling to work is not an option for many people because of distance, time, weather and safety. Bus services do not necessarily fit with different work patterns and timings. Electric cars will be a substantial way


forward for rural communities and make a significant contribution to reduction of greenhouse gases, this needs to be recognised and supported by the Council. 3. Policy T2. 6. Only addresses electric vehicle charging in new developments where there will be parking facilities; while being a step in the right direction this will have a limited effect on greenhouse gases. Rural communities need car charging facilities that anyone can use now. Charging facilities should be in accessible positions such as near shops, community centres, schools, in Council owned car parks etc. Many people live in homes where there is no off-street parking and visitors to the area need car charging facilities too. It would be properly supportive of the Council to aid local communities in establishing adequate car charging facilities, either through providing them, helping with costs and/or helping with expertise. It is noted that there is no mention in the DPD of how goods traffic can be encouraged to use railway provision where appropriate, does the Council have a view on this? 4.

034 1.It would be difficult to argue with the principles laid out here but in the short – medium term certain realities need to be addressed: People not only use cars for convenience but (sadly) many people have an emotional attachment to their car. Rather than decrease on-site parking spaces, why not increase them but prohibit any parking on-street? Experience also shows that where an on-site garage is provided this will often be used to expand living accommodation or for storage with the car being left outside. Are there ways of preventing this? 2. There is no objection to this Policy, other than to say that it is very “urban” based – perhaps naturally. But it would be difficult to translate much of this to the countryside. 3. Surely it is better that people keep their cars within their boundaries and not on public land which suggests two spaces per dwelling is ideal. This is particularly the case outside of the towns and/or where frequent public transport is not available.

348 1. Vistry Group support policies T1-3. 2. The policies are comprehensive 3. Vistry Group support the use of electric and hybrid vehicles via a national standardised approach implemented through the building regulations to ensure a consistent approach to future proofing the housing stock. In our experience, we have encountered challenges with network capacity. The policy would need to be aligned and supported by a comprehensive network upgrades to support the required infrastructure. In respect of T2.5, we would recommend rewording to reflect the individual charging requirements for different site contexts i.e. tenure, location, access and maintenance requirements and supply requirements e.g. standard 13 amp. In respect of T2.6, we feel that this requirement for off-plot parking is onerous and from our experience on larger developments across the country, can often lead to the use of parking courts which may not be the best design solution and can create management and maintenance issues as well as increased service charges. Homeowners of all tenures prefer to park their vehicle outside their own home. In addition, on-plot parking facilities is the most straight forward method to deliver


electric vehicle charging points, where the point can be wired into the supply for that property. This will reduce the estate management costs particularly important for the residents of affordable homes. We were also concerned that the provision of unassigned / visitor charging points would disproportionally raise the costs for residents particularly for the residents of affordable homes. 4. Although not core to our business, we believe this would be a sensible approach.

386 1. We are fully supportive of Policy T1 Sustainable Transport which states that all developments that generate significant amounts of transport movement should be supported by a Transport Statement or Transport Assessment, that gives details of proposed measures to improve access by public transport, walking, cycling etc, and to mitigate transport impacts in line with guidance set out in the National Planning Policy Framework and reflected in a Travel Plan where one is required. 2. Policy T3 refers to the safeguarding of strategic transport infrastructure sites and routes. Should this also include the safeguarding of land to mitigate for flooding or sea level rise impacts for example with regards to Hayle Causeway referenced above and the potential for a new junction on the SRN. In due course, we will need to understand further what any new junction proposal would look like, how it would be funded etc.

388 3. There should be a recognition that dedicated cycle ways are not always the most effective routes for commuting cyclists who speed along at 20+ mph but who need to feel safer along the main roads - A394 is a good example. 4. Yes 5. Yes

389 1. Physical transport infrastructure (trains and buses) need to be able to take more cycles in order to realise sustainable transport goals and mix modes. 2. TR1 dedicated and connected cycle links need to be established in order to help faciliate a modal shift. For example, the cycle route through Highertown, Truro is broken as it stops at the vets – even though people of course continue to cycle on the pavement for their own safety. Connectivity through Langarth will be welcome but there is also an opportunity to create a dedicated link down to Scorrier and therefore link Camborne and Redruth with Truro and make electric bike commuting feasible. 20mph speed limits need to be forced onto and designed into all rural roads to make cycling and walking safer. 3. Again, TR1 contradicts the previous policy aspiration of lower density development, Like recycling storage, storing bikes and chargers for possibly a whole family will take an amount of space unless there can be a secure and commununal area. Streets are not necessarily accessible for people with disabilities if some heritage features are retained. This needs to be looked at carefully in partnership with disabled people. Generally supported but in order to improve sustainable connectivity electric bikes need to be more afforable and available to faciliate commuting between towns and villages. If Covid or a variance is with us for years it could be that public transport use will not recover and bikes become a more viable non car choice. This will be require connected and segregated cycle routes and electric bikes will be essential for those


who could not cope with a conventional bike. Subsidy is needed to make them more affordable. Nothing is said about current residential parking policies. Resident parking charges have been imposed as a consequence of Firms failing to implement travel planning which (ironically with Covid) they are having to do now or because the cost of car parks were a deterent to commuters and shoppers using them. This is clearly not fair on residents having to pay a tax to park their cars, those without drives and those with larger families/numbers of cars who are unfairly penalised. There needs to be a much more imaginative and co-ordinated approach to parking and town and village regeneration. 4. Yes. It makes no sense that narrow streets in seaside towns (in particular) should have delivery vans and lorries trying to negotiate them in places such as St.Ives; where an extra couple of carriages and a distribuition venue at either end could get smaller amounts of goods in more regularly. Its also important to distribute produce around Cornwall and get off the A30 the tractors which have been engaged in accidents and cause polluting variable speed to other traffic. 5. Yes. The policy needs to develop in conjunction with the views of business.

393 1. Our vision of the future is that any remaining private vehicles will be parked/stored outside of town centres and when required will be linked by active travel or public transport, possibly autonomous. This, in itself, will be slightly inconvenient and is likely to encourage more people to adapt to public transport and even get rid of their cars. With more people living in the towns this would allow virtually car free streets that could become green spaces where people could socialise, relax and where children could play (no noise, no pollution). There is an opportunity where the private or autonomous vehicles are parked, to cover the area with PV panels. This would not only provide power, possibly for EV charging, but also shade the vehicles reducing the power required for their air conditioning (not an insignificant amount and an important factor as summers get hotter). The PV covering could also provide rainwater harvesting helping to reduce runoff from the car park. The inclusion of Vehicle to Grid & battery storage would help balance demand from the grid. This might not fall under the remit of planning and might be government led but the EU is introducing automatic speed limiters that detect and slow a vehicle to the speed limit and we were wondering whether there should be a policy to adopt this technology by Cornwall Council. 4. Yes, this is a good idea and could help local business if located at or near their premises. A reduced delivery cost would help take-up of the scheme. Can’t quite see how food could work with this system but definitely for other goods. 5. Yes, at key transport hubs as well as at local business. Plymouth has an InPost collection point outside the railway station.

395 1. All new builds must incorporate solar panels this could also help electric charging. Cornwall has a particular problem of thousands of small narrow roads where walking and cycling are very dangerous, vehicle numbers have significantly increased so unless field owners are willing to have tracks inside their roadside hedges walking and cycling will not increase by much at all. 2. As stated above locating large developments in the wrong locations will negate pollution targets both when building the houses and when they are built.


4. Yes this is important and the carry on transport to be all electric 5. I think these locations could be specific and linked with the railways

192 1. The transport hierarchy is quite rightly stated at the beginning. However, the policy layout does not reflect the hierarchy. The policy should mention pedestrianisation and walking (as that is the head of the hierarchy) Therefore point T1 no 5 should be at the start of the list. We feel this should also cross-reference town centre design. We believe these policies could be far more ambitious. By the time this plan is adopted and begins to have an effect on developments, it could easily be 2025. This leaves only ten years before the UK Government plans to phase out new fossil-fuelled vehicles completely, with an ambition to do this before 2035 if at all possible. How can the provision of charging points for only one in ten new parking spaces possibly be enough as little as ten years after the practical implementation of this DPD? Another example of the lack of long-term planning, is that the likely impact of sea level rise at places like Long Rock and Lelant Saltings goes without mention. Surely a transport policy must recognise the very real possibility that rail lines at Long Rock and Lelant (and the strategic A30) are under threat. What will be done to mitigate that threat and adapt to sea level rises? Existing railway beds are mentioned in T3, but it appears that the policy is to ‘leave them alone, just in case we decide to do anything with them’. Transport modes will not change until viable alternatives are provided. Since the roads from Helston to Redruth, or Camborne via Praze-an-Beeble, are unlikely to be widened to make them safer for cycles, should we not now be talking about re-establishing the branch line from Helston to Carnon Downs, even if as a cycle-way (preferably for electric cycles)? There are presumably other Beeching lines that could be brought back into use to widen transport alternatives. 2. These are broadly sensible policies, and it would be reassuring if we could believe that Cornwall Council would take them seriously. We make this statement thinking about the large new developments already approved by the Council, or likely to gain approval in the near future. These include developments beyond cycle and walking distance from their nearest town/city centre with no provision for local working, or scores of houses to be built in areas likely to be at risk from sea level rises. No mention is made of air transport. What about Newquay Airport? Surely it would be within Cornwall Council’s power to devise a way to at least ensure that people travel by train rather than air wherever possible. Furthermore, in the light of this document, perhaps the council should re-examine their decision to support the Newquay Spaceport. May we remind you once again: this is an emergency. Should not the council also be re-examining the connection to the Isles of Scilly and the re-introduction of the helicopter service with a thorough examination of the carbon impact of this service? 3. As with the previous section we hope that a good editor will be asked to look at Sustainable Transport. The wording of the policies is obscure and needs to be rendered in plain English, avoiding phrases that are incomprehensible to most people. The phrase “the biggest contributor being private vehicle trips” in 16.1.2 is untrue. The ONS statistics that the authors rely on, actually state the opposite. For household


travel in 2017, 22.16 million tons of oil equivalent (mtoe) were used (11.38 petrol, 10.78 diesel). For road transport it was 39.68 mtoe, almost double (12.76 petrol, 26.92 diesel). 16.1.4: What does “internationalisation of trips” mean? 16.2.3: What is an LCWIP? 16.4.3: This is a difficult paragraph to parse, but seems to be saying that important planning around transport will actually be in other documents? The phrase “physical provision of features necessary to enable a shift to more sustainable transport modes” is meaningless without an example. Policy T1 Point no 2 states: “Integrate with the existing settlement through inclusive, active travel networks ensuring easy and sustainable connections to community facilities and infrastructure and enabling connections to potential future travel modes;” Should the council not consider compulsory purchase of strips of land to ensure that active transport and nature corridors can be created? Policy T1 Point no 5 includes: “Deliver more sustainable streets by making it easier and more attractive to walk and cycle and considering access only streets to create green networks” It is unclear whether this is integrated with nature corridors, but we certainly feel it should be. What is the meaning of “Incorporating high levels of green and blue infrastructure”’? 4. Yes. Again there is a lack of vision and sense of time in the Council’s thinking. Goods vehicles are likely to be autonomous in the short to medium term, and our infrastructure will need to adjust. With the introduction of smart roads, it will be relatively easy to provide automated hubs with charging for goods vehicles in places adjacent to the A30 and A38, with smaller vehicles able to complete the final segment of deliveries on our challenging Cornish roads (or drones for smaller deliveries).

396 3.To ensure that permit parking charges are not introduced in urban or rural areas, as these penalise residents. Increased building of cycle lanes and clearer signage indicating correct usage should be prioritised. 4. Yes

226 1. Cornwall’s nature as a rural County makes the use of sustainable forms of transport extremely challenging. Attempting to design private cars out of schemes has failed in the past and there is no reason to assume that any such attempt would have a different outcome now. Parking provisions should be well designed taking in to account the aesthetic and functional considerations. 3. Policy T2 is self-conflicting. It seeks to require the application of a travel hierarchy as well as compliance with the Councils Parking Standards Guidance. The two methods conflict in their advice. The Parking Standards Guidance gives a more balanced and sensible approach to parking design and acknowledges that the design of each development will need to take account of the individual factors of each location. The hierarchy contained in T2 seeks to apply a blanket approach to all sites which simply does not work in a practical sense. The Council shouldn’t seek to duplicate


advice and should leave the application of parking standards to the guidance already in place. Attempting to remove cars from individual plots simply results in unneighbourly parking and conflict. Parking courts are rarely used to their capacity despite being well located and designed because people will naturally want to park close to their home, particularly when they have young children or in poor weather. The Council would serve their communities better by delivery standards that work for the end users rather than by seeking to apply a theoretical ideal. The existing parking Standards Guidance is more than adequate. There is no need to attempt to create conflicting advice.

266 1. In general, Policies T1 – 3 pick up the right issues for rural areas. 2. In general, the policy approaches are about right. 4. Yes in the case of goods, but no in the case of food. With regards to the latter, rather than encourage the provision of new distribution facilities at key locations the development of local sustainable community food production should be encouraged (see my comments in this regard in relation to Policies AG1, AG2 and AG4.)

397 1. Agree with WREN – more EV charging and introduce cycle repair stations 2. WREN consider that the ambitions of Policy T2 with regard to residential electric vehicle (EV) charging do not match the realities of anticipated near-future demand, or Government strategy on EV charging. We have concluded that residential charging demand is unlikely to be met if Policy T2 is not strengthened to include greater commitments for EV charging in residential parking spaces. We feel the policy, as it stands, will constrain the widespread uptake of electric vehicles in Cornwall. 3. T2.1.): WREN agrees with this hierarchy and in particular the priority of club cars over privately owned vehicles. Club car spaces may also facilitate shared Autonomous Vehicles (AVs) in the longer term. T2.6.) i.): WREN considers this policy point, and specifically the phrase 'opportunity for electric vehicle charging in communal spaces', to be ambiguous and lacking in ambition. This could be interpreted in such a way that no physical charging infrastructure is installed on a new residential development, on the grounds that there is future 'opportunity' for its installation. With no specific definition of what 'opportunity' entails, this policy point lacks commitment. We would like to highlight the Government's Industrial Strategy on Electric Vehicle Charging for Residential and Non-Residential Buildings (currently under consultation). (https://www.gov.uk/government/consultations/electric-vehicle-chargepoints-in-residential-and-non-residential-buildings) This document states in the summary on page 7: Policy position: Residential Buildings The government proposes every new residential building with an associated car parking space to have a chargepoint. We propose this requirement applies to buildings undergoing a material change of use to create a dwelling. Or at least a duct with a draw wire to facilitate a future chargepoint (lower initial upfront costs) We would also like to highlight the National Grid's Future Energy Scenarios 2020 document (https://www.nationalgrideso.com/document/173821/download), specifically page 44, which shows that sales of EVs in Great Britain have more than doubled since 2019, following a very steep increasing curve. The uptake of EVs has


accelerated dramatically and the picture in 2020 is very different to that of 2019. We are concerned that this trajectory has not been fully appreciated in Policy T2. 6.) i.). It is our opinion that in order to align with Government strategy, and to meet near-future demand for EV charging, Policy T2. 6.) i.) should specify that every new residential dwelling with a parking space should have an EV charger, whether that space is private or in a communal hub. T2.6.) ii.): WREN considers this policy point to be a good reflection of Government strategy, and appropriate in ambition. We would, however, like to see a minimum standard of 7kW Type 2 charge point equipment defined in the policy." 5. Maybe this should be evidence based?

253 1. T1-T3 Qs 1-3 (There are many links made under the Town Centre comments) We consider there is insufficient emphasis on public transport in these sections. There is rightly an encouragement of walking and cycling, but this mainly addresses short distance journeys within existing towns. All initiatives to encourage walking and cycling should be integrated with a fully accessible and affordable public transport system that removes the need for cars wherever possible. Affordable and reliable public transport is needed for longer journeys between towns and villages. If public transport is not available then car travel becomes the only practical alternative. Dominance of cars on streets is rightly identified in the report as a deterrent to walking and cycling. Pressure on parking space is identified as a planning issue. Taking action to reduce the number of cars goes some way to addressing both these issues. As well as ensuring that reliable and affordable public transport is available, reducing car numbers could also be achieved through co-car clubs, in which the use of cars is shared. The development of autonomous driver vehicles will facilitate car sharing. Although there are Government targets to replace petrol and diesel cars with electric vehicles, it still makes sense to reduce the number of cars. This is because all car manufacture, including the manufacture of batteries, uses scarce and unsustainable materials, and uses carbon. Any policy to extend pedestrianisation needs to take into account the specific requirements of disabled, young families, the elderly etc for easy access. T2-1 Disabled vehicles need to be included in the hierarchy of parking priorities. T2-6 One electric parking point per 10 bays is insufficient in terms of future planning Non Planning Issues. •To support child travel to school by bus where the alternative is extra car journeys by parents or guardians. Individual car journeys could also be reduced by a policy of providing school transport for all children who require it, not simply those outside the current 3 mile limit ·To allow easier reduction of speed limits, This both saves fuel (and carbon) and is a good safety measure on many roads."

005 1. Yes, you pick up on the issues but there is not enough detail on modal shift. 2. Hayle Town Council considers that you have not gone far enough. The policies need to be more ambitious. 3. They are lacking detail on modal shift. 4. Yes 5. Yes


403 3. T1 point 5 – when considering access only streets, the impact on alternative routes in terms of traffic volume, safety, noise and emission pollution must be properly assessed. Certain london boroughs are currently reversing such measures due to disproportionate impact on residents of full access roads. Providing that road access is adequate and safe and they do not impact on residential areas 4. T1 point 5 – when considering access only streets, the impact on alternative routes in terms of traffic volume, safety, noise and emission pollution must be properly assessed. Certain london boroughs are currently reversing such measures due to disproportionate impact on residents of full access roads. Providing that road access is adequate and safe and they do not impact on residential areas 5. Would make sense to locate at transport interchanges which are also less likely to impact on residents

404 1. LiveWest support Cornwall Council in promoting non-car transport options within our new developments for local travel and transport providing good alternatives are available. The provision of a hierarchy of travel modes is a sensible suggestion and would provide clarity in delivering new housing schemes. The LiveWest approach when designing new housing schemes is to ensure good connectivity to existing cycle and footpath networks and to prioritise non-car transport for local journeys by enabling greater connection through our new schemes. Policies T1 and T2 are focused primarily on new development but sustainable transport should be considered across the County within existing communities. LiveWest support Cornwall Council in promoting non-car transport options within our new developments for local travel and transport providing good alternatives are available. The provision of a hierarchy of travel modes is a sensible suggestion and would provide clarity in delivering new housing schemes. The LiveWest approach when designing new housing schemes is to ensure good connectivity to existing cycle and footpath networks and to prioritise non-car transport for local journeys by enabling greater connection through our new schemes. Policies T1 and T2 are focused primarily on new development but sustainable transport should be considered across the County within existing communities. 2. Allocated parking remains our preference as a landlord to avoid neighbourhood conflict. Whilst new developments provide an opportunity to influence behaviour change and achieve necessary modal shift this will only occur if there is provision of convenient, efficient, affordable and appealing alternatives. We would encourage Cornwall Council not to limit car parking spaces for anything other than schemes sited in city centre locations. As Cornwall has a large rural population our customers will rely on car travel without a firm commitment to public transport infrastructure including increased frequency. LiveWest are actively supporting EV charging and low emission vehicle ownership with EV charging at our 3 offices and a salary sacrifice scheme for employees to purchase an electric or low emission vehicle. Whilst LiveWest support EV charging provision the requirement to provide off-plot parking and EV charging conflict in our opinion as it is difficult to meter any charging that is away from the home. Currently


the capital cost of electric vehicles is prohibitively high but we support the policy of installing EV charging infrastructure into new homes to ensure the homes if fit for the future. From our experience car share clubs work best where sited in a town environment and are less beneficial in more rural settings and more difficult to administer. We would ask Cornwall Council to consider this when setting these policies.

163 1. I absolutely support the hierarchy suggested and would welcome and move away from the dominance of cars and provision of better active travel and public transport connections. 3. The provision of electric car charging points should also be in visible, safe and well-lit areas so that they are safe for women (and everyone) to use at any time, day or night. 5. I have no objection to this idea in principle but would not support the development of this on greenfield land.

280 1. Transport needs much more of a radical debate and although not within the structure of the DPD, investigation could be made into the viability of ‘rural road charging’ and in particular to more sensitive honeypot locations using ANPR camera systems. This will be controversial but it deserves a debate. Money raised could improve public transport even provide ‘free public transport’ We all can’t have electric cars, but electric bikes offer a cheaper and more flexible solution.

109 1. The protection and policy requirements already afforded to designated landscapes must not be diminished by this.

405 1. Policy T1 – Sustainable transport As a local business we would support having regular “Traffic Suspension Days”. This could be a day when certain roads are closed to traffic (apart from bicycles), and instead used to bring the community together. It could be a way in which the street can be reimagined, and local people and businesses can use the street in a different way, demonstrating what is possible when cars and other vehicles are taken out of the picture. The days could lead to more extended periods of traffic suspension. We were surprised there is no policy for incentivising people to take public transport. We need incentivising to take public transport. Buses are expensive in Cornwall and arguably under-used. If they were cheaper they may well be better-used and more economically viable, becoming more and more frequent and the main mode of travel. We would like to see a bold move by Cornwall Council to not just promote, but incentivise public transport. We are surprised that the “Airport” and “Spaceport” are not mentioned in this document. Whilst carbon emitted from aviation in 2016 is comparatively low - 1.5% - it had risen from 1% in 2008. Does the rise mean more people are flying? Clearly the Climate Emergency Development Plan will want to see a fall in this rather than rise.? Is this going to help Cornwall get to carbon neutral by 2030? The Council’s support and funding of Newquay airport during Covid-19 crisis does not benefit most Cornish residents (who don’t use it) and doesn’t seem compatible with the carbon neutral target."


2. 16.2.3 We appreciate that, being a rural area, cars will remain a significant mode of transport. That said, it seems that this point should say “must/will be” not “should be”. We really appreciate that point 6) states the more positive “will” rather than a “should”.

292 1. Again, don’t understand the reference to rural areas. In general with few exceptions public car parking is not supported by rural communities in my experience. 2. In general, as there is no specific reference to rural areas it does appear reasonably comprehensive. However, as has transpire in Cornwall energy conferences I have attended retrospectively installing electric vehicle charging points is difficult in many cases impossible. Strongly support the requirement to incorporate these in any future developments. Furthermore there is more than one ‘flavour’ of charging point. Again at a Cornwall energy conference a local businessman who invested in electric double-decker buses found there were no provisions on any of his routes to charge them – they require a three phase supply. 3. See above comments 4. Rather think it’s up to commercial companies to develop distribution facilities appropriate to their needs. Rather than support widespread home deliveries with delivery vehicles clogging up rural roads better targeted support for rural village shops should be considered. Any visit to any size food store will reveal to shocking scandal of food miles for imported staples. The Council have no mandate to limit these imports but instead they do have the power to support innovative local production of staples. Also in the near future the security of food import might be compromised once the post-Brexit transition period has past.

097 1. There is a lot of evidence here of good intentions around encouraging active travel but in practice success in this requires practical measures, examples of which should be made explicit. The surest way to increase active travel will be to reduce car use – evidence of this was very clear in the recent Covid-19 lockdown. The policies are far too squeemish about measures to reduce car use – see below. 2. Reduction of car use is essential to the aim of net zero. This will only be achieved by making car use less convenient and there should be explicit policies for doing so. They should include reduction of parking availibility and convenience and reduction of speed limits. Suggested speed limits: 20mph throughout all towns and villages, 30mph on all rural roads, 50mph on all major trunk roads. 5. No

407 1. As many of the current policies are aimed at reducing car use the availability of “low carbon delivery systems” should be considered. 2. See above: as many of the current policies are aimed at reducing car use the availability of “low carbon delivery systems” should be considered 3. The proposals seem to be adequate for urban areas but the rural areas will have great dificulty in achieving the same aims." 4. They can be encouraged but I do not see how they can be enforce unless developers have a financial incentive to do so and are compensated for a loss in revenue.


5. No, this aspect is too complicated for such a blanket policy given the diversity of locational chaacteristics, distribution systems and companies unless a local area lead distributor system is enforced"

408 1. Yes, we stress strong support for the following: T2 paragraphs 4 and 6 – “Parking provision for vehicles and bicycles should incorporate integrated green infrastructure, street trees and sustainable drainage in line with the Cornwall Design Guide” and “Provide electric vehicle charging points in line with the following as a minimum: • New residential building where there is associated car parking provision (including buildings undergoing a material change of use to create a dwelling(s)) will provide the opportunity for electric vehicle charging in communal spaces; or • New non-residential development with 10 car parking bays or more, will provide at least one charging point per 10 spaces and the infrastructure to enable future installation of charging points in every parking bay, consideration should be given to grouping parking bays to optimise provision of charging infrastructure.” 16.4.1 – “Sustainable transport aims to reduce the need to travel by car, encourage a hierarchy of modes (walking, cycling, public transport) but also recognising that due to rurality some form of private vehicle is likely to still be necessary, but the aim is to reduce the number of these trips.” 16.4.2 – “To achieve the goal of reducing the need for travel by private vehicle, particularly for shorter journeys, active travel needs to be embedded in design of new places, promoted by parking and design standards.” 16.4.3 – “The approach to transport assessments and travel plans is vital in driving change in the way the development plans for travel and change is needed to create less car dependant places. Travel plan guidance and philosophy is being developed with transport colleagues but will be based around physical provision of features necessary to enable a shift to more sustainable transport modes.”" 2. Yes, we stress strong support for the following: T2 paragraphs 4 and 6 – “Parking provision for vehicles and bicycles should incorporate integrated green infrastructure, street trees and sustainable drainage in line with the Cornwall Design Guide” and Provide electric vehicle charging points in line with the following as a minimum: • New residential building where there is associated car parking provision (including buildings undergoing a material change of use to create a dwelling(s)) will provide the opportunity for electric vehicle charging in communal spaces; or • New non-residential development with 10 car parking bays or more, will provide at least one charging point per 10 spaces and the infrastructure to enable future installation of charging points in every parking bay, consideration should be given to grouping parking bays to optimise provision of charging infrastructure.” 16.4.1 – Sustainable transport aims to reduce the need to travel by car, encourage a hierarchy of modes (walking, cycling, public transport) but also recognising that due to rurality some form of private vehicle is likely to still be necessary, but the aim is to reduce the number of these trips. 16.4.2 – “To achieve the goal of reducing the need for travel by private vehicle, particularly for shorter journeys, active travel needs to be embedded in design of new places, promoted by parking and design standards.” 16.4.3 – “The approach to transport assessments and travel plans is vital in driving change in the way the development plans for travel and change is needed to create


less car dependant places. Travel plan guidance and philosophy is being developed with transport colleagues but will be based around physical provision of features necessary to enable a shift to more sustainable transport modes.”" 3. We agree with the general intentions. 4. Yes. This is a good idea and could help local business if located at or near their premises." 5. In principal yes, although if it is over specific it could be limiting. This can only be carried out if other infrastructure such as roads and railways are upgraded at the same time. There needs to be a large investment in safe paths and cycle routes/tracks to reduce vehicle use."

411 3. My vision of the future is that any remaining private vehicles will be parked/stored outside of town centres and when required will be linked by active travel or public transport, possibly autonomous. This, in itself, will be slightly inconvenient and is likely to encourage more people to adapt to public transport and even get rid of their cars. With more people living in the towns this would allow virtually car free streets that could become green spaces where people could socialise, relax and where children could play (no noise, no pollution). There is an opportunity where the private or autonomous vehicles are parked, to cover the area with PV panels. This would not only provide power, possibly for EV charging, but also shade the vehicles reducing the power required for their air conditioning (not an insignificant amount and an important factor as summers get hotter). The PV covering could also provide rainwater harvesting helping to reduce runoff from the car park. The inclusion of Vehicle to Grid & battery storage would help balance demand from the grid. This might not fall under the remit of planning and might be government led but the EU is introducing automatic speed limiters that detect and slow a vehicle to the speed limit and I was wondering whether there should be a policy to adopt this technology by Cornwall Council. " 4. Yes, this is a good idea and could help local business if located at or near their premises. A reduced delivery cost would help take-up of the scheme. Can’t quite see how food could work with this system but definitely for other goods. 5. Yes, at key transport hubs as well as at local business. Plymouth has an InPost collection point outside the railway station.

265 1. We support the model hierarchy for future planning and development. However, it will be equally important to address legacy infrastructure in terms of increasing EV charge-points. It would be helpful if plans for this could be more clearly outlined. It would also be useful for Cornwall Council to speak with the DNO (WPD) from the outset to ensure that any distribution grid challenges are proactively addressed to reduce/manage network constraints that could cause delay in the expansion of charging infrastructure. Facilitating active travel is a critical element in managing car numbers. The draft DPD describes “accessible, secure, and convenient cycle parking for all users” which lacks precision and clarity as a policy. The existing planning process results in varying levels of cycle parking provision. Local planning authorities around the UK have set clear and often ambitious minimum standards of cycle parking (e.g. Greater London Authority, Cambridge City Council, Bath and North East Somerset). Explicit minimum standards for cycle parking which go well beyond the current “4% of uses” statement


(Travel Plan Guidance) (along with investment in wider dedicated cycle infrastructure) would help to harmonise provision, facilitate cycling and discourage car reliance.

329 1. There are several points that would require a great deal of investment and infrastructure to be considered realistic in my experience in Cornwall. These are Cost and reliability of public transport- public transport in Cornwall is not affordable to the huge number of people working in minimum wage jobs. It is also generally not reliable enough for people to use it on a regular basis to get to work early in the morning or late at night or if they are having to visit different sites throughout their working day. i.e. care workers Also though the ideal would be to have a high take-up of electric vehicles the cost of these is very prohibitive and is not realistic for most residents of Cornwall again working in low waged, unstable jobs. Again the need would likely be for funding to be available to support the expansion of EV use. A large part of the population in Cornwall, particularly those households with children attending schools, nurseries, etc tend to have to carry out many journeys in a day to meet their households needs and again public transport infrastructure is not currently efficient enough to meet those needs." 4. Yes this should be included where realistic. Many groups are forming ‘co-operative’ purchasing of goods, particularly for bulk, zero waste buys and this should be encouraged 5. This should be decided by the communities living in specific areas with support from local services/authorities

276 • Encourage bike sheds for all new builds, rather than car parking spaces. • We need charging points for electric bikes as well as electric cars. • Again we need to encourage and support people who walk instead of taking any other transport. We need to concentrate on less cars and more walking and cycling. To do this we need to fully support walkers and cyclists and dull down a journey in a car. We need to take the convenience out of driving. 1. Making roads safer to walk on. Especially routes to school. I used to walk to and from my school in St Just from my home in Botallack. We walked on the road because it wasn’t muddy in the winter and it is generally the quickest route. It wasn’t safe then and it is a lot busier on the roads now. 2. Slowing the speed limits for cars (I know this is a Highways issue but Council should lobby for this change) 3. Walk and bike lanes on roads

413 1. A policy is required in order to connect existing housing stock to a charging grid for electric and low emission vehicles. Particularly those properties that front onto roads with no allocated parking. 2. Consideration of topography, promotion of electric bikes 3. As towns grow larger, the town centres are getting further away. This means the residents could have difficulty walking and cycling to their work and shops

264 1. Cornwall CLT welcomes the proposals 2. Although actively considering it, Cornwall CLT would question the benefit of off-plot parking spaces in rural areas


3. Without significant improvements to public transport in rural areas, access to cars and parking remains an essential part of life for many. Care needs to be taken over how the use of the car is discouraged as simply providing less parking can lead to fly-parking and various types of friction between neighbours.

095 1. The gradual development of horse-drawn transport 2. There is no clear plan of what to do if fossil fuel becomes totally unavailable, which could happen in 3 or 4 years’ time.

417 1. The JLP Councils agree with the aims of these policies, and would encourage Cornwall Council to consider how they can work proactively with developers to contribute to a regional network of EV charging points in new and existing developments. This will help to rapidly de-carbonise domestic and commercial travel, and enable low carbon travel between Cornwall and adjoining authority areas.

418 1. You MUST plan for a time without any fossil fuels – which may come within a year or two. Please include a plan, even if you think it is unlikely. Horse-drawn transport supplementing bicycles and a network of electric buses might work. 5. One of the key aims of this plan must be to reduce international imports and even local distribution. Cornwall will survive well if we grow our own food and collect our own energy.

419 5. We need to acknowledge that given the geography of our communities in Cornwall and insufficient public transport that we have, that whilst we do appreciate the impact on our vehicles impact have on the environment that cars are likely to continue to be the prime mode of transport in Cornwall, particularly for hard to reach areas and ones that struggle with sufficient public transport. Unless there is a reasonable alternative then the car in Cornwall will be the prime mode of transport. This therefore needs to be acknowledged but planned for. Instead looking at ways to reduce the need for too many journeys and trying to encourage any shorter trips to be done in other ways. We need to acknowledge that we do need the use of our cars in Cornwall and plan for them particularly with moves to being electric in the near future

421 1. Lobby for central government to delegate the power to Cornwall to charge a separate rate on domestic and non-domestic parking spaces. Then to utilise this to charge households and businesses in such a way as to discourage car ownership and usage. 2. Recommend more contingency planning for extreme events, both weather-related (e.g. intense rainfall) and geopolitical (e.g. interruption of electricity, oil or gas supplies, sudden influx of refugees) 4. Should we develop a policy to encourage the provision of new distribution facilities at key locations where it can be shown that these would help to consolidate freight journeys, particularly those related to home deliveries of food or goods? 5. Specific, but will probably need to adapt and change over time.

243 3. Policy T2.3 reads “Provide accessible, secure, and convenient cycle parking for all users, located in prominent locations”. As drafted, this policy would appear to apply to cycle parking at destinations (eg transport hubs, town centres or workspaces). That’s the implication of the words “prominent locations”. But people also need secure cycle storage at home, and in most cases this would mean within the curtilage of their dwelling (if bikes are stored outside the dwelling, that will decrease usage


due to concerns about theft and also the need to walk to the bike store). So new dwellings should be required to incorporate cycle storage within the curtilage. 4. Yes. And this could be used to promote out-of-town transhipment hubs where loads could be split and transferred to a fleet of small low-emission delivery vans for final-mile distribution to town centre retailers (for example, a hub in Long Rock serving Penzance). This would cut emissions and noise pollution in town centres and showcase Cornwall as a green pioneer. There’s also the possibility of funding from central government via the Office for Low Emission Vehicles (OLEV).

189 2. "Draft Policy T1 does not appear to have been drafted with due consideration of a range of development types, importantly tourism and leisure, which is a vital part of Cornwall’s local economy. Neither does the draft policy acknowledge the large size of Cornwall and its topography which makes the issue of travel a big challenge and hence the use of cars is important. Many tourism facilities are located in rural areas, and it is this very nature which makes them attractive to visitors. Likewise, visitors from an accommodation site in Cornwall will travel all around the county to visit various city and town centres, attractions, and tourism facilities. The draft policy does not reflect the current level of infrastructure in Cornwall, and the consultation document does not identify how this will be developed, in order to facilitate minimising the need to travel and supporting a modal hierarchy where private fossil-fuelled vehicles are at the bottom. This issue is exacerbated by how ambitious Cornwall is seeking to be, ahead of the rest of the Country, which will mean the wider infrastructure will not be in place to support the aims of Policy T1, particularly in relation to the large number of visitors travelling into and around the County. Cornwall’s economy relies on its visitors and therefore, development proposals need to be fairly considered to ensure the proposed transport policies do not have adverse consequences on the ability of the sector to invest." "Policy T2 identifies that non-residential development with 10 car parking bays or more are to provide at least one charging point for 10 spaces and the infrastructure to enable future installation of charging points in every bay. Clarification is needed to confirm whether this will apply to tourism accommodation sites (such as Holiday Parks). Inevitably as the use of electric vehicles increases, Park operators will respond to customer expectations and requirements (as they do with many other aspects of the operation of a Park). However, this will be phased as public take up increases and Parks need to phase investment accordingly. This will be one of many aspects of change and investment over time. The Council does not need to and should not set some artificial date or expectation (where capital investment that is limited, needs to be placed where it is useful and productive). Timing is key. Any new requirements must only apply to the additional units secured by that permission and not the entire Park, where the proposal forms an extension to an existing provision.

019 1. Policy T1 and Policy T2: Historic England notes the intent of this section and Policy T1 and Policy T2. We are pleased to see acknowledgement in paragraph 16.1.3 and 16.5.2 of the potential


negative impacts of parking on streetscapes and the reference to the Cornwall Design Guide in paragraph 16.1.4 and 16.5.5. It should also be noted, however, that conservation area character appraisals and/or management plans may also contain relevant information, e.g. identifying parking as a negative feature that needs addressing. In our view, the settings of some heritage assets and the experience of being in some historic streetscapes, townscapes and landscapes may also benefit from the greater use of electric vehicles due to improved noise levels and air quality. With care in the amounts, locations and designs of parking, streetscenes and the settings of heritage assets need not be dominated by parking and the character and experience of being in historic townscapes, landscapes and seascapes need not be compromised. Likewise, the careful installation of electric vehicle charging infrastructure can ensure that harm to the significance of heritage assets is avoided or minimised. Relevant guidance can be found in Streets for All (2018) and the South West version (2018), and The Settings of Heritage Assets (2017). To this end, we consider that a new requirement should be introduced into Policy T1 and Policy T2 for parking and electric vehicle charging points to be carefully sited and designed so as to conserve and enhance the significance of heritage assets, including their settings. Policy T3: We note the intent of Policy T3. Former railway land may contain heritage assets and their reuse may offer opportunities for the conservation and enhancement of their significance, as well as opportunities for greater public understanding and appreciation, e.g. through interpretation. Their reuse may also offer opportunities to enhance the setting of heritage assets located outside of former railway land."

9. Proposed Policies Renewables (including geothermal & mine water)

Policy RE1 - Renewable Energy principles Policy RE2 - Safeguarding Strategic Renewable Energy Sites Policy RE3 - Wind energy Policy RE4 - Solar Energy Installations Policy RE5 - Geothermal/Mine Water Policy RE6 - Community Led Energy Proposals Pre-submission Consultation Questions 1. Do Policies RE1 – 6 pick up the right issues for renewables – are there anymore that you would add? 2. Are the policy approaches that we are suggesting in policies RE1 – 6 about right – is there anything missing? 3. Do you have specific comments to make about the content or intentions of policies RE1 – 6? 4. Do you have an alternative approach to Policies RE1 - 6 that you think the council should consider? 5. Is there anything that we could do to further promote or enable community led energy proposals?


6. Policy RE1 requires community benefit from renewables installations – do you have any opinion on the form that this should take?

URN Comments

352 1. Renewable energy storage is addressed but many people rely on natural gas or oil for home heating. Alternatives should be sought, e.g., piped hydrogen, warm air or shared ground source heating. 2. Renewable energy storage represents no less than the route to dominance for renewable energy in replacing fossil fuels. As such, much more emphasis needs to be placed on natural resources (underground caverns, molten salt and other technologies) to complement short discharge devise like batteries, flywheels and mine shaft weights. 4. RE2 is not strong enough - "will support non-renewables only where proven to be unviable". 5. Policies RE3,4,5 should require local storage of surplus energy. 6. There should be a scheme whereby Council Tax is offset by donation to local approved energy schemes.

355 1. Yes 5. Lack of information is a barrier so CC information campaigns about what/how/the benefits to local communities would be helpful to capacity build. 6. If there was anyway of passing on any price savings directly on to local communities and making this lower energy bills very visible would help.

358 1. Yes Nothing to add 2. Yes Nothing to add 3. No 5. Don’t Know 6. Direct financial benefit to households

360 1. "RE1. In the past too much emphasis has been placed on renewables at the expense of local communities. Sites for these fixtures must take into effect any heritage sites, local households, environmental sites and habitat of any local species. Too much emphasis has been expressed on installing Solar panels which should leave the ground under them for grazing. In reality this doesn't happen so the ground used to install them is lost as food producing. The visual effects of certain renewable projects leave us with a moving horizon which takes away from the original church spire. If renewables are to be installed let it be without any subsidy. I believe Cornwall Council have lent money to renewable projects to encourage these projects but without the support of subsidies these projects would not be beneficial. Some of these renewable projects get paid more to turn off their production so how does this benefit us?


The temptation of financial grant to local communities should not be used as a ""carrot"" to get support. If the projects are as good as they are supposed to be let them show this by not accepting any subsidy from government. I don't believe the statement that there is a consensual support from all communities for certain types of renewable. 2. I hope that this statement is adhered too. 3. That the agreed instalment of any wind turbines is in alliance with the local plan. Wind turbines are not placed near local communities as the noise and flicker they generate does have a medical impact on some personnel. 4. The cumulative impact has not always been taken in consideration in the past as there are numerous installations close to each other."

364 1. "RE1 Renewable energy should be on property roofs, not on farm land that is here to produce our much need food supply. We can grow just about anything here in Kernow, and we should do this. So as we do not have to purchase food that has been trucked in to the UK, one, causing more climate problems, from the EU, and where it has been grown by African slaves. Until the power grid is made to take power up through Kernow and on into the rest of the UK. Kernow will not be permitted to use the huge amount of assets that we have here both the sea, i.e. Hayle, and our mine water. RE 2 Why was the disgusting filthy incinerator permitted. It produces hardly any power. And, then only what EDF permit it to. This is a complete waste of a billion pounds of our tax money. We should be recycling every thing that we can, and, not using plastic for any reason. RE 3 Wind turbines are a complete waste of our money, as most of the time they are not permitted to put power into the grid. So unless the farmer or company can use the power for themselves, then it is a waste of both money and our valuable farm land. RE 5 This is great, but the second home owners are not going to like it when they realise that there are mines beneath their feet, and their malty million pound properties. Perhaps we can rid ourselves of these crooks at last. RE 6 Has Konsel Kernow got permission from EDF to do this?? When is Konsel Kernow going to demand that the power grid can take our power and send it up the line to the rest of the UK, and not just one way as now? "


363 1. "27 Policy RE1. I don’t see any mention here of anaerobic digestion, Mistake! No 1 do a comparative analysis of the returns per £ invested with the array of renewable energy technologies. Make sure to include AD, geothermal and wind turbines repurposed and powered by water wheels. Don’t laugh they rotate at about the same speed and water wheels work 24x7 rather than 25% of the time, are controllable and the water is used over and over again. Look at Trethellan water to Perranarworthal and how many waterwheel sites there are along that three miles of river! If there is excess supply use it to convert water into hydrogen which is easily stored and used in fuel cells. Kennall Vale can still be a nature reserve just


with the mill buildings housing two turbines each driven by a water wheel, no noise, no mess, no fuel and connections to grid already down there underground. The costs and benefits of AD I have banged on about for years, several streams of revenue as well as savings on beach cleaning, water supply etc etc etc. Geo thermal remember to add in the benefits of using waste heat for greenhouses and the like and any potential mineral recoveries from the water. See also my comments above about high density planting of selected fast growing species such as Eucalyptus to produce charcoal and wood. Selected here being selected high yielding individuals from the normal curve to maximize yield. This has been shown to raise yield per hectare compared to seeding populations by 400%. 28 Policy RE2 how much will sine developer have to pay to get over this? 29 Policy RE3 and RE4. These technologies score very low on the comparative analysis of the return per £ invested. They should never had been allowed other than on the roofs of buildings. The benefits just do not stack up against the costs, it is structural. Wind only blows 25% of the time and solar doesn’t work at night. And of course they don’t work at all in Feock! Where do the benefits accrue? Not to Cornwall that is for sure the installations I have seen are often owned by big companies not even in UK. 30 Policy RE5. See my comments about geothermal above 31 Policy RE6. See my comments about high density wood plantations above. If schools grew nurseries then pupils could plant trees which they have grown and thereby own a share in the enterprise from which they would benefit proportionally as long as they continued the maintenance through the whole cycle to harvesting and coppicing and harvesting. Shares would be transferrable to relatives and even friends but not saleable. This is sweat equity not for cash sale. Run by Parish Councils? Contribute long enough and you get a free burial plot? Or discounted anyway.

374 1. Renewable energy storage is addressed but many people rely on natural gas or oil for home heating. Alternatives should be sought, e.g., piped hydrogen, warm air or shared ground source heating. 2. Renewable energy storage represents no less than the route to dominance for renewable energy in replacing fossil fuels. As such, much more emphasis needs to be placed on natural resources (underground caverns, molten salt and other technologies) to complement short discharge devise like batteries, flywheels and mine shaft weights. 4. RE2 is not strong enough - "will support non-renewables only where proven to be unviable". 5. Policies RE3,4,5 should require local storage of surplus energy. 6.There should be a scheme whereby Council Tax is offset by donation to local approved energy schemes.

029 3. Yes. Much good work on the siting of wind turbines and wind energy is already there in Cornwall Council’s Appendix 1 to Annex 1 of the Renewable Energy Planning Advice March 2016. Please don’t reinvent the wheel.

032 2. 17.1.1 Why is offshore wind excluded?


RE1 There seems little difficulty here except that reference to Landscape Character Areas appears to have been set aside as does any special consideration of landscape diversity and the coastline. Respect for landscape should not be ignored, particularly significant landscape, when considering renewables RE2 Policy Maps showing locations for renewables in the existing Cornwall Local Plan appear to be absent. Where are they? If they do not exist already, it is difficult to see how this Policy can be considered anything other than a blank cheque. In fact, further on, at 17.6.3 it is confirmed that “the DPD does not currently set out allocations or suitable areas for wind energy. These allocations and suitable areas will form part of a future consultation on the DPD”. Accordingly, it is impossible to accept RE2. RE3 - Again, without a draft Policy Map it is impossible to support the Policy as a whole. The Policy provides no reference to landscape or environmental designations other than WHS (such as AONB or SSSI). As mentioned above, there are sound environmental reasons for extending recognition and protection to locally designated landscapes. Under sub-paragraph 2, To address an issue is to direct attention to it. It doesn't mean the issue will be solved, only acknowledged. There is a need for more powerful wording." RE4 - Sub-paragraph 2 is, I think, essentially an issue with ground mounted installations. The word “minimised” can simply mean making the best of a bad situation. Should the word “minimised” be altered to “minimal”? Should a consideration be given to requiring all commercial buildings to have solar panels on their roofs unless good reasons are put forward to avoid this? RE5 - There is no comment on this other than the Mine Water system is in very early days of proving itself (as, I guess, is geothermal). It is not clear why they require a planning policy at this stage of their development RE6 - No comment here. Seems OK.

378 1. Yes 2. Consideration needs to be given for the potential to use electricity generated from renewal sources to produce hydrogen for heating and for generating electricity during times when that produced from renewables is insufficient. Consideration also needs to be given to the potential to produce liquid fuel from surplus electricity by combining carbon dioxide with hydrogen (Air to Fuel — A2F technology) This has the potential to solve the problem of the intermittent nature of electricity generation by renewable means. The alternative of using batteries results in environmental degradation to obtain the battery ingredients. As the use of lithium batteries is likely to increase in the immediate future, we would encourage the mining of battery-grade Lithium in Cornwall. As the UK extractive industries operate under tighter environmental controls than in many of the countries where Lithium is currently extracted the more we can extract in Cornwall, the less will be the environmental degradation in other countries. A thriving Lithium extraction industry in Cornwall would hopefully lead to the manufacture of Lithium batteries in our county using locally-sourced Lithium. 3. We welcome the intention regarding the erection of wind turbines. During consultation for the Lostwithiel Neighbourhood Plan we found that there was


limited support for wind turbines and considerable opposition to them. Wind turbines represent a mature technology and, as such, it is unlikely that their efficiency will improve in the future. They also dominate the landscape and should be discouraged. In contrast solar power technology is advancing fast. Recent gains in efficiency of 30% have been achieved. Cornwall Council should consider mandating that all development should, unless it conflicts with local heritage or special landscape value, incorporate solar panels. Cornwall Council should consider encouraging the retro-fitting of solar panels. Encouragement should be given to improving the aesthetics of solar panels to make them more visually acceptable in architecturally sensitive areas. 4.See responses to questions 2 and 3 above. 5.If A2F (or other) fuel is burned to generate either mechanical or electrical energy, the waste heat should be used, where practicable, to heat homes as is being achieved in Denmark. 6.Installation of combined heat and power schemes as outlined in our response to question 5 above.

053 2. Under Policy RE1, we welcome, with suggested addition underlined, 'it will not result in adverse impacts on the local environment or the integrity of the wider nature recovery network and natural processes which cannot be satisfactorily mitigated, including cumulative landscape and visual impacts, and the special qualities of all nationally important landscapes, heritage assets including their setting which must be conserved or enhanced'. We also welcome promotion of integrated land use at, 'the use allows for the continuation of some form of agricultural or biodiversity use.' We urge the council to particularly support renewables on (low ecological value) brownfield sites and rooftops, rather than taking from agricultural or high conservation value land.

383 In respect of both wind and solar farms there must be adequate site security to protect the facilities and obviously in turn the energy supply. There have been some examples of resistance on occasion to the erection of for example of robust security fences and CCTV. Without such measures these facilities can be very vulnerable to criminal attack which does occur and is often difficult to combat due to the size and location of the “farms”. Also recently there have been planning applications requesting increased CCTV and intrusion audio response systems for solar farms. These have been demanded by insurance companies for these facilities because of the increased risk. To be “sustainable” these installations must be properly secure.

385 1. Policy RE1.5. and Policy RE6.2 State that community-led energy proposals must evidence community consensus in support of the proposal. Does this stipulation on community consensus apply to commercial proposals as well, and if not, why is there an additional hurdle for community-led proposals? What is the Council’s definition of community consensus, is this a certain percentage of the community? Does the Council have a way of verifying and assessing consensus and will it be advising communities on appropriate methods of collecting, collating and analysing such information? Is the Council planning to require commercial enterprises to also prove community consensus?


The last paragraph in Policy RE1 states that mechanical and battery storage will be ‘supported’. This area is clearly a significant part of the way forward to increasing energy provision and self-sufficiency in Cornwall. It is also an area where development is essential. Will the Council consider active involvement and investment in this as part of its ‘support’? 2. Policy RE3.3, Policy RE4.4. and Policy RE5.2. In Policy RE3. 3, the Council requires a 10% biodiversity gain in respect of windfarms. It is noted that no biodiversity gain is required in Policies RE 4 and 5 - Solar and Geothermal/Mine Water projects. Is there a reason for this discrepancy, and what assurance does the Council expect from developers that any 10% biodiversity gain will be permanent and meaningful? Should this gain be a higher percentage even? Policy RE6 Some local areas are among the poorest in the UK; it is essential that disadvantaged communities are encouraged and supported to develop community-led energy plans. Should the Council be supporting community-led energy proposals more actively through some form of funding and/or provision of specialist advice?

034 2. 17 Renewables (including geothermal & mine water) 17.1.1 Surely, off-shore wind energy should be mentioned?" 3. There seems little difficulty here except that reference to Landscape Character Areas appears to have been set aside as does any special consideration of landscape diversity and the coastline. Respect for landscape should not be ignored, particularly significant landscape, when considering renewables. 4. Policy Maps showing locations for renewables in the existing Cornwall Local Plan appear to be absent. Where are they? If they do not exist already, it is difficult to see how this Policy can be considered anything other than a blank cheque. In fact, further on, at 17.6.3 it is confirmed that “the DPD does not currently set out allocations or suitable areas for wind energy. These allocations and suitable areas will form part of a future consultation on the DPD”. Accordingly, it is impossible to accept RE2. 5. Again, without a draft Policy Map it is impossible to support the Policy as a whole. The Policy provides no reference to landscape or environmental designations other than WHS (such as AONB or SSSI). As mentioned above, there are sound environmental reasons for extending recognition and protection to locally designated landscapes." 6. Sub-paragraph 2 is, I think, essentially an issue with ground mounted installations. The word “minimised” can simply mean making the best of a bad situation. Should the word “minimised” be altered to “minimal”? Should a consideration be given to requiring all commercial buildings to have solar panels on their roofs unless good reasons are put forward to avoid this?"

348 1. Vistry Group support policies RE1-6. 2. The policies are comprehensive. 3. We are concerned about the requirement for all major development proposals over 100 dwellings to seek to integrate decentralised energy networks. In our experience 100 units is significantly below the number of units required to make decentralised energy networks viable.


Decentralised energy plants require significant upfront funding and multi-site agreements. This approach will require coordination from Cornwall Council and critically commercial energy providers. Where scale and location is deemed appropriate, this should be considered at local plan allocation stage as this policy is undeliverable by individual developers and could adversely impact on housing delivery. 5. We support the principle of community energy delivery as an aspiration. However, as set out above, to ensure this does not adversely impact on housing delivery, this requires signification coordination and funding and therefore must be considered as part of a strategic local development plan. 6. Vistry Group do not have an opinion on the form that Cornwall Council should take. We would be happy to work with the Council to explore the joint understanding of the costs associated with the various options to meet each development’s need.

122 2. This is the section of the DPD which gives the Society the most concern in the context of protecting the AONB. We repeat our concern that there is no differentiation of policies in this DPD between land within and without the AONB. Technically, this must be wrong. RE1 - Paragraph 2 is a good example of the need for different policies for the AONB. This paragraph is technically wrong. Local Plan policy 23.3(a) for "land within or affecting the setting of the ANOB" is "Proposals must conserve and enhance the landscape ... " This proposed policy is in conflict with this requirement." RE4 - Because of the wording of this policy, the policy can definitely apply only to land not within AONB and that should be stated explicitly in the policy. In our area of concern, and indeed throughout Cornwall, we do not expect the Policies Map to identify any land within the AONB for wind turbines. Policy RE4. As with policy RE3, we do not expect this" As with policy RE3, we do not expect this policy to apply to land within the AONB. What is omitted from these policies and which needs to be considered urgently is the physical requirements for the transmission of electricity. The transmission system in Cornwall is designed basically to distribute electricity generated out-county. It is not designed to export electricity generated from within the county. Given the proposed policy as it stands, turbines and solar panel arrays should only be allowed if the electricity will be consumed in-county. Power lines and pylons are very unsightly and are as bad if not worse that turbines. Any new application for turbines should detail how the power from them is to be delivered to the grid and no new power lines or pylons should be allowed. Probably, it is necessary for the council to determine how much extra energy is needed in Cornwall before mapping where turbines and solar panels should be, so that the needed power generation is located in optimal positions (subject to all other planning policies) with little wastage on connections.

388 1. Yes, about right 2. About right


389 3. It makes no sense that policy RE1 is just couched in terms of the contribution that Cornwall can make to national renewable energy targets; but does not specify its own or any aspiration to ensure that renewable energy is as far as possible a Cornish ‘cash cow’ to fund future sustainable ‘growth’ (in the widest sense of the word) through the creation of a sovereign wealth fund. It is ironic that the visual impact of rebewable energy on the landscape is highlighted and considered in RE1; yet housing development can and does have an impact. 6. As with my earlier response; there is a need for income (or at least a proportion of it) to support a sovereign wealth fund to act as alternative to planning obligation income and also support infrastructure put under strain by inward migration.

390 1. Relying on areas listed in the NDP for wind is tricky. These require large amounts of work and may not have the right people advising on aspects like wind energy. There should be more support to help communities plan for and integrate renewable energy within their NDP region. Also improved guidance for updating the NDP without requiring the full consultation and workload. 2. Clear targets for the renewable energy capacity to be achieved should be included.

393 1. These policies do cover the right issues. Does RE1 need clarification so that there is no requirement to remove district heating pipes at the end of their life? 2. The approaches to wind, solar and geothermal are about right but why are we picking out only three approaches here? Should there also be policies for hydro. Ie. micro hydro, pumped storage (clay pits), tidal energy (Truro’s new riverside development, Hayle, Padstow, Fowey, Helford) There is also potential here to protect these towns from sea level rise. 3. We think that a condition of planning permission for dwellings but especially for factory/out-of-town shopping facilities, should be to have solar PV panels installed. This should also include covering car parking facilities with PV panels. These coverings could also provide shading and rainwater harvesting helping to reduce runoff from the car park. 5. In 17.9.3 it was suggested that possibly additional guidance on community-led energy schemes would be provided. We are sure this would help get schemes started.

395 1. I cannot understand why marine applications are not more widely used. 2. Surely simple turbines in the thousands of our coves with all the tide force we get would provide more power than Cornwall would need? In my opinion the Wave Hub has been an absolute and costly failure can this be revamped to use turbines instead." About right but use the sea and its tides! 3. Geothermal has not been the success predicted, the original system at Longdowns failed because of the geology. When water is forced down under high pressure the granite rock structures more than likely fissure therefore dissipating the heat gain and this also occurred at the Penzance lido where heat pumps have to be used to achieve the temperature needed. Great care will have to be used in reclaiming mine water due to contaminants and the chances of wall collapses when a chamber is emptied risking possible further flooding.


5. Assign an area in each development for an allotment for home grown produce, I have found mine a tremendous asset both in terms of supplies and occupational needs. 6. Unsure as how to achieve this.

174 1. Policy RE1 - Renewable Energy principles “All major development proposals should seek to integrate low carbon energy and decentralised energy networks into the proposal. Proposals for development of more than 100 dwellings or non-residential development of over 1,000sq.m will be expected to consider the integration of community energy networks in the development, taking into account the site’s characteristics and the existing cooling, heat and power demands on adjacent sites.” Would this include minerals applications? The focus of the wording of the Policy seems to be on residential and commercial major developments with definitions given, accordingly. For clarity, minerals definition needs to be given or excluded from this Policy.

192 1. As in other sections of the DPD, there is a lack of imagination and ambition in this section. There is also an underlying assumption that growth in energy use is a given and that planning should accommodate this. This is a dangerous assumption and ignores the fact that we are in a Climate Emergency. Continued ‘growth’ in energy demand is unsustainable, and development that leads to a rise in carbon demand should be resisted. The DPD correctly recognises that there is an abundance of renewable energy potential in Cornwall. However, it is presented in terms of meandering towards an increased share of renewables in the energy mix. This seems very unambitious given our resources. Cornwall should be aiming to simultaneously reduce its energy demand, while at the same time striving to replace all fossil fuel use with renewables. There is potential for excess capacity to be sold outside Cornwall, as part of a green economy. With the current inadequate state of the UK's electricity infrastructure, Cornwall might consider large scale production of hydrogen using excess onshore wind energy to electrolyse water. 2. There is no mention of wave energy, marine biomass, or energy storage of any kind (though it is mentioned in passing in Sustainable Construction). For example, Cornwall is riddled with deep abandoned mine shafts. The potential for gravity-based energy storage could be huge. https://www.theengineer.co.uk/abandoned-mine-shafts-energy-storage/ https://www.theguardian.com/environment/2019/oct/21/how-uks-disused-mine-shafts-plan-to-store-renewable-energy. 3. 17.4.3, 17.6, RE3: Onshore wind energy production can produce electricity for around half the cost per unit as offshore wind, and more cheaply than large scale solar PV (see https://en.wikipedia.org/wiki/Cost_of_electricity_by_source#United_Kingdom). Cornwall Council cannot delay setting out areas suitable for onshore wind development, given the availability of this resource. 4. There is no mention of integration. For example, the DPD mentions that energy storage is important, and that ideally it should be used where it is generated. Elsewhere, it’s mentioned that public transport should be encouraged. So, we feel there is an opportunity here for a truly green public transport system that would be

https://www.theguardian.com/environment/2019/oct/21/how-uks-disused-mine-shafts-plan-to-store-renewable-energy

https://www.theguardian.com/environment/2019/oct/21/how-uks-disused-mine-shafts-plan-to-store-renewable-energy


free in terms of energy costs and therefore extremely cost effective for residents. It would be simple to create bus depots for electric buses, with solar PV and/or wind generating the energy to charge the batteries. The buses would have exchangeable battery units so they could effectively recharge in seconds. This can be achieved right now with existing technology. The Council could even implement this at existing park and ride locations, such as Truro, covering existing car parks with solar PV roofs, and electrifying the buses. Even without giving specific examples, the Council should encourage vision, ambition, and ideas, and make it clear to communities that they would be favourably minded towards such projects. https://www.theguardian.com/sustainable-business/2016/oct/08/brighton-solar-powered-buses-electric https://www.evoenergy.co.uk/technologies/solar-carports/ https://news.stv.tv/west-central/car-park-covered-in-solar-panels-to-help-light-up-stirling?top. 5. The Council could only further promote community led proposals if it was already promoting them. Apart from a single geothermal project, we can't think of a single renewable energy project currently under development. 6. Cornwall Council should rapidly replace gas boilers in its own housing stock and combine solar PV and with large heat pumps to provide low cost (or free) heating and hot water to social tenants, supplying several dwellings from one source. This will reduce carbon use and help alleviate poverty, another example of an integrated approach.

297 1. RE1 (2) – protected landscapes. The NPPF states that protected landscapes should be conserved and enhanced. As worded/punctuated this clause suggests that the need to conserve and enhance just applies to heritage assets. We advise that this clause is re-phrased to state that landscape and scenic beauty in nationally protected landscapes is conserved and enhanced. As a more general point the Council should also consider whether it is necessary to repeat general policy principles set out in the overarching Cornwall Local Plan/NPPF on an ad hoc basis as this could lead to confusion. RE1 (3) – biodiversity. Either policy should state a requirement for net gain or net gain should be covered by a general policy, applicable to all development. This clause doesn’t set out the general Local plan/NPPF requirement that biodiversity should be protected and enhanced. This is a different approach to that taken for landscape issues in clause (2), where CLP policy is repeated. This is confusing. The DPD should be clear on what issues are covered by general policies. RE1 (6) - Site restoration. We advise that restoration of the site to an acceptable alternative use requires clarification. Does the wording mean an alternative to the original use or an alternative to the energy use? RE2 - This policy refers to potential sites for renewable energy. We assume that these will be published for consultation in a future iteration of the document. 2. This policy refers to potential sites for renewable energy. We assume that these will be published for consultation in a future iteration of the document. 3. We suggest that policy sets out criteria relevant to the specific nature of solar development rather than repeat, in very general way, criteria set out in the Local Plan. For instance, RE4 (4) requires that “there will be no unacceptable impacts on biodiversity and landscape including cumulative impact”. The Cornwall Local plan

https://news.stv.tv/west-central/car-park-covered-in-solar-panels-to-help-light-up-stirling?top

https://news.stv.tv/west-central/car-park-covered-in-solar-panels-to-help-light-up-stirling?top


already sets out more detailed criteria to protect biodiversity, the best and most versatile agricultural land and landscape in policies 21, 22 and 23. 4. One of the policy criteria for geothermal energy development is ‘appropriate siting’. We suggest that more detail is provided on the criteria which would help define an appropriate location given the likely nature and scale of this type of development. The policy should also refer to the need to deliver biodiversity net gain unless this is covered in a general policy which requires net gain for all types of development. Hydropower. There is no mention of hydropower. This is an area of growing interest and such development often has environmental implications. Specific policy, supporting information and specific guidance in a supplementary planning document, would be useful here as is proposed for solar, wind and geothermal.

041 1. RE3 Planning needs to include offshore wind farm developments. Large scale infrastructure wind projects, whether floating or not, need to deliver more than 10% net gain. It is critical that offshore wind farms avoid detracting from the aesthetics of seascapes that are visible from along long stretches of Cornwall AONB and World Heritage Site coasts. Offshore wind farms must demonstrate 30% net gain on marine habitats and species. Solar energy should be compulsory on all rooves to ensure buildings are energy self sufficient to the maximum possible. " 2. No mention of wave or tidal energy…both should be considered due to effective energy generation off Cornwall’s vast coastline. Council need to ensure widespread promotion of community-led energy generation projects and incentives need to be provided to encourage this.

396 3. Ideally, non-renewable energy projects should not be permitted. Time for bold action. Also, perhaps biodiversity offsetting (significant contribution to other biodiversity projects) should be considered for renewable energy generation sites so as not to impede their roll-out. 5. Encourage more community ownership / community power generation schemes.

266 1. In general, Policies RE1 – 6 pick up the right issues for renewable energy, but I would add: - policy principles in RE1 that consider the impact of climate change on the future viability and sustainability of renewable energy sites. - policy on micro-hydro schemes, particularly run of river/stream installations. - policy on wave or tidal energy schemes located on the Cornish coast. 2. In general, the policy approaches suggested in policies RE1 – 6 are about right. 3.In the penultimate paragraph of RE1, rather than “…community energy networks…” I would state “...community low carbon energy networks…”; - In the final paragraph of Policy RE1, rather than “…provide power direct…” I would state “…provide energy direct…” as “power” implies electricity and not other forms of energy such as heat or cooling. - At item 3 of Policy RE1, rather than “…agriculture…” I would state “...sustainable agriculture…”; - Why are the equally applicable policy elements in Policy RE3 not included in Policy RE4 and vice versa (eg Policy RE3 element 2, as well as element 3


and its associated bullets of “impacts on the natural environment”; “are compatible with the Outstanding Value of the Cornwall and West Devon Mining Landscape World Heritage Site”; “impacts on built environment and historic assets”; and “the creation of 10% biodiversity net gain”, might equally be applied to Policy RE4; and likewise Policy RE4 has element 1 and element 5 which might equally be applied to Policy RE3)? - The same comment on equally applicable policy elements can be made with regard to Policy RE5 and Policy RE3 and RE4. 6. No comment in relation planning, apart from the need for a supportive, streamlined planning environment for such installations.

397 1. There are two unnumbered statements in RE1, which should also have the status of “policies”. We agree with developments integrating decentralised energy networks, but consider that the size of development to which it applies should be a lot lower than 100. We welcome the support for mechanical and battery storage. 2. (a) Policies RE3 (wind), RE4 (solar) and RE5 (geothermal) all address methods of generating renewable energy, and so should be very similar. However, they are expressed in very different ways, with wording that is sometimes similar and sometimes very different. This makes it hard to compare policies across the different technologies. For example, RE3 and RE5 do not mention removal of the installation, but RE4 requires that: “the design provides a method to remove the structure and sets out a commitment restore the site.” We consider that the same structure and approach to the wording should be used in all three, subject to our comment (b) below. (b) Policy RE1 expresses principles, which implies that they apply to all the various renewable energy technologies. However, policies RE3, RE4 and RE5 which apply to specific technologies repeat some of the principles in different wording. For example, RE1 (2) requires that “It will not result in adverse impacts on the local environment that cannot be satisfactorily mitigated, including cumulative landscape and visual impacts, and the special qualities of all nationally important landscapes, heritage assets including their setting which must be conserved or enhanced.” RE3, RE4 and RE5 all refer to some of the same things, but not all of them. Where RE1 and RE3 differ, which will take priority? Having policies which ought to be the same but in fact differ is a recipe for confusion and provides avenues for expensive litigation which ought not to be present. We consider that the principles expressed in RE1 should be taken as applying to RE3, RE4 and RE5, and that within RE3, RE4 and RE5 only matters that are specific to the technology should be stated." 3. (c) RE1 contains asymmetric treatment of commercial and community-led developments. Item (5) requires that: “For community-led proposals there is evidence of community consensus in support of the proposal.” However, evidence of community consensus is not required of commercial developments. This puts community-led developments at an immediate disadvantage, with a more onerous burden of proof. RE3 requires only “consultation” with the community. RE5 requires only that community “engagement” is undertaken. RE4 does not mention any involvement with the community. There is also no indication of what “evidence of community consensus” actually means. We consider that the requirement to provide evidence of community consensus should be removed from the policies.


Policy RE3 (WIND energy) should include single wind turbines for certain rural businesses subject to Planning Permission, location etc (d) Policy RE6 (Community Led Energy Proposals) contains four requirements. 1) The impacts arising from the proposal are acceptable or can be made acceptable; This repeats what has been said already in RE1 and RE3-5. As argued above, repetition is unnecessary, so this should be removed. 2) They are community led and there is evidence of community consensus in support of the proposal and/or proposals are brought forward as part of the neighbourhood planning process; See comment (c) above. This should also be removed. 3) The proposal delivers local social and community benefits; This is useful in that it distinguishes community-led from commercial developments and can help to prevent a commercial development passing itself off as a community venture. However, more is needed. The purpose of a community development is to deliver local social and community benefits. A commercial development might deliver some small proportion of local social and community benefits, but its main purpose is profit. 4) There are administrative and financial structures in place to deliver/manage the project and any income from it. This is necessary. We consider that Policy RE6 should focus on defining what a community-led proposal means, and what support Cornwall Council can give" 5. (e) Cornwall Council could make its properties available for community groups to develop, say, rooftop solar PV. The community group could raise the development funds, such as through community share offers, and sell the electricity to the building user. The Council should identify a person or persons to be the contact point for community groups wishing to pursue this approach and create a standard, prompt and efficient process for doing it. 6. The community benefit from a commercial installation should be a fixed sum, defined in advance as a condition of planning permission, payable annually and increased by inflation (RPI) each year. It should be for the benefit of defined parishes and towns, within the local area of the installation. The distribution model used in the Wadebridge area is that the local community energy group, Wadebridge Renewable Energy Network (WREN) Ltd, receives the payment and is responsible for distributing it to local community groups, but does not itself determine which local groups should benefit. This is done by local committees defined for each fund. WREN administers the committees, receives the payment and makes the distribution to local groups. There is a well-defined process and an easy to use application form. WREN receives a fee for this work. We recommend this approach. We do not consider a share of profits a suitable method of determining the annual payment. It would be too difficult for a local community to audit the amount of distribution, and too easy for a large organisation to load a local installation with overheads and thus reduce the ostensible profit of the installation. Similarly, we do not consider local community ownership of a minority interest in an installation to be a suitable structure. A minority interest gives no control and leaves the local community open to charges for its share of unexpected costs.


In both of these cases, the local community would be placing reliance on the goodwill of the installation owner, and whilst the current owner might be a known quantity, future owners, if the installation is sold, would not be."

253 1. RE1 - This policy seems very little different to the policies in the Local Plan and is restrictive. There is no mention of support for new technologies as in the local plan. This should be included. Policy RE1 – power provided direct to an end user. When new housing developments (or industrial developments) are being planned: (a) support and prioritise the provision of a heat main / district heating (b) ascertain the possibility of adjacent wind or solar to power the electric boiler (c) set up a community-led managing agent scheme to administer the power supply to households. (d) look at housing orientation so as to maximise solar gain. The bar is set too high in the RE principles section for this kind of approach. It should apply to housing developments larger than 25 dwellings, (not 100 dwellings as stated in the principles) Policy RE1 requires community benefit from renewables installations – do you have any opinion on the form that this should take? Community benefits should be used to fund energy conservation in domestic housing, particularly in the private rented sector where the poorest levels of insulation and draughtproofing are likely to be found. We support Cornwall’s policies that recognise the benefits of providing electricity direct to an end user, rather than putting the electricity into the national grid. Sending power direct to the end user minimises transmission loss and creates local resilience and security of power supply. In line with this policy we suggest that when new housing developments (or industrial developments) are being planned, planning applicants are required to investigate the possibilities of adjacent wind or solar generation. Such generation could then be used to power the heat requirements of a heat main supplying all the houses in the development. This requirement should apply to all proposed housing developments, large or small. RE3 Is the policy map drawn from Neighbourhood Development plans? This is restrictive and an alternative approach needs to be found. It is a climate shame that no new on-shore wind has been granted in the last few years. We welcome the proposed strategy to map sites that are suitable for onshore wind. Identifying suitable sites for wind is important. A restrictive approach to sites will defeat the aim of carbon reduction. For a wind strategy to be successful, suitable sites should be close to appropriate major components of the National Grid. Failure to do this will mean delays while those portions of the Grid are updated. It will be helpful if Planning can recognise that according to all credible measures of public attitudes, the majority of the UK population support renewables including wind. Opposition generally comes from a well organised, vocal, and influential groups who underestimate the negative effects of climate change Energy from onshore wind is an effective and proven technology, producing energy at a price cheaper that derived from coal, oil, gas and nuclear. As such it is an effective way of minimising carbon dioxide as a by-product of electricity production . It is our understanding that current government policy severely constrains the


expansion of onshore wind by putting in place planning requirements that are designed to obstruct it. Time is not on our side in responding to the climate emergency. RE4 The assessment of visual amenity and cumulative affects is still an imprecise tool. Presumption should be in favour of development. (of solar energy installations) RE 5 Minewater / Geothermal How will community engagement be assessed? The Neighbourhood Development Plan is too cumbersome for this. RE 6. What are acceptable impacts of Community led low carbon or renewable energy principles? Some existing are very restrictive. How will this be assessed if no proposal from the NDP? Otherwise support. RE Q5 The planning document asks the question; is there anything that we could do to further promote or enable community-led energy proposals? Community-led energy proposals often come from small groups of individuals who have identified specific, small scale, projects within their own communities. These are valuable but can only contribute a small part of the scaling up of renewable energy that will be necessary to help Cornwall meet its carbon neutral target by 2030. Although small scale, community energy groups: • provide a link back into local communities that cannot be achieved in any other way. inform local needs • can help channel the benefits of renewable energy back into communities in a way that meets with local approval. To retain the benefits of community-led renewables, and combine these with scaling up of renewables, requires the creation of true partnerships between community energy groups and commercial developers. The complexity of moving from concept to realisation, from plan to implementation, is challenging for ‘amateur’ groups ; there is a need for support and coordination of the community energy groups across Cornwall. We therefore ask Cornwall Council to lead the process of setting up a county-wide network in conjunction with community energy groups so that they are supported to partner with commercial developers to implement renewables at scale. "

398 1. These policies make no mention of the potential for tidal energy production (eg bringing the tidal mill pond at Forder back into production) or for micro-hydrogeneration projects at former river mill sites, both of which have potential for carbon-neutral energy production.

064 1. Recognition of the opportunities geothermal and mine water energy could provide in Policy RE5 is welcomed and supported. To achieve the objectives of the plan as a whole there is a need to balance the impacts of a proposal for this type of development on biodiversity and landscape against the benefits of delivering sustainable energy, particularly in the short-lived development stage of a project. In this respect RE(2) should require an assessment of impacts and how they could be mitigated rather than saying there should be no unacceptable impact. It is important that the policies make provision for geothermal energy projects that could serve individual or small developments in rural or semi-rural locations. It should also be noted that appropriate siting should account for the location of the heat resource, which may be very site specific. The policies should also support the


scale of infrastructure required to produce the energy source and recognise that any impacts associated with it would be of a temporary nature. It should be more positive in encouraging the development of geothermal and mine water as a source of energy given is potentially more difficult to assess and appraise and potentially requires greater levels of investment. The development stage would be temporary; production would not be as disruptive or have the same level of physical or visual impact as some other forms of renewable energy. Sources of mine water energy (and/or geothermal energy) may be remote from the developments they could potentially serve due to their historic locations. The policy should make provision for the temporary nature of site development and support the construction of associated infrastructure to deliver energy to the developments they are designed to serve. 3. It is noted the consultation also invites comments on the Sustainability Appraisal for the Cornwall Climate Emergency DPD, albeit there does not appear to be a separate response form. The Appraisal has a section on ‘Renewables (including geothermal and mine water)’. However, whilst there is a subsequent appraisal of options for wind energy and mine water and shafts, there is no distinction between energy from mine water and shafts and geothermal energy; the means of realising such are very different. This part of the Appraisal lacks an understanding of the different sources of potential energy, fails to differentiate between the two and is confusing in its reference to such in both the introductory supporting text and in Table 3.11. It is considered to be fundamentally flawed and should be revisited.

402 3. 3.16 We would request that when reviewing and allocating sites for wind turbine development the Council consider existing businesses and the potential impact of an allocation on these sites. Wind turbines should not be allocated in close proximity to sites where there may conflict with existing developments.

403 2. Policies should cover all types of renewable energy, now and future, (tidal for example) not just the most obvious 3. Should it not be a condition of all new residential and commercial development incorporates renewable energy? Solar panels in car parks for example? 6. Ideally the benefit should be energy related -perhaps priority given to tackling fuel poverty either with cheaper energy or supporting energy saving measures

404 This policy should be re-named to include low carbon energy-generating technologies which should also include individual heat pumps as well as distribution networks. LiveWest have significant experience of installing and managing renewable and low carbon heating systems. We are pleased to see Cornwall’s approach to new residential development and the encouragement of low carbon energy and decentralised energy networks alongside renewable technologies. If used in combination with domestic scale renewable systems, and enhanced fabric performance, heat pumps can be an effective strategy in providing low and zero carbon housing. LiveWest are involved in a communal ground source heat pump development in Bristol and we have delivered several developments using air source heat pumps. For reasons discussed in the Energy section these technologies must be considered after building fabric improvements.


LiveWest have a dedicated renewable technologies team who work closely with our customers to ensure they understand how to operate low and zero carbon systems within their home and enable them to run their homes in a cost-effective manner. Other organisations and private landlords may not be able to support customers in this way and we would encourage Cornwall Council to consider their role in supporting home occupiers in operating these systems. LiveWest would encourage Cornwall Council to consider the potential future use of Hydrogen boilers as a viable and low carbon gas alternative heating system. This is an emerging market however with medium and large-scale trials proposed within other local authority regions it is anticipated that this will form part of the solution in achieving a Net-Zero Carbon economy. RE5 LiveWest agree that Cornwall have a unique opportunity to provide geothermal heating supplied by a district heating system. It is potentially a good solution to decentralise the heat network and provide a long lasting and sustainable heat source. We would encourage Cornwall Council to assess the legal aspects around ownership of mine systems and Mineral Rights as previous experience of developing housing sites on land with historic mine activity has taught us this is a legally complex area that is likely to require public intervention. LiveWest also believe consistency and reliability of supply of heat from mine water needs consideration as the heat pumps rely on supplementary immersion heat provided by electric. This could therefore result in higher energy bills. We would encourage Cornwall Council to consider the viability of delivering a decentralised heat network. Our experience in delivering housing schemes in this manner is that a critical mass, often in excess of 2000 homes, is required in order to ensure that capital costs of this heat network are viable. In most instances where these district heating systems have been delivered there is often a level of public subsidy. Decentralised heat networks are currently an unregulated sector. As a social housing provider, we are focused on supporting our customers and protecting them from fuel poverty associated with rising energy bills and the potential for disconnection in the event of payment default. LiveWest would encourage Cornwall Council to develop policies in order to offer greater protection to customers who purchase properties where district heating systems are present.

163 1. I support the development of renewable energy in Cornwall including new solar and wind energy installations. 3. They should contribute to national or local targets Policy RE1.3 applies only when they are on greenfield land. Renewable energy should be supported first on non-greenfield land such as rooves, car parks, brownfield sites etc (particularly solar). Where they are on greenfield sites, the sites should also be providing some biodiversity or agricultural services. Biodiversity net gain should apply. Appropriate safety considerations should be given to geothermal energy – this requires a process not unlike fracking and all the safety implications should be considered.


6. The council could set up it’s own structure which could be rolled out to deliver community benefits. Have lessons been learned from Community Energy Plus and/or the Wadebridge Renewable Energy Network?

280 "No mention of Heat pumps or Hydrogen or micro-grids Micro-grids Developing energy self-sufficiently by using advanced digital technologies such as smart meters to reduce dependence on energy from outside the area. Micro-grids and virtual energy islands provide independence,encourage the growth of renewables and allow buyers of electricity to financially benefit from the surplus of others. Control of local energy system handed to municipally owned utilities. Hydrogen. We can use surplus renewable electricity for making hydrogen. Hydrogen will come from an electrolyser linked to a community wind farm. We can replace natural gas with hydrogen for heating homes and other buildings. This will require us to replace central heating boilers and adjust cookers, hydrogen is a viable replacement for existing fuels. In large parts of the country the gas network can carry hydrogen and by 2031 this should apply to the whole country as all the iron pipes on the gas network will have been replaced by polyethylene. This will allow safe delivery of hydrogen gas made from surplus electricity generated at times of excess renewables. Heat pumps They can be remarkably efficient and looks like the easiest way to cut carbon emissions from home heating and is recommended by the Uk government’s advisers at the committee on Climate change. In well insulated homes heat pumps are the logical choice. Problems are lack of skilled installers combined with poor home insulation and usually require replacing all radiators in a house - it would be simple to switch to hydrogen boilers. Hydrogen-ready boilers ie operating initially on natural gas with conversion to hydrogen at a later date. Other European allow 20% mix of hydrogen and natural gas. Insulate homes so well that they use virtually no energy Energiesprong a Dutch company that carried out work the Nottingham refurbishment is now converting 1,000 homes in the Netherlands each year. Control of local energy system handed to municipally owned utilities."

109 The protection and policy requirements already afforded to designated landscapes must not be diminished by this. The use of community energy networks should be more forcefully required for larger developments such as Langarth. Policy RE2 should be extended to consider the exclusion of other development within areas close to renewable energy installations or potential installations that would constrain such renewable development – for example housing within a distance that might give rise to limits on the renewable capacity as a result of the noise requirements of ETSU-R-92. Cornwall needs to consider if it would accept


compulsory purchase of assets that were a notable constraint to renewables to liberate the resource. Policy RE3 is conspicuously missing AONBs of bullet point 2 of item 3 Policy RE4 does not specifically refer to AONBs which should be included point 4 of the policy wording is inadequate given the protection afforded to AONBs Policy RE5 does not specifically refer to AONBs which should be included point 2 of the policy wording is inadequate given the protection afforded to AONBs Policy RE5: Does Cornwall have the infrastructure required to process the waste production from geothermal/ mine water? Would developers proposals need to demonstrate the nature of this process will not have a polluting detrimental effect on water quality and indirect effects on natural processes and wildlife beyond the boundaries of the proposal.

405 There is a sense that much attention in this document is given to “heritage” and not a lot to “fossil fuels”, the use of which we clearly need to tackle in order to work towards becoming carbon neutral by 2030.

292 1. In general, a resounding Yes. These are the best worded policies in my opinion. If it appears that Cornwall is on the cusp of an energy revolution with the exploitation of geothermal plus the processing and utilisation of lithium resources then the future in this area could be very bright indeed. I would urge the Council to seek the expert opinions of experienced mining engineers still resident in the County. I have spoken with several and they are genuinely excited about these developments but always with certain provisos. For example the United Downs exploration is reputed to have the potential of energy availability the equivalent of four nuclear power stations but I’ve heard comments about lack of access to core samples for geologists to analyse. 5. Yes, there isn’t any mention of the exploitation of the incorporation of biodigestors. These could be beneficial in reducing the carbon footprints of farms plus at the community level could be fed with green waste. 6. A trip to a local recycling centre could reveal there is not a great deal of actual recycling. For example I’ve been informed that the contents of the timber skips go to a facility near St Austell for chipping and from there ship to Scandanavia for energy generation – is the County not missing an opportunity here?

097 3. The limiting of new onshore wind schemes to sites that have been pre-identified is too restrictive and should be relaxed in the case of community led scheme applications. 5. Encourage the formation of community energy networks(see below.) 6. This requirement is an excellent policy. One approach to this is the Section 106 type of contribution to the community. There is a place for this but other approaches are important. Community energy networks can facilitate shared ownership schemes and also energy trading among private schemes. These can be mutually beneficial for all concerned and are starting to be encouraged by the energy network providers. They also have the potential for the alleviating of energy poverty.

407 1. The use of surplus power for “Hydrogen back up” and transport use should be considered


3. There should be consideration of the results of the existing “direction of power flow within the grid” to avoid the situation that has developed in Scotland where renewable power is dumped (but still paid for) as the system was designed for power to areas rather than power from areas. 5. Simplification of the process for funding such a system. 6. Suggest any surplus income “profit” be ringfenced for community projects or reduction in community costs e.g free power to community buildings such as libraries.

408 1. "Yes generally, although we feel that there needs to be greater emphasis on the following points: RE4, 1 – “heritage assets will be conserved, in a manner appropriate to their significance, including views important to their setting.” RE4, 4 – “there will be no unacceptable impacts on biodiversity and landscape including cumulative impact” RE5, 2 – “There will be no unacceptable impact on biodiversity and landscape” RE5, 4 – “Impact on visual amenity is minimised” RE5, 5 – “Community engagement has been undertaken and the proposal takes into account any issues raised.” RE6, 4 – “There are administrative and financial structures in place to deliver/manage the project and any income from it. 5. There should be a standard question included in all planning applications asking what energy related benefits will come out of the scheme. 6. There should be a range of benefits; it should not be limited to one type.

410 6. "Wainhomes response: Policy RE1 states that all major development proposals should seek to integrate low carbon energy and decentralised energy networks into the proposal. It also states that proposals for development of more than 100 dwellings or non-residential development of over 1,000sq.m will be expected to consider the integration of community energy networks in the development, taking into account the site’s characteristics and the existing cooling, heat and power demands on adjacent sites. In response, further detail is required as to what this would entail, and what the implications would be in terms of viability and delivering the sites identified within the adopted Local Plan, including windfall sites."

411 2. The approaches to wind, solar and geothermal are about right. However, should there also be policies for hydro. Ie. micro hydro, pumped storage (clay pits), tidal energy (Truro’s new riverside development, Hayle, Padstow, Fowey, Helford) There is also potential here to protect these towns from sea level rise. 3. I think that a condition of planning permission for dwellings but especially for factory/out-of-town shopping facilities, should be to have solar PV panels installed. This should also include covering car parking facilities with PV panels. These coverings could also provide shading and rainwater harvesting helping to reduce runoff from the car park. 6. In 17.9.3 it was suggested that possibly additional guidance on community-led energy schemes would be provided. I am sure this would help get schemes started.


265 3. RE1 states that proposals for mechanical and battery storage will be supported. However the policy could be more explicit in stating that battery storage projects are considered to be low carbon energy projects. There is evidence from other localities (for example East Devon) of storage projects being refused planning permission at Committee stage as they are not clearly considered to be low carbon projects. See https://www.regen.co.uk/wp-content/uploads/Planning-for-a-Smart-Energy-Future-final-published-report.pdf for more details. RE1.5 and RE6.5 state that evidence of ‘community consensus’ would be required for community projects. The nature and degree of what is meant by ‘consensus’ is currently ambiguous and we suggest that future documents should expand on this term for clarity. RE2 point 1 currently suggests that non-renewable generation resources would still be acceptable on a more permanent basis in certain circumstances. We suggest that this holds potential to undermine carbon reduction targets and should therefore be removed. 4. As an alternative we suggest tightening the criteria of RE2 - restricting this to temporary permissions only based on the principle of last resort (i.e. permissions only granted where all renewable options are unfeasible within an allotted timeframe). Where permissions are granted we suggest that these are paired with a regular review process that holds powers to revoke permissions once renewable alternatives become feasible. 5. The focus of the community energy section appears to implicitly focus on models that involve community ownership of renewable generation technologies. This is by no means the only model of community-focussed projects and the Council should not foreclose avenues for supporting projects within the wider ecosystem of distributed energy resources (DER) or service models. It would be helpful if the DPD explicitly indicated support for a wider range of models - that could for example include energy storage or flexibility services. The work of Carbon Co-op (https://carbon.coop) and REScoop (https://www.rescoop.eu) may provide good case-studies in this area. We would be happy to provide additional evidence or speak with the Council on required to deepen understanding of alternative community energy models. 6. The DPD already notes financial benefit. It may also be useful to explore benefit in terms of data resources and research/educational potential. For example, there may be opportunities to partner with universities, research institutes, schools or companies in order to explore where project data could be used to develop auxiliary products or services that support community need. The Isles of Scilly Community Venture EV car-share project provides one such case study where there is potential to link renewable electricity generation with both car-pooling and wider grid services (e.g. vehicle-to-grid storage dispatch). https://www.ioscv.co.uk/carshare"

329 1. I would add a need to support individuals and communities to have small scale renewable infrastructure where they live. For example co-housing models to have solar panels as standard and small wind turbines to power the needs of their project. This would potentially need advice and financial support but particularly with low visual, impact could provide the power needs of people throughout Cornwall. "


6. Consultation, transparency, pro’s and cons, doing “with” the community not “to” the community

276 5. Literally ask communities if this is something they would like to do, dress it up a bit, educate them on the pros of self-sustaining energy, give them the confidence to take on the task and fully support them throughout. (this is a really exciting opportunity!)

412 Is the policy map drawn from Neighbourhood Development plans.? This is restrictive and an alternative approach needs to be found. We have no NDP.

413 1. facilitate the installation of off-shore wind farms. 2. RE1 Require the installation of batteries (rather than support). Admire ambition of RE6 but smaller parishes and towns need expert financial and technical support in order for this to be achieved. 4. All new development should have solar roof tile panels to harvest energy, all new developments should have LED lighting installed as standard. 5. CC to enable communities to buy the land necessary. 6. The immediate community should benefit – via energy discounts, community shares, benefits being distributed by the Parish/Town Councils for the parish/town

264 1. Cornwall CLT welcomes the above proposals

095 6. This is a good plan. Please keep small-scale renewable energy proposals put forward by cohousing communities really simple, ideally so that all systems below a certain size are permitted development, please.

114 1. Policy RE1, Paragraph (4), of the DPD provides that a renewable energy distribution network will be supported if it provides a community benefit in terms of profit sharing or proportion of community ownership. That would mean that satisfaction of such community benefit consideration would be a material consideration to be undertaken by Cornwall Council in determining whether to approve an application for planning permission for a wind turbine. However, it is well-established law that the provision of a general community benefit fund does not qualify as a “material consideration” under the Town and Country Act 1990, as amended. This is because the law requires that planning permission cannot be bought and sold, and as a result, a planning condition must serve a legitimate planning purpose, meaning that it must be fairly and reasonably related to the proposed development. See, for example, Wright v. Resilient Energy Severndale Ltd and Forest of Dean District Council, Supreme Court, November 20, 2019 (link to case attached). In that case, the Supreme Court confirmed that (a) the provision of a community benefit fund was impermissibly taken into account as a consideration in the District Council’s determination to approve a wind turbine application, and (b) the community benefit fund did not qualify as a “material consideration” under the Town and Country Act 1990, as amended. As a consequence, RE1, Paragraph (4) of the DPD could be construed to be invalid as being contrary to law. In any event, that policy could at a minimum be reasonably expected to be subject to legal challenge in the context of a specific application, thereby burdening Cornwall Council with mounting a costly legal defence.


https://www.bailii.org/uk/cases/UKSC/2019/53.html 6. In addition, while we recognize that the DPD envisions the designation of specific areas as suitable for wind turbine development, Cornwall’s DPD, RE1 – RE6 should more proactively encourage that any future installations of on-shore wind turbines and solar farms be limited primarily to already industrialised and blighted areas, as opposed to encouraging siting new installations in areas that are not easily accessible from major highways or possess rural beauty and do not already have a proliferation of these installations. Because Cornwall already has many corridors of large wind farms that are easily accessible from major highways, this suggested policy should not inhibit development. Further, it would be more efficient in terms of construction and maintenance to have a large number of such installations sited in one place, close to and easily accessible from highways. In furtherance of the Cornwall Local Plan: Strategic Policies, Policy Number 23 (Natural Environment), Cornwall’s DPD, RE1 – RE6 should more clearly discourage the installation of one-off wind turbines and solar farms in rural areas that are not easily accessible from major highways or possess rural beauty and do not already have a proliferation of these installations. In addition to the purely aesthetic policy-based reasons against such developments in such rural areas, other policy-based reasons include the following: 1. Such developments in the very recent past proved to have been very unpopular in rural communities and thus required expending a disproportionate amount of time and money relative to the potential electricity capacity added, by local communities in seeking to stop such developments, by developers in seeking to obtain planning approval and dealing with appeals, and by Cornwall Council in dealing with the highly contentious planning permission process and appeals. Creating a policy which could cause a return to such a large scale waste of resources by all involved would ultimately prove counter-productive and would be in no one’s interest. 2. Wind turbine and solar developments on rural agricultural land could have an adverse impact on farming and food supply. Developers have frequently used agricultural land of high quality for renewable energy projects. As the UK's transition period for leaving the EU is about to end in less than 4 months, most likely without the benefit of a trade deal, it is more important than ever that as a country we make sure that there is enough agricultural land that is safeguarded for food production. The current COVID-19 pandemic has also highlighted the importance of food security and having the means to avoid shortages of food. 3. Inappropriate and widespread wind turbine development, particularly in rural areas possessing natural beauty, could have an adverse effect on tourism, which is obviously a major and crucial industry for this county. 4. Such developments can cause disruption to local residents as the delivery of the construction materials and crew and maintenance of the developments can cause the clogging of narrow, winding country lanes. 5. Such developments are much less efficient in terms of the amount of construction, cabling and connections, as opposed to siting the developments in areas that have already been developed as wind farms or solar farms. We ask that Cornwall Council take into account these considerations in developing its final DPD.


In addition, while we recognize that the DPD envisions the designation of specific areas as suitable for wind turbine development, Cornwall’s DPD, RE1 – RE6 should more proactively encourage that any future installations of on-shore wind turbines and solar farms be limited primarily to already industrialised and blighted areas, as opposed to encouraging siting new installations in areas that are not easily accessible from major highways or possess rural beauty and do not already have a proliferation of these installations. Because Cornwall already has many corridors of large wind farms that are easily accessible from major highways, this suggested policy should not inhibit development. Further, it would be more efficient in terms of construction and maintenance to have a large number of such installations sited in one place, close to and easily accessible from highways. In furtherance of the Cornwall Local Plan: Strategic Policies, Policy Number 23 (Natural Environment), Cornwall’s DPD, RE1 – RE6 should more clearly discourage the installation of one-off wind turbines and solar farms in rural areas that are not easily accessible from major highways or possess rural beauty and do not already have a proliferation of these installations. In addition to the purely aesthetic policy-based reasons against such developments in such rural areas, other policy-based reasons include the following: 1. Such developments in the very recent past proved to have been very unpopular in rural communities and thus required expending a disproportionate amount of time and money relative to the potential electricity capacity added, by local communities in seeking to stop such developments, by developers in seeking to obtain planning approval and dealing with appeals, and by Cornwall Council in dealing with the highly contentious planning permission process and appeals. Creating a policy which could cause a return to such a large scale waste of resources by all involved would ultimately prove counter-productive and would be in no one’s interest. 2. Wind turbine and solar developments on rural agricultural land could have an adverse impact on farming and food supply. Developers have frequently used agricultural land of high quality for renewable energy projects. As the UK's transition period for leaving the EU is about to end in less than 4 months, most likely without the benefit of a trade deal, it is more important than ever that as a country we make sure that there is enough agricultural land that is safeguarded for food production. The current COVID-19 pandemic has also highlighted the importance of food security and having the means to avoid shortages of food. 3. Inappropriate and widespread wind turbine development, particularly in rural areas possessing natural beauty, could have an adverse effect on tourism, which is obviously a major and crucial industry for this county. 4. Such developments can cause disruption to local residents as the delivery of the construction materials and crew and maintenance of the developments can cause the clogging of narrow, winding country lanes.

415 6. This is a good plan. Please keep small-scale renewable energy proposals put forward by cohousing communities really simple, ideally so that all systems below a certain size are permitted development, please.

417 The JLP councils support the proposal to identify suitable areas for wind energy, and would encourage any evidence base study to consider the potential landscape


impacts of identifying areas for onshore wind development beyond the Cornwall - Devon border.

421 6. Generally good. Aim to encourage small-scale and resilient projects, and promote local skills and enterprises.

243 1. Yes. No mention of marine renewables (wave/tidal power).

056 2. As set out in the response to Policy C1, planning policy needs to be guided by a fundamental principle of achieving the legally binding UK target of net zero by 2050 and the interim carbon budgets. Cornwall has an objective of net zero by 2030. To achieve this Cornwall needs to establish a set of transition pathways with targets for renewable energy (possibly technology specific), energy efficiency and carbon sequestration. These pathways and targets should be informed by citizens forums. Progress against these targets needs to be measured, and the balance between them adjusted if necessary. The planning considerations for renewable energy development as listed in RE1 - 5 are well established. Renewable energy planning policy should continue to apply these considerations to guide the best possible locations for renewable energy development, within the overarching principle that the targets must be achieved. 3. RE1.5 states ‘For community-led proposals there is evidence of community consensus in support of the proposal’. Community consensus is not required of commercial developments so this sets a higher bar for community schemes than commercial schemes. Positive planning weight for community schemes should be based on compliance with a robust definition of community energy (see below) and the economic and social benefits delivered by the project, not consensus. Public responses to the statutory consultation process for community schemes should be considered in the same way they would for commercial schemes. Policy RE2 - Safeguarding Strategic Renewable Energy Sites is positive. 5. •Set a target for at least 50% of the new renewable generation capacity to be community-owned by 2030. •This may include shared ownership for larger schemes. Community shared ownership share is not about offering individuals the opportunity to invest in a commercial project. It should be by a locally based, not-for-profit community organisation with appropriate community benefit purpose, governance and legal structure. •Set a policy for community organisations to have the right to have first option or a right to bid existing renewable energy generation projects above 1MW when they come up for sale. •Set a policy for community organisations to have the right to have first option or a right to bid on public land to develop renewables projects. A robust definition for community energy Policies to support community energy need to underpinned by a robust definition of what community energy is. The definition needs to be flexible enough to enable a range of good models whilst safeguarding against abuse. The definition could include: Essentials:


•Ownership of the asset by a community energy enterprise with an appropriate legal structure (i.e. community benefit society, community interest company, co-operative, charity or council) and an asset lock; •The community energy enterprise should be governed by a board of local volunteer directors, but may be professionally managed; •The community energy enterprise should be set up to serve a local community purpose which could include supporting local net zero transition initiatives, tackling fuel poverty and supporting local community organisations and services; •The definition of ‘Local Community’ may be Cornwall-wide or local to the project; •A business model which enables surplus income to be generated over the life of the asset which is in excess of community fund payments that would be paid by a commercial development. Optional: •Community participation in the ownership and governance of the organisations through £1 ‘one member one vote’ shares; •A community share or bond offer which enables people to invest in the project, therefore retaining some of the cost of finance in the local economy; •A local energy supply arrangement that enables local energy consumers to purchase the energy generated. 6. The best community involvement and benefit will be delivered by community-led, owned and controlled projects, including partnerships with commercial developers on larger schemes. This is illustrated by the table below which shows the community benefit funds delivered by the community solar projects CfR has supported. At the time these projects were developed, commercial developments were paying up to £5,000 per MWp per year in community benefit payments, and some significantly lower.(See supporting info)

189 3. "Draft Policy RE1 identifies that proposals for renewable and low carbon energy generating and distribution networks will be supported where they “…will not result in adverse impacts on the local environment that cannot be satisfactorily mitigated, including cumulative landscape and visual impacts, and the special qualities of all nationally important landscapes, heritage assets including their setting which must be conserved or enhanced”. There is no reference to ensure proposals do not have adverse impacts on the amenity of sensitive neighbouring or nearby land uses, such as tourism and/or tourist accommodation sites. Given the value of tourism to the Cornwall economy, we consider that such a reference needs to be included. This would also be consistent with the approach taken for draft Policy RE3. Adverse impacts on the amenity of tourism and accommodation sites could result in a decline in their success as visitors are deterred and decide to travel/stay elsewhere. This would have consequences for jobs, supplier expenditure and visitor spending. On this basis, we propose that draft Policy RE1 is amended as follows (proposed new text in bold): “…will not result in adverse impacts on the local environment that cannot be satisfactorily mitigated, including cumulative landscape and visual impacts, and the special qualities of all nationally important landscapes, heritage assets including


their setting which must be conserved or enhanced, and, the amenity of neighbouring land uses (particularly sensitive uses such as residential and tourist accommodation)”. "The requirement in draft Policy RE3 for proposals for wind energy to ensure no adverse impacts on ‘neighbouring land uses’ is supported. However, we request clarification in the policy or supporting paragraph wording that this includes all uses including tourist accommodation sites. Policy RE3 states that wind energy development proposals will be permitted where they are located in a ‘suitable area’ identified on the Policies Map. Designation of these areas is not currently available. These areas need to be identified and included as part of the consultation on this emerging DPD as it is not possible to comment on whether the approach set out in draft Policy RE3 is appropriate. Part 2 of draft Policy RE4 identifies that impact on visual amenity and neighbouring uses is ‘minimised’. We disagree with this approach and the emerging policy should be worded to ensure there are no unacceptable adverse impacts. ‘Minimising’ impacts on amenity is subjective and does not provide certainty that neighbouring uses will not have their amenity adversely impacted. Draft Policy RE5 should clarify that proposals should demonstrate the five requirements in relation to both the proposed below and above ground infrastructure required for such development. In addition, and consistent with draft Policy RE4 and our comments on draft policy RE5, there is no reference to ensure proposals do not have adverse impacts on the amenity of sensitive neighbouring or nearby land uses, such as tourism and/or tourist accommodation sites. Given the value of tourism to the Cornwall economy, we consider that such a reference needs to be included. As set out for draft Policy RE1, adverse impacts on the amenity of tourism and accommodation sites could result in a decline in their success as visitors are deterred and decide to travel/stay elsewhere. This would have consequences for jobs, supplier expenditure and visitor spending.

423 We note this policy sets out a proposal to agree “suitable areas” for wind turbines, which is a shift from Policy 14 in the Cornwall Local Plan that says sites will be allocated for wind turbines in Neighbourhood Plans. A number of renewal energy schemes have already been delivered in our parish (including five large wind turbines and three solar farms, which together have an installed capacity in excess of 20 mW). We did not explore the possibility of an allocation or allocations of land for turbines in the Neighbourhood Plan, as we had not received any requests from landowner for this. We did however state that if landowners “in the future” wished to put forward proposals for wind energy “the Parish Council will consider a revision or addendum to this Neighbourhood Plan.” This remains our position and councillors consider that if areas for wind energy are to be agreed in St Enoder Parish, it should be done by the community through an addendum for the Neighbourhood Plan.

019 Historic England recognises the importance of climate change mitigation and adaptation as part of building resilience for the historic environment. We offer information and advice on many related topics including the installation of renewable energy generation in historic buildings and traditional homes, as well as


commercially. We believe that energy efficiency, sustainable technology and reducing carbon emissions are compatible with the conservation of our heritage. Historic England notes from paragraph 17.2.1 of the Introduction that new wind energy development sites need to be identified as suitable in the Local Plan and/or neighbourhood plans. We are uncertain as to what the Council’s intended approach in relation such allocations, taking into account the explanatory text for Policy 14 in paragraphs and 2.96 2.94 of the adopted Local Plan and the information in paragraphs 17.5.1 and 17.6.3 of this DPD. We would welcome further information on this point. Our key concern in relation to the allocation of sites for all types of renewable energy in development plan documents is to ensure that site selections are informed by proportionate heritage impact assessments for all potential sites. These should identify affected heritage assets and their settings, as well as wider townscapes, landscapes and seascapes, and then consider how alternative options could first avoid, then minimise and mitigate any negative impacts on their significance. We also note from that the following renewable energy policies will replace Policies 14 and 15 in the adopted Cornwall Local Plan: Strategic Policies. Policy 14 contains criteria that require impacts, including cumulative impacts, on the World Heritage Site and other heritage assets and their settings, as well as on some landscapes and undeveloped coast, to be considered with direction to other relevant policies in the Plan. Our key concern is to ensure that the replacement policies also contain adequate requirements for the conservation and enhancement of the historic environment and wider townscapes, landscapes and seascapes. As you will from the comments below, we do not consider this to always be the case. Policy RE1 Historic England welcomes the intent of Policy RE1 and we support criterion 2). We consider that this criterion would benefit from minor change to reference the World Heritage Site and wider townscapes, landscapes and seascapes. Policy RE2 We note the intent of Policy RE2. We note from paragraph 17.5.1 that areas are intended to be identified as suitable for large scale, strategic renewable energy installations in the DPD. Further to our comments above, we seek assurance that this allocation process will be informed by proportionate heritage impact assessments for all potential sites. Policy RE3 We note the intent of Policy RE3 and support the inclusion of criterion 3) and the bullet points related to the historic environment, landscape character, and cumulative impacts. However, we consider that the wording of the first bullet point would benefit from broadening to reference townscapes and seascapes in addition to landscapes and the ‘built and historic assets’ are replaced with ‘heritage assets, including their settings’. We also note the intent to identify suitable areas for wind energy development. Further to our comments above, we seek assurance that this allocation process will be informed by proportionate heritage impact assessments for all potential sites. Policy RE5 We note the intent of Policy RE5 and support the inclusion of a criterion that requires proposals to demonstrate that heritage or historic landscape issues are addressed, noting the presence of the Cornwall and West Devon Mining Landscape World Heritage Site. We consider that the wording of this criterion


would benefit from being amended to set out more explicit information and policy requirements. For example, an appropriate Statements of Heritage Significance and Heritage Impact Assessments should be provided (where relevant), which will need to consider the impacts on the significance of heritage assets, including their settings, including the outstanding universal value of the World Heritage Site. It will also need to consider the impacts on archaeology and the potential impacts of any changes to hydrology on the any buried archaeological and palaeoecological resource including in adjacent wetland areas including floodplains and peatland. Programmes of base level recording and on-going monitoring may also be needed. The requirement should also seek to first avoid and then minimise and mitigate any negative impacts as well compatibility with the World Heritage Site Management Plan. Further information can be found on our website. Policy RE6 We do not wish to comment on Policy RE6 except to say that we hope that the additional guidance that is to be provided will direct communities to consider the potential impacts on the World Heritage Site, heritage assets and their settings, as well as townscapes, landscapes and seascapes and find ways to avoid, minimise and mitigate any negative impacts.

168 1. We ask that biofuel proposals that will need feedstock from other holdings are assessed very carefully as mentioned previously. Large-scale biofuel plants can have an impact on the land use across large areas and this can lead to soil loss and associated increase in carbon emissions. We have seen this with increased maize growing around existing large-scale biodigester sites in Cornwall.

354 100% support for these proposals. To quote from correspondence with our local MP on behalf of Transition Groups in Truro and Falmouth asking for her support for the Power for People Campaign.... ""the message is clear : the Local Electricity Bill, if made law, would empower community energy groups across the country to sell their clean energy directly to local people. This would unlock the huge potential for more local renewable energy generation: simultaneously strengthening local economies and tackling climate change We urge Cornwall Council to lend their support for this campaign. More details can be found at https://powerforpeople.org.uk/the-local-electricity-bill/support/ The one omission relates to unavoidable food waste. Transition Falmouth supports the forthcoming kerbside collection service, but believes that this waste, together with commercial food waste, could be processed here in-county through anaerobic digestion, thus creating a genuinely renewable energy resource and a useful fertiliser by-product. This would also reduce food waste miles and contribute to achieving reduced carbon emissions. It is understood that this is an aspiration and appears in Cornwall's Climate Action Plan, so maybe this could also feature in the finalised CC Planning Document. There is much more that could be added under the other key headings in your document, but the above represents, for me, some of the current topics of immediate import. Our documents mentioned at the head of this piece contain a summary of all the key themes of concern to Transition supporters as we continue to focus on initiatives which would aim to address climate change, by reducing reliance on fossil fuels, conserving natural resources and by working towards a low carbon and circular economy.


One final suggestion....... is that all planning applications should be subjected to an initial climate and biodiversity impact assessment before they are allowed to proceed further. If carbon neutrality and biodiversity net gain is to be achieved by 2030, and continue beyond that date, carbon and nature impacts, and any mitigation deemed essential, will need to be addressed and agreed as a priority issue.

10. Proposed Policies Energy and Sustainable Construction

SC1 - Energy and Sustainable Construction SC2 - Protecting Natural Carbon Storage


1. Do Policies SC1 and 2 pick up the right issues for sustainable construction – are there anymore that you would add? 2. Are the policy approaches that we are suggesting in policies SC1 and 2 about right – is there anything missing? 3. Do you have specific comments to make about the content or intentions of policies SC1 and 2? 4. do you have an alternative approach to Policies SC1 and 2 that you think the council should consider? 5.Do you think that a Sustainable Development Checklist covering categories including energy, water, materials and waste, resilience, health and wellbeing with different requirements for different sizes of development proposal should be introduced? 6.Should development proposals be required to conform with an external standard such as BREEAM or a bespoke requirement made up of elements of the former Code for Sustainable Homes?

URN Comments 355 1, Yes, absolutely crucial to get construction to adopt better energy standards from the

very beginning. New builds should use the best available technology to achieve the highest energy standards possible. Retrofit is much more expensive from a societal perspective. 5 & 6, Yes

360 SC1.Domestic renewables, ie, Solar panels. Why aren't solar panels included with all new builds where appropriate. I note on the new development at Quintrell Downs, Duchy development. This doesn't appear to have any solar panels is there a reason for this? Does Prince Charles have objections? 5.2.Recycling of waste should be even more promoted with penalties for non compliance.

364 SC 1 – 2 This all looks OK in theory, but in practice it is unworkable. To start with property has to be built correctly of some sort of rock, Which does not burn. The modern property is being built just as it was built in the 15th and 16th century of wood and burnable coverings. And, just as it did then, it will all burn down very easily. As then, it is


making a few crooks a great deal of money, whilst at the same time killing a great many innocent people, because of the dangers, in the contaminates in the products that the property is being built from.

367 I believe these Policies cover important issues and principles. Members of the Public would like I believe to see clearly the chain of accountability, monitoring, enforcement and responsibility for explaining how policies are monitored and put into practice

363 1. Policy SC1. The less carbon positive your dwelling the lower rates it pays, how hard is that? Include recycling water and sewage. Include solar water heating. New development make sure Gas network is available. Make sure car charging included. SUDS required. Not just water harvesting, what is done with it? Send it down the sewer, Nul Points. Use on a garden, use for car washing, fishponds, get rates discount. Of course the reality is that those who don’t do these things get charged more rates but sell it as a discount more easily. 33 Policy SC2. No idea what this means. Is it using wood in construction? Build things out of lumps of coal? Plant more trees? That I understand. What is a major development? Needs definition. 3. Yes, SC1-5 seeks to prioritise the use of previously developed land and buildings. In practice the local authority seems powerless to make developers use brownfield sites if they don’t want to. At present the system is developer led, not planning led. 4. Yes, make planning proactive and not reactive. 5. Yes. 6. We prefer a bespoke tailored approach. BREEAM is a start point but it should be tailored and adapted to the site and usage of the development.

032 1. 18.1.3. In the UK, fuel poverty is defined by the Warm Homes and Energy Conservation Act as: “a person is to be regarded as living "in fuel poverty" if he is a member of a household living on a lower income in a home which cannot be kept warm at reasonable cost”. So, it’s little wonder that Cornwall’s figure is higher than the national average given its relatively low average wage. The paragraph is misleading in that for new buildings, it is probably mainly – if not only – affordable or other social housing that will help people come out of fuel poverty. New open market homes are generally most likely to be sold to those with sufficient capital and income not to be in or fall into fuel poverty. 2. 18.1.5. We don’t like carbon offsetting. If a development is going to “pollute” by being responsible for excess carbon emissions, then it must be upgraded or not carried out. If it falls within the lawful standards of construction, then it should not be penalised. Development should not be allowed to pay for polluting: that is akin to the mediaeval practice of buying indulgences to as payoff for sinning. Either the market pays the full price or public subsidy increases for social housing. 3. It is noticed that “rewilding” suddenly seems to come into play here (again, no definition or suggestion of consultation: surely essential). 4. 18.2.5. As far as Building Regulations go, it is suggested that national standards are preferable to local standards – if only for certainty in the mind of house purchasers, lenders, builders, designers, insurers and so on. More important, should we not be pressing to take responsibility for compliance with Building Regulations back into the hands of local authorities. In any event, this is a document about planning policy not building regulations or construction details. Therefore, how will planning issues and building construction detail interface in the consideration of planning applications? What level of evidence or


undertaking will be required to gain a planning permission? Will the planning permission contain standard conditions on this subject? 18.4.2. Many old terrace stone wall cottages are owned by families on lower than average incomes. It would be unjust, as well as unnatural, to attempt to employ planning conditions to compel wall or other insulation when extensions or conversions are being carried out except in those parts of the structure directly forming the new work.1 Energy - New Development It seems wrong to seek to impose standards of construction beyond national requirements and particularly inappropriate in a county which has one of the UK’s lowest average earnings per head. This could lead to severe impairment of new housing and improvements to existing stock to the detriment of targets in the Cornwall Local Plan. It will impact disproportionately on low income households and fail to address social justice. Parts 1.1 and 1.3 of the Policy are objected to. The weighting given in paragraph 2 of the Policy (Energy – Existing Buildings) should not be to the detriment of other factors where the health and well-being of the occupants are a major reason for the development proposal, or where the additional work to the existing structure would unduly limit or restrict its utility, or where the costs are so high in addressing issues within the existing structure (given the applicant’s financial position) that the whole project is rendered unviable. With global warming, emphasis should be placed as much on ventilation and air conditioning as heating. Water: Is the metric of litres of water per person per day the most logical? Should it not be per habitable room? After all, a 3-bedroom home may house between 1 and 6 persons at varying times of its life. In addition, is the standard applied appropriate if a) more people work from home and b) weather patterns change to increase risks of dehydration and rainfall decreases? The national target is 125 litres of water per day: why, again, does Cornwall need to be different? The general issue of sufficient water to cope with possible drought as a consequence of climate change continues to be ignored, as it was in the preparation of the Local Plan. Is there not a case for planning options for another reservoir in Cornwall and/or a desalination plant(s)? With Cornwall’s extensive coastline, desalination must be an option to consider. Materials and Waste: Seems OK."

378 1. Yes 2. Yes 3. See our responses to RE 1-6 above. The aspiration for Cornwall should not be to achieve carbon neutrality but should become carbon negative. The is an urgent need to reduce atmospheric carbon dioxide content as fast as possible. 4. See our responses to RE 1-6 above. The aspiration for Cornwall should not be to achieve carbon neutrality but should become carbon negative. The is an urgent need to reduce atmospheric carbon dioxide content as fast as possible. 5. The larger the scale of development the greater will be the opportunity for community energy schemes. Larger developments should be required to incorporate such schemes. 6. Any standards developed should equal or exceed BREEAM standards.

053 Regarding the fabric first approach: We would welcome an explicit requirement for the use of low-carbon materials, and specifically sustainably sourced Uk. timber, in buildings. Using sustainably sourced locally grown timber is an effective way of locking up carbon while supporting sustainable forestry to respond to the Uk. 19% woodland cover target advised by the Committee on Climate Change to reach Government targets. The Climate Change Committee has recently produced several useful reports on this issue including: Wood in Construction in the U k.; and Uk. housing: Fit for the future? Building on their recommended national target (that 40% developments should have timber frames), the Council might consider adopting a similar, or more ambitious, target. A recent example from South Somerset's Local Plan (submitted to Inspector) reads: '14:48: ... The procurement of locally grown timber products to the Uk Woodland Assurance Standard (Uk.WAS) should be supported, in particular in relation to development, in order to achieve improved sustainability of construction and in support of


local supply chains.' We strongly welcome Policy SC2 and the requirement of Carbon Storage Calculations that show the difference between the carbon storage capacity of the pre and post development habitat on the site (with any loss of carbon compensated). As mentioned above this is separate (but related to) Biodiversity Net Gain. We welcome these remaining separate requirements, to avoid confusion (and conflation), while promoting the integrated support of strategic natural climate solutions that strengthen the Nature Recovery Network.

383 Sustainable should also mean designing out crime which reduces carbon footprint in the long term (18.1.6) To ensure homes meet requirements to ensure crime is designed out and carbon costs are reduced, should require all homes to meet SBD Gold – this is above the requirements of Building Regulations (Part Q). (18.2.4) and ensure bot the layout and physical security of developments and/pr buildings are assessed by Police DOCOs Reduce impact of carbon cost of crime, increase resilience and sustainability – all achieved through SBD/ CPTED (Crime Prevention through Environmental Design Principles (18.4.5) Policy SC1 Provide evidence that the development has been designed to meet the requirements of SBD Gold Award. This covers both the site layout and physical security standards

385 1. Policy SC1.1. Why should only development proposals for 10 or more dwellings and non-residential development with a floor space of 1,000 m2 or more be required to submit an Energy Statement that demonstrates the three points in this section. Surely every new building should comply with these requirements, especially if carbon zero is to be reached by 2030. Cornwall does not need large new developments and certainly most new building in rural areas like Pendeen is on a small scale, usually infill of two or three houses. We need strong and consistent insistence from the Council that all future housing be carbon neutral and sustainable. We also need an increased focus on bringing existing housing up to a better standard in order to achieve warmer, drier homes with lower emissions. 2. Policy SC2. It would be helpful to define what a ‘major development’ is. How will the Council make sure that offsetting, because of loss of carbon storage, will not be used as an easy way out for developers, rather than actually addressing site biodiversity and carbon storage needs?

034 1. 18.1.5. We don’t like carbon offsetting. If a development is going to “pollute” by being responsible for excess carbon emissions, then it must be upgraded or not carried out. If it falls within the lawful standards of construction, then it should not be penalised. Development should not be allowed to pay for polluting: that is akin to the mediaeval practice of buying indulgences to as payoff for sinning. Either the market pays the full price or public subsidy increases for social housing. It is noticed that “rewilding” suddenly seems to come into play here (again, no definition or suggestion of consultation: surely essential)."

2. Water: Is the metric of litres of water per person per day the most logical? Should it not be per habitable room? After all, a 3-bedroom home may house between 1 and 6 persons at varying times of its life. In addition, is the standard applied appropriate if a) more people work from home and b) weather patterns change to increase risks of dehydration and rainfall decreases? The national target is 125 litres of water per day: why, again, does Cornwall need to be different? The general issue of sufficient water to cope with possible drought as a consequence of climate change continues to be ignored, as it was in the preparation of the Local Plan. Is there not a case for planning options for another reservoir in Cornwall and/or a


desalination plant(s)? Materials and Waste: Seems OK.

348 1.Vistry Group support the polices but believe that an Energy Hierarchy should be adopted for the design of buildings. This should prioritise Fabric First, orientation and landscaping with aims of minimising energy demands for heating, lighting and cooling. We do not support a mandatory requirement to exceed national standards set in the building regulations e.g. the emerging future home standard as part of Cornwall’s local policy. This could adversely impact on housing delivery, and in particular affordable delivery, due to additional viability pressures. Developers can choose to exceed standards where this is appropriate in terms of site constraints and opportunities and product selection. 2. We support this approach. However, we would welcome consultation regarding the content and application of the sustainable development checklist. We would encourage a sliding scale or zoning approach similar to the CIL approach to ensure the delivery of new homes of all tenures is not adversely effected due to site or wider local constraints.

3. We would advise that developments should be required to conform with the national standard as part of building regulation requirements rather than a further additional external organisation. Bespoke requirements that add significant cost through redesign, uncertainty and reduce efficiencies in delivery, risk adversely impacting on the delivery of new homes of all tenures.

388 1. Should there be more of a focus on funding energy efficiency in old granite properties. I know there are grants for internal wall insulation but it might need beefing up? 2. SC6 Bespoke requirements based on the Code for Sustainable Homes, with a requirement for detailed analysis as part of the planning application.

389 5. Yes. Connectivity should be added as travel plans were just lip service that were never monitored. Once occupied, development needs to be monitored (ideally) to see whether a difference is being made to people’s lives 6. The Cornwall Sustainable Building Guide is a good starting point. Perhaps developers could be given reductions in planning fees for development that is truly ‘sustainable’ or that makes a proven difference to the outcome of people’s lives?

390 We should be leaders and go beyond building regulations in terms of energy efficiency.

393 1. We think they are about right, However one of our members has made these additional comments in green and I concur with him. I don’t know what the Energy Hierarchy is so can’t comment on that suggestion. The proposals on energy efficiency in new buildings demonstrates a serious lack of ‘emergency’. Local authorities in Bristol and London are already working to planning policies that require lower carbon emission buildings than is being suggested here. I understand that the ability to set rules on this at local authority may be taken away but this policy is a key one and is currently lacking any ambition. Proposals for domestic renewables should seek to minimise noise and air quality impacts in addition to the visual impact. I think that not substantially reviewing the balance of appropriate measures for heritage buildings doesn’t adequately reflect the emergency part of the climate emergency. It is important that we look after the heritage and character of our built environment, it is more important that we address climate change quickly. 3. Our thoughts on 2 energy efficiency of existing buildings. We think there will be an initial take-up of insulation measures now that government has introduced its latest grant scheme. However, either because people can’t be bothered or because they don’t want


the upheaval, they will continue to pump more heat into their badly insulated buildings. This is likely to leave a large proportion of Cornwall’s housing stock still requiring insulation. An idea I (Brian Piper) have been kicking about, is maybe councils should place a carbon order on any property that has an EPC below a certain value. (Similar to a condemned order of the 1950s) This carbon order would be placed on a building when it came up for sale. The carbon order would not stop the sale of the property but would reduce its selling price by, say 5%, allowing the new owner money to improve the energy efficiency and this would have to be done within a set time period, say 3 years, to have the carbon order lifted. Alternatively, if the original owner wanted the full selling price, they would have to carry out the remedial work themselves. I think any house owner is more likely to insulate their home if they know its value will be less, if they don’t insulate, when they eventually want to sell. Eventually this would rectify the inefficiency of Cornwall’s housing stock and I don’t think it would mean every house would have to come to market to achieve this. This approach might even work for rented properties. 5. This seems like a good idea. 6. Don’t know. We just think new housing should be to the highest energy efficiency possible and as far as I know this is to Passivhaus standards.

394 4. Members were concerned that the national standards for construction were likely to be disappointingly low in terms of energy standards. It was hoped that Cornwall Council would do all that it could to encourage low carbon usage and that the policy would reflect the highest standards permissible by the Government

395 1. All developments to present a Habitat Regulation Assessment Plan at pre planning submission stage. Triple glazing of all windows a priority as this accounts for a huge loss of retain heat to a building. 4. One of the things I think should be considered is as the recycling teams go around for them to report properties not recycling and then for those to be targeted by the Council first by mail and then even by a visit to encourage recycling. If then there is no response apply an additional council charge to those properties for recycling loss. 5. Not sure but think second homes need to pay an extra charge to assist irregular collections. 6. Yes

192 1. It is quite right that the Energy Hierarchy is stated at the head of the policy. Could not the council also suggest some incentives towards provision of on-site energy storage? It is unacceptable to use offsetting to compensate for bad design and low ambition. We should be aiming at Passiv House standards rather than an improvement on the existing requirements. Whilst there may be a valid argument for on-site offsetting in specific cases (with a legally binding future management system), contribution to an offsetting fund has been demonstrated many times to encourage continuity of existing life habits. In fact, people will need to adapt their lifestyles, and this should be encouraged,

2. Why are SC1 sections 1,2 & 3 restricted to developments of ten or more dwellings and non residential with a floor space of 1000m2 or more? Why would it not apply to all developments?


3. SC1, point 2: This section appears to be taken from ‘Improving Energy Efficiency in Historic Buildings’ (see comments on 18.4.3 below) and takes a very conservative approach. This is a time when we need a rather more radical approach to historic buildings. Let’s say it again - this is an emergency. SC1, point 3: Seems sensible, but we cannot find reference anywhere to Cornwall Council’s Carbon Offset Fund. SC1, point 4: Also seems sensible SC1, point 5: While it is commendable that thought has been put into re-developing old sites and reusing materials, this could be much more robust, omitting phrases like “where possible” which provides a get out clause for those who are not committed to the most efficient type of developments. Reference the Amsterdam City Donut. In the Amsterdam project, if it can’t be repurposed, it mustn’t be used! Also: 18.4.3: ‘Improving Energy Efficiency in Historic Buildings’ is referred to. While this is an informative document it is about conservation and is therefore ‘conservative’ by nature, being heavily skewed towards preserving the character and appearance of historic buildings. Its approach to making them more efficient is pretty lukewarm - seeming to imply that since they have stood the test of time anything you do to a historic building must, amongst other stringent conditions, be reversible. This approach will not help us achieve carbon neutrality by 2030 or any other date. It may be very nice to treat historic buildings like this in normal circumstances, but, let us remind ourselves that there are no longer any ‘normal circumstances’. 18.4.5: The energy hierarchy is not followed here."

5. If enough effort is put into making this checklist fit within the Council’s decision-making wheel, it can only be a useful tool.

041 1. No new buildings should be possible without their own self-generated renewable energy to ensure self-sufficiency. Developments must fund increased energy infrastructure grid capacity in Cornwall. The council should consider incentives for domestic renewables including grants or rewards to encourage individuals to reduce carbon emissions and non-renewable energy use. Encouraging carbon storage in natural spaces should be prioritised over carbon offsetting. All new domestic buildings should have a water butt and home compost supported or provided by the council. Where home composting is not possible links should be created between developments and local allotment schemes. SC2 Cornwall must aim to have a marine equivalent for the ‘Forest for Cornwall in the form of a ‘Seagrass Forest for Cornwall’ for carbon sequestration. 5 & 6

226 2. The Council is seeking to impose increasingly strict requirements on new buildings. Whilst the ultimate goal is admirable, the Council risks severely limiting the supply of new housing and significantly increasing the cost of the new homes that are available as a result of the additional build cost being passed on to the buyer. The main factor in Cornwall’s carbon emissions from residential properties is not new build housing. It is the existing housing stock which is aging and often extremely poor in terms of energy efficiency. The Council should seek to support the upgrading of existing housing rather than targeting new housing which are already built to high standards in terms of energy efficiency 3. The additional requirements and contributions contained throughout this document and in SC2 are placing the Council at significant risk of damaging the delivery of the homes


that Cornwall so urgently needs. In the midst of a housing crisis the Council should be seeking to support the delivery of homes, not applying increasingly onerous requirements on new homes whilst ignoring the existing housing stock

266 1. In general Policies SC1 and 2 pick up the right issues for sustainable construction, but I would add: policy to address the issues of extreme heat events in relation to sustainable construction. This is important because climate change projections for the UK (please refer to UKCP18 produced by the Met Office) include hotter, dryer summers with increased incidence and severity of extreme heat events. In the built environment, these events can lead to heat stress induced health problems (particularly in relation to the elderly and vulnerable people in our community), reduced workplace productivity and reduced educational attainment in schools and colleges. The implications of this aspect of projected climate change are wide ranging for planning and touch on the design of new buildings and retrofits to existing buildings as well as the layout, orientation and character of developments, ie in the provision of sustainable cooling through natural approaches (shade and ventilation) and low carbon energy efficient mechanical technologies. 2. In general, the policy approaches suggested in policies RE1 – 6 are about right. 3. At item 3 of Policy SC1, why only “Domestic renewables” and not “Domestic and None-Residential renewables”? - At item 5 of Policy SC1 why is there no mention of development proposals contributing to a circular economy (which is a policy climate change principle listed in draft Policy C1 at objective 5)?

5. Yes, I think a Sustainable Development Checklist should be introduced to ensure that the Climate Change Principles are adopted, the energy hierarchy has been implemented and compliance with all relevant policy elements.

397 1. Householders must have access to repayable/recyclable grants and/or secured 0% loans to enable installation of better insulation, renewable energy heating and lighting sources. 2 & 4. As above – recyclable grants and secured 0% loans to enable

6. BREEAM is an ideal research tool but we need bespoke elements for Cornwall – this will aid local employment.

253 1. SC1 Ensure that there is a proper inspection regime to check new build energy efficiency. SC2 Does this mean that external insulation will be supported? Is this possible under permitted development? We also feel the provision of solar systems or water saving devices should be possible without the needs for offsetting SC4 It is feasible to provide these water saving devices so the removal of ‘wherever feasible’ is requested. SC5 Significant developments should be requested to provide a waste management plant to ensure proper use of materials on site.

398 3. I am concerned that these policies do not take account of the embedded carbon costs of new construction and focus almost entirely on the energy expended in the future use of buildings. The policies of “refuse/reduce/re-use/recycle” should be applied to all planning applications –1) Planning policies should require better use to be made of existing buildings before permitting new buildings- a. All planning applications should be required to demonstrate why existing development or development already granted planning permission cannot meet the need of the proposed development, either as it stands or with appropriate refurbishment. b. All new residential buildings should have a requirement that they are to be a primary/only home.


c. All existing residential buildings which are not primary homes and not used commercially as holiday businesses for more than 18 weeks in a year should pay Council tax in that year as though they had been empty for two years or more (this should be a policy/lobbying aim of Cornwall Council until put into law) 2) New construction which has embedded carbon should be refused where the community benefit does not outweigh the carbon costs of construction. Examples of construction which will not have sufficient community benefit are – a. New residential buildings in locations where there are under-utilised homes. An under-utilised home is one which is unoccupied, is a second home not used as a business or is a holiday home used as a business but unoccupied as such for less than 18 weeks in a year. b. Over-large new buildings: there should be a principle that permission will not be granted for buildings which are larger than that required for the intended purpose (with reference to eg average house sizes to refuse permission to over-large new houses) c. Extensions to existing buildings which have not been minimised as much as possible. Extensions of existing houses beyond permitted development limits should be strongly discouraged or refused altogether – family groups are smaller and the embedded carbon in excessively large “lifestyle” extensions to single family houses is a waste. d. Demolition and replacement of existing buildings: more stringent requirements should be placed on demolition of existing buildings, for instance by applying the criteria for demolition of a listed building/building in a conservation area to all buildings. e. New areas of impermeable hard standing, of any size, other than new or improved public highway.

064 1. Policies SC1 and SC2 for sustainable construction are supported and welcomed. Geothermal energy could be an integral part of new development projects and could easily be accommodated as part of the development phases. The policy could encourage the investigation for such on allocated sites as an integral part of site assessment and design. A flexible approach should be encouraged or required to demonstrate how renewable energy resources could be used. Geothermal energy can also be supplied to existing buildings and the policy should encourage the consideration of all renewable energy sources, including geothermal energy.

401 1. Our Response is that we agree with: Development proposals for 10 or more dwellings and non-residential development with a floor space of 1,000 m2 or more will be required to submit an Energy Statement that demonstrates how the proposal will: 1) Achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document Part L (or achieve any higher standard than this that is required under new national planning policy or Building Regulations) based on energy efficiency measures The other two proposals, as follows, could render such developments uneconomic, leading to a dramatic and unwelcome drop in construction across Cornwall, so these proposals should only be adopted if Cornwall Council can provide suitable evidence which demonstrates that they will not reduce development in the Duchy: 2) Provide on-site renewable energy generation, or connection to a renewable or low carbon community energy scheme, that contributes to at least a further 20% reduction in the residual carbon emissions subsequent to 1) above; and 3) Provide onsite natural carbon offsetting/make financial contributions to Cornwall Council’s carbon offset fund in


line with Policy SC2 to enable all residual carbon emissions subsequent to 1) and 2) above to be offset by other local initiatives.

403 3 & 4. We cannot afford to be building anything now that is sub-standard to 2030 requirements (energy use and water) otherwise we will just be increasing the stock of buildings that need to be retrofitted at vast cost. We must take every opportunity to avoid this

5. Yes, the more information available and the easier you make it, the lower the overall cost and therefore, the higher the compliance. Also, easier to identify non compliance 6. Should be aiming for the highest standards possible. Ultimate ambition passive house, subject to location

404 1. LiveWest fully support Cornwall Council in setting an approach to encourage development to follow the energy hierarchy and to prioritise energy reduction. This should absolutely be required prior to looking at the installation of renewable and low carbon systems. LiveWest have adopted minimum u-values for the building fabric and minimum targets for air tightness for all our own land-led new development. These exceed current Building Regulations and ensures that the building fabric is fit for the future. Whilst it is correct to ensure new homes are constructed in a manner that is fit for the future most of the homes that will be standing in 2050 are already built. As an organisation that manages more than 37,000 homes, we recognise that our existing stock is our biggest impact on the environment and, indeed, LiveWest have committed to improving our existing homes to Energy Performance Certificate (EPC) band C by 2028, which is two years ahead of the government target. 2. Through the Climate Change agenda Cornwall have a real opportunity to set ambitious and challenging targets and policies to drive improvement in the existing homes as well as new homes. Cornwall should consider more robustly how this policy can promote, encourage and support energy improvements to the existing homes within the authority area. As the document identifies, fuel poverty affects over 31,000 of all households in Cornwall and as a receiver of homes from developers through S106 we are concerned that in only setting carbon reduction targets developers will look to provide the lowest cost solution to achieve these targets. LiveWest have undertaken significant modelling to support our strategy and from our experience, where the dwelling fabric is not sufficiently robust the in-use running costs for these electric-based heating systems can often be double the level of an A-rated gas boiler. Therefore, whilst achieving the carbon reduction requirements under SAP these can increase the running costs to our customers which could increase the incidences of fuel poverty. LiveWest would encourage Cornwall Council to allow landlords to access the money that may be paid into the carbon off-set fund to promote the enhancement and upgrade of existing housing stock. Where Cornwall Council are looking to set additional targets for the carbon reduction improvements upon the Building Regulation requirements, you should clarify the baseline from which these carbon reductions will be taken. Even with a robust building fabric and domestic scale renewable, gas remains a cheaper


fuel source for our customers. LiveWest are designing our new homes to ensure a non-gas heating system can be cost-effectively fitted retrospectively, ensuring our homes are resilient to change. LiveWest would encourage Cornwall Council to consider adopting a similar policy which would ensure homes built today are fit for tomorrow. "Whilst we absolutely support the principle of locally sourced materials and lifecycle assessment this will put additional cost burden, present an opportunity for viability challenges and introduce delay on new homes which may ultimately reduce the level of affordable housing. It may be more appropriate to consider the Green rating of building materials as there are good sustainably sourced building materials available such as timber which are more readily available." "We note that there is no mention of Modern Methods of Construction (MMC) within these policies. LiveWest has a good history of using modern methods of construction systems, whether these are rainscreen cladding systems, panelised or volumetric construction systems. We see that MMC will have an increasingly important future role to play in the housing sector in terms of increased delivery, waste reduction and improved environmental performance. LiveWest is a board member of Building Better which is a strategic alliance of housing associations supported by the NHF. Our aim is to encourage collaboration across the social housing sector in order to realise the true benefits of MMC in terms of quality, sustainability and better value. We would happily discuss our approach with Cornwall if that is of benefit."

163 4. I support the carbon reduction targets for new developments although I would prefer these to be as high as possible and would like to see a road to carbon neutral 5. This sounds like a great idea, I would imagine the developers appreciate clear guidance and regulation. This also helps to level the playing field. These should be completed for each planning application to that the public and stakeholders can see at this stage. 6. I think it makes sense to use an existing standard, or as consistent as possible with those used elsewhere.

109 1. The proposals should go beyond the expectations of BREEAM – Bespoke requirement is required to achieve the standards of sustainable homes.

405 2. We’re in an emergency. The house is on fire, but we’re still concerned with maintaining the appearance of old buildings. Section 18..4.3 (conflicts with energy efficient/renewable technology and preserving our historic environment/heritage) and Policy SC1 – Energy and Sustainable Construction sections 2 (Energy- existing buildings) and 3 (Domestic renewables) suggest that the priority is still to keep historic buildings as they are as a priority over the need to make a building more energy efficient, or put PVs on the roof. We would ask for a much bolder approach, emphasising that there is an emergency, the council agree with this, and in an emergency we have to act differently, swiftly and this require a switch of the emphasis of what is important.

292 1. In general Policies SC1 and 2 pick up the right issues for sustainable construction, but the UK’s building standards have always lagged other more progressive economies notably those in Scandanavia. There are many instances of shoddy workmanship in housing construction and the Grenfell Tower tragedy and the revelations of testing of external finishes and lax building control are positively criminal. In reality where countries such as France and Germany have historic excellence in trades skills training the UK’s apprenticeship system is shambolic. Given that in large parts of the UK many local trades people are immigrants – legal EU residents – what is the oversight of their qualifications and skills? If it were within the Council’s power to legislate for properly regulated apprenticeship schemes and training then that would be a positive contribution to the implementation future quality developments. 2. In general the scope is about right - the detail needs fleshing out.


5. Yes, definitely

6. I’m a great believer in not reinventing the wheel. If policies/standards/enforcements are seen to work in other similar areas/economies then I have no qualms about copying these. In particular I’m a firm believer of COTS – commercial of-the-shelf technologies. When it comes to sustainable carbon neutral housing development strong consideration should be give to the incorporation of the PASSIVHOUSE principles and designs.

097 1. SC1: the arithmetic here does not add up to net zero even for this easiest of cases of new build. If the DPD itself does not require net zero then failure to meet the net zero target is guaranteed. The requirements here need to be more demanding. SC2: The requirement for a Carbon Storage Calculation is an excellent policy but many carbon offsetting schemes and methods are highly questionable. It would be safer and better simply to reject schemes causing a reduced carbon storage capacity. 6. BREEAM is a standard for general assessment of buildings across a wide range of categories. As such it may be useful for certain specific purposes. But as an assessment of a building’s sustainability it is deeply flawed and should not be used (it’s supporters and promoters argue differently.) Other, more sustainability focused standards are available ( eg Passivhaus) and they may be more appropriate here.

407 1. Design to allow/encourage working/trading from home

2. As above: design to allow/encourage working/trading from home and rules on change of use of buildings to ensure standards are appropriate for the new use. 5. Yes, although an enforceable, quantitive system may be difficult to achieve. 6. Suggest a compromise by using National standards with additional, identified requirements to take account of Cornwall specific requirements e.g. some, particularly exposed, areas should not have cavity wall insulation to prevent “void bridging” but external insulation/water infiltration prevention systems such as “slate faces” as part of the standard.

408 1. The policies should apply to all dwellings and just to 10 or more dwellings. There should be heavy emphasis on the following points: 18.4.1 – In order to make progress towards our target of being carbon neutral by 2030, it is essential that new development minimises carbon emissions by adopting the energy hierarchy 18.4.2 – Measures are also needed to address emissions from existing buildings. In a residential property this means insulating every available loft and cavity walled building, along with the majority of solid walled buildings. Much of this falls outside the remit of planning, however, there are opportunities where applications are made for change of use, conversions, reversions and extensions. The Council supports increases in domestic renewable energy generation. 4. There should be a carrot and stick approach to encourage existing households to improve the energy performance of their homes 5. Yes

410 6. The requirement to exceed building regulations Part L on energy efficiency and for 20% on site renewable energy is inconsistent with national planning policy and guidance, which makes clear that the only additional technical requirements exceeding the minimum standards required by Building Regulations that can be sought are the optional technical standards as detailed in the NPPG. The application of the optional water efficiency standard can comply with the NPPG, but the Council is required to provide evidence in relation to whether the standard is necessary and viable in line with NPPG. No such evidence has been provided. Similar evidence is also required in relation to Policy SC2. Whilst we do not consider that such an approach is consistent with national policy, even if it were to be, the implications for development (and the achievement of the LP:SP development requirements) need to be fully assessed and set out."

411 These policies do cover the right issues for sustainable construction. Nothing more to add. 1.All proposals should embed the energy hierarchy within the design of the buildings by


prioritising the fabric first. 2. Prioritising the use of previously developed land and buildings where possible, whilst maintaining and enhancing local character and distinctiveness; 3. Reuse and recycling of materials that arise through demolition and refurbishment, including the reuse of excavated soil and hardcore within the site; 4. Prioritise the use of locally sourced, sustainable materials and construction techniques that have smaller ecological and carbon footprints; 5. Using locally distinctive, resilient, low maintenance materials that are appropriate for Cornwall’s damp maritime climate (for example locally won materials such as slate and granite) as described in the Cornwall Design Guide; 6. Considering the lifecycle of the development and surrounding area, including how they can be adapted to meet changing community needs and how materials can be recycled at the end of their lifetime; and 7. Providing adequate space to enable and encourage greater levels of recycling across residential and non-residential developments. Space requirements for residential developments should follow those outlined in the Cornwall Design Guide…… 3. My thoughts on 2 energy efficiency of existing buildings. I think there will be an initial take-up of insulation measures now that government has introduced its latest grant scheme. However, I think either because people can’t be bothered or because they don’t want the upheaval, they will continue to pump more heat into their badly insulated buildings. This is likely to leave a large proportion of Cornwall’s housing stock still requiring insulation. An idea I have been kicking about, is maybe councils should place a carbon order on any property that has an EPC below a certain value. (Similar to a condemned order of the 1950s) This carbon order would be placed on a building when it came up for sale. The carbon order would not stop the sale of the property but would reduce its selling price by, say 5%, allowing the new owner money to improve the energy efficiency and this would have to be done within a set time period, say 3 years, to have the carbon order lifted. Alternatively, if the original owner wanted the full selling price, they would have to carry out the remedial work themselves. I think any house owner is more likely to insulate their home if they know its value will be less, if they don’t insulate, when they eventually want to sell. Eventually this would rectify the inefficiency of Cornwall’s housing stock and I don’t think it would mean every house would have to come to market to achieve this. This approach might even work for rented properties."

5. This seems like a good idea. 6. Don’t know. I just think new housing should be to the highest energy efficiency possible and as far as I know this is to Passivhaus standards.

265 2. SC1 refers to heat once when discussing reducing energy demand (though it is possible that the ‘district energy networks’ may distribute heat). We agree that ensuring energy efficient building fabric must be the first priority. In 2018, heat represented over 80% of domestic energy consumption and 75% of total energy consumption in UK buildings. Transitioning away from gas and oil fuelled heating in buildings is a major challenge, and one which local planning policy should be explicitly encouraging. This could involve refusing permission to developments which require extension of the gas network (and thus lock in carbon emissions), expressing particular support for developments using heat pumps or connecting to heat networks, as well as promoting the future-proofing of developments with fossil- fuelled heating by, for example, ensuring that there is a sufficient power supply to site for future installation of heat pumps. We also note that the UK Government has made clear that it intends to phase out the installation of high carbon fossil fuel heating in new and existing buildings in areas off the gas grid during the 2020s. Given that large areas of Cornwall do not have access to the gas grid, specific mention should be made of the expectation that no new dwellings will be built with oil or LPG heating systems. 3.The introduction to the section describes how offsetting may play a role due to the challenges of achieving ‘zero carbon buildings’ in the ‘short term’. Under ‘1 Energy – New Development’ points 1


and 2, thresholds of 19% carbon reduction from building fabric above and beyond Building Regulations, and a further 20% emissions cut from renewable generation are specified. We suggest that the Council provides further detail regarding how and why these 19% and 20% thresholds are being used. Presumably this is based on the clarification from Government in 2019 that standards beyond building regulations but no higher than the equivalent of Level 4 of the Code for Sustainable Homes can be applied. However we note that some LPAs are proposing local policies that exceed this level, including Greater Manchester, Reading and Bristol City Council (see here for more details) In the context of the apparent aspiration to achieve zero carbon buildings in the medium or long term, it would also be helpful to know what duration of time the thresholds will be applicable for – and whether they might be increased in future. Regarding offsetting (largely SC1.1.3 & SC2), the approach lacks specificity and clarity. Firstly, Policy SC1.1.3 refers to the need to offset “all residual emissions” – it is unclear whether these are limited to building fabric, or also include estimated building lifetime energy consumption, and inhabitant local transport emissions (e.g. does action to truly facilitate active travel reduce the “all residual emissions” total?). We think that residual emissions should be holistic. Secondly, SC2 could more clearly state that the carbon compensation must be equal to or exceed the carbon storage loss. Thirdly, SC2 does not set geographical limits on the ‘offsets’, though one example is local. We think it is important that any offsetting is as local to the development as possible, and certainly within Cornwall. Purchasing international offset credits would be undesirable so it should be clear that this would be unacceptable. Finally, we would like to underline the zero sum nature of offsetting – retrofitting existing buildings to compensate for emissions from new developments simply moves the emissions source, it does not solve the problem. One way to mitigate this effect is to, as the policy does in part, emphasise the importance of high fabric standards, accepting that some energy consumption may still cause emissions. Retrofitting energy sources is cheaper and less disruptive than building fabric. We would therefore support the strongest possible policy for fabric standards.

329 1. proposals. These are often a way for high carbon projects to continue acting in the way they always have and to move the responsibility onto abstract locations to mitigate their impact. Behaviour change should be the priority alongside financial support for renewables development before any offsetting is considered. Where it is considered it would need to be evidenced why that was seen as necessary.

5. Yes absolutely 6. An analysis of the pros and cons would need to be made before a decision was made on that. The one with the biggest environmental gain should be supported.

246 5. Q5 – Yes! Most definitely Carbon Offsetting is still worryingly scattered throughout your document. This is a rich persons tool to a quicker job done. Please be vigilant with this. It should be made a lot harder for developers to carbon offset than for them to increase biodiversity and retain natural environment. A LOT harder. I am very interested to see the next part of this epic development plan, and the policies map that will come from it. I’m hoping you will force issues further and more radically. The harder you push the better and more successful the outcome will be.


412 1. Sc1. Ensure that there is a proper inspection regime to check new build energy efficiency 2. Will external insulation will be supported? Is this possible under permitted development? 4.It is feasible to provide these water saving devices so the removal of ‘wherever feasible’ is requested. SC2 The provision of solar or water saving devices should be possible without the need for offsetting"

264 1. Cornwall CLT welcomes the proposals

095 6. This is a good plan. Please keep home energy proposals put forward by cohousing communities really simple, please. Cohousing people will be working together to improve their quality of life so do not need regulating, whereas builders and landlords might.

415 6. This is a good plan. Please keep home energy proposals put forward by cohousing communities really simple, please. Cohousing people will be working together to improve their quality of life so do not need regulating, whereas builders and landlords might.

420 1. Houses are being built more frequently than reservoirs. Therefore to take the pressure off of the increasing reservoir requirements if more emphasis could be directed to underground storage of harvested rainwater, which could then be reintroduced with a pump through a partial and a UV filter in to the house cold water system by linking into the mains with a one way valve on the mains incoming pipe. Tank sizes to be reflect the size of house hold. Plus if the waste water from the bath could have a pipe plumbed in specifically to an outside tap to water the garden and a sign on the tap for the use there of this water too can be recycled locally taking pressure off of the mains drainage system.

421 6. Generally good. Will need increased skills in-house. I think a checklist/ tock-box approach to sustainable development will commonly be gamed by developers looking to increase their profits. Maybe need to set maximum sizes on developments to discourage large developers and encourage local business e.g. a maximum bundle size of no more than 20 dwellings plots.

243 5. Yes 6. A standard for measuring whole-life carbon emissions, including embodied carbon footprint, could be used (see answer to policy C1 question 2).

422 3. t is not evident that draft Policy SC1 is achievable without negatively impacting investment and delivery of new development projects in the County. As currently drafted, Part 1 of draft Policy SC1 requires developments to achieve a reduction of at least 39% in carbon emissions through energy efficiency measures and on-site renewable energy generation. The residual carbon emissions must then be offset by other local initiatives. This is a substantial step change from the current policy position and we are concerned about the implications of this on the viability of development. We do not consider that the policy approach is sufficiently flexible to facilitate development (for wider economic reasons) or to take into account the significant differences in what can be achieved at a particular time by different sectors. Whilst it is right that new standards drive forward reductions in carbon emissions, it is necessary for these standards to be in line with national targets. This is to ensure that the sectors benefit from advances being made at that time without unacceptable or unintended consequences upon that industry and for the local economy. We have not seen any evidence that suggests that Cornwall must move forward well in advance of the rest of England. For these reasons the Council is encouraged to carefully consider the implications of the proposed energy efficiency targets. 4. Policy SC1 needs to include a degree of flexibility to take into account the points raised in relation to question 3 above. This could include transitional arrangements to ensure businesses are not unduly discouraged from investing in Cornwall.

189 3. It is not evident that draft Policy SC1 is achievable without negatively impacting the tourist industry and accommodation sites in the County given the value of tourism to the Cornish economy. As currently drafted, Part 1 of draft Policy SC1 requires developments to achieve a reduction of at least 39% in carbon emissions through energy efficiency measures and on-site renewable energy generation. The residual carbon emissions must then be offset by other local initiatives. This is a substantial step change from the current policy position and we are concerned about the implications of this on the viability of development. We do not consider that the policy approach is


sufficiently flexible to facilitate development (for wider economic reasons) or to take into account the significant differences in what can be achieved at a particular time by different sectors. Whilst it is right that new standards drive forward reductions in carbon emissions, it is necessary for these standards to be in line with national targets. For caravan Parks, alternative energy sources (to the current LPG) are likely to be incorporated into caravan design but this will be something the industry looks at nationally. This is to ensure that the sector benefits from advances being made at that time without unacceptable or unintended consequences upon that industry and for the local economy. We have not seen any evidence that suggests that Cornwall must move forward well in advance of the rest of England. By forcing significantly challenging standards upon the tourism industry in Cornwall, decisions will be made on whether to invest in new and improved facilities and/or whether to make those investments elsewhere, where the targets are more achievable. Further, for companies that operate across England and Great Britain, as Bourne Leisure does, there is a need for consistent standards and development requirements otherwise costs will spiral from ad hoc approaches. Such a position could have a chilling effect on investment decisions for particular locations. For these reasons the Council is encouraged to carefully consider the implications of the proposed energy efficiency targets. 4. Policy SC1 needs to include a degree of flexibility to take into account the points raised in relation to question 3 above. This could include transitional arrangements to ensure businesses are not unduly discouraged from investing in Cornwall.

189 3. It is not evident that draft Policy SC1 is achievable without negatively impacting the tourist industry and accommodation sites in the County given the value of tourism to the Cornish economy. As currently drafted, Part 1 of draft Policy SC1 requires developments to achieve a reduction of at least 39% in carbon emissions through energy efficiency measures and on-site renewable energy generation. The residual carbon emissions must then be offset by other local initiatives. This is a substantial step change from the current policy position and we are concerned about the implications of this on the viability of development. We do not consider that the policy approach is sufficiently flexible to facilitate development (for wider economic reasons) or to take into account the significant differences in what can be achieved at a particular time by different sectors. Whilst it is right that new standards drive forward reductions in carbon emissions, it is necessary for these standards to be in line with national targets. For caravan Parks, alternative energy sources (to the current LPG) are likely to be incorporated into caravan design but this will be something the industry looks at nationally. This is to ensure that the sector benefits from advances being made at that time without unacceptable or unintended consequences upon that industry and for the local economy. We have not seen any evidence that suggests that Cornwall must move forward well in advance of the rest of England. By forcing significantly challenging standards upon the tourism industry in Cornwall, decisions will be made on whether to invest in new and improved facilities and/or whether to make those investments elsewhere, where the targets are more achievable. Further, for companies that operate across England and Great Britain, as Bourne Leisure does, there is a need for consistent standards and development requirements otherwise costs will spiral from ad hoc approaches. Such a position could have a chilling effect on investment decisions for particular locations. For these reasons the Council is encouraged to carefully consider the implications of the proposed energy efficiency targets. 4. Policy SC1 needs to include a degree of flexibility to take into account the points raised in relation to question 3 above. This could include transitional arrangements to ensure businesses are not unduly discouraged from investing in Cornwall

019 1. Historic England supports the approach outlined in this section. However, the Introduction omits reference to the important positive contribution that the historic environment, and in particular historic buildings, can make towards minimising carbon emissions and the target of becoming carbon neutral by 2030. Research by Historic England has found that retaining, reusing, refurbishing and retrofitting existing buildings should be a priority for meeting the Government’s net zero carbon target by 2050, taking into account their embodied carbon and that we can reduce the carbon emissions of historic buildings by over 60% by 2050 if we take a whole of life carbon approach. Historic England recognises the importance of climate change mitigation and adaptation as part of building resilience for the historic environment. We offer information and advice on many related topics including energy efficiency and historic buildings, including historic buildings and traditional


homes, Part L of the Buildings Regulations and renewable energy generation, as well as to help advise on how this can be undertaken while minimising negative impacts on the historic environment. We would like see a new sub-section in the Introduction that addresses this point. 2. We note the explanatory text for Policy SC1 notes the contribution that reducing emissions from existing buildings can make in paragraph 18.4.2. While we welcome this, the wording could be expressed in a much more positive way – see our comments above about the contribution of historic buildings to reducing emissions. While we are also pleased to see the reference to the Council’s ‘Improving Energy Efficiency in Historic Cornish Buildings’ in paragraph 18.4.3, Historic England has published a wealth of relevant information and advice on our website, some of which have been referenced in these comments. We also consider this paragraph should be reworded to more positively. Historic England believes that energy efficiency, sustainable technology and reducing carbon emissions are compatible with the conservation of our heritage. In respect of Policy SC1 itself, we strongly support part 2 and its positive approach to encouraging the retention of historic buildings, including designated and non-designated heritage assets, and securing sustainable futures for them through proposals that conserve, and where appropriate, enhance their significance. We also support the intent of part 3 of this Policy. However, we consider this should be re-worded to consider impacts on all types of designated and non-designated heritage asset, (not just listed buildings) and their settings, as well as the wider townscapes, landscapes and seascapes. 3. Policy SC2: We note the intent of Policy SC2. We would refer you to comments we have made elsewhere in relation to the potential allocation of sites for carbon offsetting and need for proportionate heritage impact assessments to inform their selection."

168 1. We Support this policy

11. Proposed Policies -Coastal Change and Flooding

Policy CC1 - Coastal Vulnerability Zone Policy CC2 – Candidate Coastal Change Management Areas Policy CC3 – Reduction of Flood risk Policy CC4 – Sustainable Drainage System Design


1. Do Policies CC1 - 4 pick up the right issues for coastal change and flooding – are there anymore that you would add? 2. Are the policy approaches that we are suggesting in policies CC1 - 4 about right – is there anything missing? 3. Do you have specific comments to make about the content or intentions of policies CC1 - 4? 4. do you have an alternative approach to Policies CC1 - 4 that you think the council should consider? 5.An alternative policy option to CC2 could be to allocate full Coastal Change Management Areas on adoption of the DPD. This would require the publication of mitigation plans for each of the areas. We do not support this option as we believe that the level of assistance that we could provide for each area would be limited given the number of settlements impacted. Would you support this, or should we consider an alternative approach?

URN Comments

352 5. You should encourage NDP to address this. Inevitably resources will be needed to enhance the status and budget of the Environment Agency (make it a Ministry?). Sea level


rise and increasing storm surges are predicted through climate change and so MUST be addressed somehow. Saying that assistance would be limited will not cut it!

355 1. Yes

360 1. CC2. Any development should comply with the Neighbourhood Plan in the area.

362 1. 9.4 Policy CC1 - Coastal Vulnerability Zone There needs to be a policy about vulnerable areas for biodiversity. In planning a response to coastal changes caused by a rising sea level and other factors the existing biodiversity needs to be considered. There is already a large and growing body of computerised information about the coastal biodiversity and this needs to be fully consulted. For example, there are critically important plants that grow along the coastal fringe. Their location and ecological needs should be properly considered. In conclusion, whilst this planning document is full of fine words, when it comes to dealing with issues concerning biodiversity, it is clearly not based on a detailed knowledge or understanding of Cornwall's biodiversity. There is a systemic problem whereby Cornwall has the finest set of Flowering Plants and Ferns records for any region in Britain and yet those data are not routinely consulted in the planning process nor were they used in preparing this planning document. It is good that ""The draft policy suggestions of the DPD recognise the critical importance of biodiversity in relation to climate change and further embeds the Council’s Environmental Growth Strategy and the emerging approaches to nature recovery"". However, to recognise the critical importance of biodiversity Cornwall Council needs to find out what biodiversity Cornwall actually has. The headline results from the recent BSBI survey of the Cornish flora are: • At least half of the native and archaeophyte plants were more widespread before 2000. • A minimum of 40% of Cornwall has lost 90% of its wildlife in the last 50 years. Clearly, Cornwall Council has much to do and a great deal to learn about the biodiversity it is a custodian of!"

364 1. CC1 to 4 The human being never seems to learn lessons from the planets passed. The sea will always win, so building on cliffs is not a very intelligent thing do to at any time. Most of Newquay will disappear into the sea before very long, as most of it is built on very old mine workings which are very deep, and the sea is already in them. Rock is in the same position, As will a lot of the costal areas of Kernow. Until there is a person with an actual brain in Konsel Kernow, who has the whole of Kernow tested for where all the mines actually are, no one will know where all the thousands of mine shafts, and the miles of workings, and air shafts are in Kernow. Our cliffs are falling away every day, this is a natural thing. The sea always wins. No garden should be built on at any time. We are going to need our gardens to produce the food we are going to need. The crooks are steeling our good farm land at this time we must stop them before it is too late for us all. Flood risk is bound to get greater. We have over population, which is heating the planet, which means the sea is heating, so the moisture is then released into the atmosphere over the sea. This water then reaches higher ground and released back to the planet. More population more flooding, obvious to anyone I would have thought. "

363 1. 34 Policy CC1 Coastal erosion and flooding. Dunes need reinforcing with Vetiver grass planted in rows along the contour at a vertical interval dictated by the slope. Plant slips 6” apart and they then reinforce one another. It is cheap, tolerant of sea water, flooding, drought, fire, mineral and toxin concentrations. Introduce Schedule 10 of the Act which


HMG has ignored for too long. Just adopt is as part of the building regulations and let them complain if they don’t like it. It is already on the statute book just not implemented. Bring SUDS in on all developments everywhere. The coastal footpath is over done. It swallows huge amounts of money and yet what does it produce. The same money used on footpath generally would yield far greater returns. Use Vetiver inland to retain water and release slowly from uplands into the river systems. Make sure rivers are clear and free flowing to ensure water is carried as easily as possible to the sea. 35 Policy CC2 candidate coastal change areas Replacement sounds to me like a great mechanism to knock down buildings and replace them with new ones worth a lot more money. This needs careful monitoring so as not to be abused. I suggest that any development within 1km of the coast should be part of a Coastal Change Management Area. Look it another way, have a coastal change management area 1km wide around the whole coast. Then you only need to have one plan with variations as necessary. 36 Policy CC3 see my comments above. Plus stop allowing people to build things in the flood plains. There is a big loophole. EA calls in anything greater than 0,5 hectares. Anything up to 0.4999 hectares does not get looked at. So you can have ten 0.45 hectare developments in the flood plain wreaking havoc with it and nobody takes any notice until the whole place floods of course. Stop this loophole up NOW. Make contact with all Riparian owners and educate them about their duties to manage the banks of the watercourse associated with their property. Set down standards for maintenance (these must exist as the EA maintain main rivers but will divulge their standards and systems for some reason unfathomable. Cormac are similarly secretive. They have operating procedures for maintaining water courses as they do it all over the place but will not share their standards. They kept referring it to Countryside access if I am not mistaken who had some tortuous process which never reached a conclusion. Cut through the tangle here and issue standards for riparian maintenance urgently. 37 Policy CC4. See my comments abut SUDS and the schedule of the Act above. Work closely with CCFF who are active in this area. The biggest difficulty with SUDS is that where systems are set in place the developer sets it up and then walks away leaving no mechanism in place for maintaining them into the future. Either this must be taken on by CC and incorporated into the rates or each property holder must have an obligation. The former is clearly the better option as a mechanism for ongoing maintenance"

374 5. You should encourage NDP to address this. Inevitably resources will be needed to enhance the status and budget of the Environment Agency (make it a Ministry?). Sea level rise and increasing storm surges are predicted through climate change and so MUST be addressed somehow. Saying that assistance would be limited will not cut it!

029 1. Nothing add 2. Not that we can see. 3. No 4. No 5. We support your view.

032 1. Seems OK 2. We have insufficient knowledge to comment but placing the responsibility for Coastal Change Management Plans on parish and town councils seems a difficult task for them. Are they happy with this? What happens if things go wrong or are omitted: are there potential liabilities? What happens where there is no NDP in place?" 3. Seems good.


4. Seems good.

378 1 – 4 We support the policies as outlined. We would like to add that consideration should be given to establishing the viability of natural coastal flood defence schemes as are being successfully piloted in the USA and elsewhere 5. We agree that the resources needed to implement such support would not be within the capacity of Cornwall Council without considerable Government assistance"

053 We support the promotion of natural flood management and sustainable urban drainage in this section.

034 CC1 Seems OK CC 3Seems good. CC 4 Also seems good.

348 1. Vistry Group support in general terms policies CC1-4. However, we strongly feel there needs to be a coordinated planning policy requirement that is accepted by County Highways, the Environment Agency and South West Water as we have had frequent experience where a lack of a coordinated approach has led to delays with starting on site building new homes and with issues with adoption. 3. We believe the content and intentions of policies CC1-4 are appropriate. The council will need to ensure that they can be both practical and deliverable. 5. We support the Cornwall Council’s approach.

386 CC2 - Candidate coastal change management areas, we note that these will be detailed in the policies map which is not yet available to view and which will be subject to a separate consultation. Of particular interest to us here would be any measures in relation to Hayle Causeway which has the potential to impact on the need for a possible future junction on the SRN. We therefore look forward to further opportunities to comment on the coastal change management areas.

122 We await receipt of the Policies Map, to see whether there are any designated Coastal Vulnerability Zones or Coastal Change Management Areas in our area of concern. Although we support the concepts in this section, we re-iterate that we are concerned that due recognition is given to the AONB status, as we do not expect any new developments which would be covered by this section in our area of concern.

388 1. All good 2. All good 5. Support Cornwall Council approach.

389 1. Sustainable tourism is predicated on the management of the coast. This includes access to and use of the coast path and looking at ways that footfall can spend money in the localities it passes. A tourist tax (again through a needed Cornish Assembly) is required to pay for the maintenance and management of such assets. These have were becoming much more popular even before Covid. 5. Supported because it would be a useful guide for developers and would raise any issues during the course of the planning permission process.

393 These policies do cover the right issues for coastal change and flooding. Nothing more to add.

395 1. Combined Sewers. All new developments have to separate surface water and sewage but they invariably go into combined sewage systems downstream. Here in the Penzance area, a critical drainage Area (CDA), this has and is a continuing problem with scores of sewage overflows in roads and into the sea on far too many occasions. In my and other people’s opinions the local sewage system cannot cope. It is time to completely replace


our sewerage system. South West Water have made huge profits over the years, charge the most but still have high water leaks and this ongoing sea pollution in Mounts Bay. Time to do something about it as any new development in a CDA has to make a betterment than the existing! To be also referenced the Shoreline Management Plan.2. Yes the Environment Agency Flood Risk Management Plan now not due to some vague date in 2021. No new development should go ahead until this long overdue plan is received, checked and assessed then put out for public consultation. This plan will affect all decisions by local authorities from shoreline protection, sewage control, water quality and planning decisions. There is also the Local Neighbourhood Plan to consider which I understand could be published but is now also long overdue 3. A Flood Risk Assessment to be required at the pre planning application stage especially in Critical Drainage areas such as Mounts Bay Sustainable Drainage must be under the control of the Planning Authority and until Part 3 of the National Flood Plan is approved that it not the case. Also reference the new paragraph 165 NPPF The Council’s Local Flood team must be able to fully approve or otherwise of any Suds system before development plus they must be able to control and have recourse against the developer after they finish the site if any problems occur. 5. Always consider alternatives they might work!

192 1. There is no mention here of the problem of soil erosion, nor afforestation of uplands. Also there is no mention of mine workings, leats and adits, nor of combined sewers. 2. The Shoreline Management Plan is long and comprehensive and it is difficult to fault it, but in policy CC1, 1) it is hard to imagine what kind of “New development” is envisaged. There cannot be many reasons for building anything at all on the shoreside. Under what circumstances might planning be considered? Policy CC1, 3: Here, as elsewhere, emphasis is rightly on “coastal stability”, but pollutants get no mention. Policy CC2, 3: “Replacement property is located close.........”; in the case of industrial units relocated necessarily upstream, as is the case in Porthleven, what validates the need for property to be relocated? Is there a loophole for re-arranging coastal settlements for economic/commercial reasons? Policy CC3, 2: “...the Environment Agency's latest surface water flood risk map.....”, this map is not easy to find. All property owners should be made aware of their situation in their own catchment area and given clear guidelines on how they can improve their property’s resilience and follow recognised best practice for water retention and conservation. Flood prevention need not be something which someone does for us, active participation would serve us better. We need guidance on tactics. A clear map of the local catchment area should be readily available, marking contours and watercourses. Policy CC3 only refers to development proposals. Consideration must also be given to existing buildings, villages and hamlets. The Cornish countryside is a warren of deep narrow lanes on steep hillsides, extremely vulnerable to surface water flooding in intense rain storms or prolonged rain. Inappropriately parked cars, for instance, can cause dangerous havoc. Small communities must be encouraged towards best preventative practice as well as plans for mitigation. Policy CC4, Sustainable Drainage System Design. There should be more active encouragement here, including small scale systems in rural areas. Information of best practice could be distributed.


That there is no mention of conventional sewers here, perhaps because they are the responsibility of S.W. Water? Is it to be accepted that there is action being taken to tackle the obvious problem of combined sewers? 3. The scope of Policy CC3 should be far more comprehensive. It must be understood that all development, especially upstream of CDAs , must contribute to Natural Flood Management measures. The principle of topsoil and surface water retention is critical to flood management. Scrutiny of the present trend towards urbanisation of the countryside must be exercised with the knowledge that the land is required to hold its water, not to rapidly shed it downhill. Manicured squares of human habitation coupled with cropped green grass and monocultured slopes increase the vulnerability of our drainage systems and all land downstream. Dense and multi layered vegetation is the only means of retaining water and regenerating topsoil. Developers should show how their proposed development contributes positively to National Flood Management aims. This could include methods such as terracing, digging of ponds, tree use, cisterns, tanks, holding pools, and bunds. Practical advice on the retention of topsoil and for water conservation must be available to everyone expected to implement these measures. All landowners, large or small, need to understand that it is incumbent on them to manage surface water." 4. Main rivers come under the auspices of the Environment Agency and one would assume they are managed appropriately (Cornwall Council Preliminary Flood Risk Assessment, 2 LLFA responsibilities). The coast is managed by the council with the Shoreline Management Plan, though it is hard to detect an actual office, and the Ordinary Watercourses under the council as the Lead Local Flood Authority. This is all very well, but to a member of the public seems disjointed. Our own flood risk and responsibility, especially as we move from the coast, is better appreciated from the view of our catchment area. A common responsibility for the management of the Ordinary Watercourses under the auspices of the council is called for. The lacework of streams, ditches, gullies and pools can only be managed at an extreme local level, but guidance and the overview of our catchment area is essential. Opportunities must be sought at all levels and on any small scale for rewilding where it is ap-propriate for water retention. An overview of the numerous systems of mine workings leats and adits and other man made watercourses may be considered in light of their potential for pollution and for sustainable energy projects. Appraisal and comparison of the White River Project in St. Austell and the harbour drainage sluices in Charlestown amongst other such schemes may yield solutions. Perhaps a coordinator is called for. The planting of trees in our uplands is a vital integral part of any flood prevention plan. 5. The recommended policy seems appropriate with Management Areas applying for Candidate Coastal Change status if and when deemed necessary.

297 We advise that this chapter highlights the need to retain and enhance natural coastal defences, particularly saltmarsh, seagrass beds and kelp forests. These habitats can act as carbon stores as well as reduce the need for high carbon artificial defences. Para 19.2.3. As states in our previous response dated 27 May 2020, Natural England does not support this approach as it could lead to inconsistencies or gaps where there is no Neighbourhood Plan. In addition, such an approach cannot reflect strategic measures to address issues affecting more than one neighbourhood plan area. 2nd sentence. It is not clear what this sentence means.


Last sentence. The aim of the review of neighbourhood plans referred to here should be clarified. Para 19.4.1. The methodology developed in the ‘SWEEP CCMA’ project may help in providing information on future erosion rates. A report on the SWEEP project is to be published shortly. Coastal Change Management Areas - The South West Partnership for Environmental and Economic Prosperity. CC1 – Coastal vulnerability map. The policy states that the Coastal Vulnerability Zone is identified on the policies map. We assume this will be included in a future iteration of the Plan. The same point applies to CC2 – candidate Coastal Change Management Areas. We will be able to respond to proposed policy and supporting evidence regarding these zones when they are published. CC1(b) – protecting the natural environment in coastal vulnerability zones. We advise that specific reference to biodiversity is made here as new development within the coastal vulnerability zone could have an adverse impact on biodiversity through coastal squeeze. This could result where development reduces areas used by species such as birds for foraging or roosting. Clarification is sought on how sustainable adaptability would be assessed. CC1 (c). Should this clause not also address ‘replacement development’. Also, should it end with ‘and/or’ or just ‘or’ CC1 (e) – Coast Path. It should be noted that the English Coast Path, enabled by the Marine and Coastal Access Act 2009, introduces the concept of roll back: where a section of coast erodes, the path will move back accordingly. We suggest that ‘moved back’ be replaced with ‘rolled back’ in clause (e). CC1 – Exceptions. The sentence regarding exceptions is confusing and needs clarification. "CC1 (2)(b). A definition should be provided for ‘public health and safety purposes’ as referred to in this policy. Para 19.5.1, 2nd sentence. The risks referred to here are already set out in the Shoreline Management Plan and the NPPF requires that they are planned for now. Para 19.5.3. Clarification is sought on how Natural England may contribute to the development of CCMAs where these are prepared by the community. In addition, what will be expected of Town and Parish Council’s in managing these plans. “Triggers” for formal designation. Our view is that work should commence on developing these plans now, in line with the NPPF. CC2. The 2nd sentence needs to clarify what exactly will be permitted here. 1st bullet. What sort of allocation is being referred to here. Do you mean areas allocated for relocation?"

041 CC1 All coastal developments must be required to prove that the changes made will not impact natural coastal processes, habitats and species. CC3 is critically important as demonstrated by the recent flooding in Hayle arising as a result of poor drainage plans in a catchment area some distance away by a recent housing development. Coastal development must respect all marine and terrestrial designations for example SSSI, MCZs, SPAs etc. Development on any wildlife sensitive or designated sites should not be supported.


266 At Policy CC1, item 2, I would add “c) would not affect the natural balance and stability of the coastline or exacerbate the rate of shoreline change to the extent that changes to the coastline are increased nearby or elsewhere.” - At Policy CC3, item 5, ..” rather than “…and predicted impacts of climate change…” I would say “…and predicted impacts of climate change and sea level rise…”; and rather than “…more frequent episodes of extreme heat and rain” I would say “…more frequent episodes of extreme heat, storms and high tides, heavy rainfall and storm surges.”.

253 CC1 support CC2 Would any development identified in the Neighbourhoosd Development Plan be subject to assessment by the Coastal Change Management Plan? CC3- Support - but need to emphasise no development in the Flood plain or predicted flood plain areas under best predicted climate change scenarios.. CC4 Would suggest wording to support SUDS rather than sound restrictive. They can play a useful role in flood management and Biodiversity."

005 To protect areas, such as Hayle, from erosion we would like to include that where a Shoreline Management Plan has stated that dredging and a net removal of sand from a system is discouraged, then a Costal Protection Authority licence should not be granted. This is unless it can be proven that there will not be a net loss of sediment, or it is for an emergency measure. Likewise there should be severe penalties if any dredging activities occur in these areas without a licence.

403 5. Not sure, would need to understand options better as this could have a significant impact on coastal villages such as Portreath

163 1. I particularly support policies CC3 and CC4 2. Developments should not be permitted on floodplains. 5. I think the proper support and expertise should be the priority as it should not be left to volunteers in communities who may not have all the required expertise. If you think that this would be a better option, and you are limited by resources, perhaps the council should be campaigning for more resources on this.

280 Agree policies seems right. Not really in a position to know too much about subject but realise that flooding and sea level rise will be a major concern for coastal communities.

109 The protection and policy requirements already afforded to designated landscapes must not be diminished by this

292 1. Although not qualified to give informed comments it is clear from walking coastal footpaths that coastal erosion is a significant issue. No structural developments should be permitted in these areas unless it is to protect them. I have also seen first hand new housing developments on land that is known to flood. To allow buildings to progress massive water pumps are seen in use to cope with the ingress of natural groundwater – is this sustainable?" 2.This is another big and complex topic but the approach appears about right. 3. No other than it is understood that the Crown have foreshore rights – do they also have responsibilities?

407 1. Cumulative development numbers should be allowed for. 2. Floating homes, water tight homes and stilt homes should be considered 3. The use of any developed policies for macro management for areas like Saltash, which is on a “shared estuary and river” need to take account of other authorities involved.


4. Timescales for establishing flooding “demand” should be part of any group of mitigation proposals We should consider (part) funded relocation as a final option for small groups of housing even if they are not in a management area. 5 If this cannot be done, “example mitigation plans” should be produced to give a framework on which to build together with funding on a “time before risk” basis."

408 There should be greater emphasis on CC4, 3 – not increase flood risk elsewhere

411 5. CC4: this is a fundamental biological diversity need to expand habitat structures where natural water from sites can flow into wetlands which can enhance Natural Englands premise of promoting the need for rewilding nature in accordance with past EU directives of restoring biodiversity of historical importance; part of a relandscaping to nature of ponds, lakes and wetland habitats and hydrophytic trees and expanding the distribution for European Beaver and Otter in such locations as needed. E.g. One particular area which is being considered is the Roswyn Valley in west Camborne close to the Local Sustainable Development Plan for the Tregenna Lea Estate close to Penponds and the Ancient and Veteran Woodlands which can be saved from eradication by a ecological SuDS system. Investigations with the developer are being hoped and local specialist wetland ecologists and the Beaver Trust are being requested for pragmatic input.

329 1. I would support this if the criteria for developments was based on truly affordable residential dwellings that are low impact, community focused and have minimal impact on the local environment. If these were movable/demountable dwellings such as yurts, cabins, etc powered by on-site renewables that would suit all of the needs outlined above. I would definitely not support developments aimed at Second home owners, tourists or anything that further impacted on the housing crisis already existing for many Cornish residents. The focus moving forward should also include a requirement for Cornish businesses to be prioritised in any tender for building works/developments and for a minimum number of staff to be employed from the local area including as apprentices. 5. I would need to understand the possible alternatives before commenting

412 CC3- Should this not state clearly that developments in the flood plain will not be allowed

264 Cornwall CLT welcomes the proposals

095 This is a good plan. I attach our brochure, “Friendship Cohousing at Maningham BROCHURE 10.09.2020” We hope to be working with you!


417 The JLP councils support the identification of Coastal Vulnerability Zones and candidate Coastal Change Management Areas on the policies map.

419 Coastal Change and Flooding: We consider it is difficult for us to comment on coastal change and flooding until we see maps in this regard and affected areas.

421 5. Generally good.

243 1. Yes. Foul water discharge – no mention of any policy to limit overloading of sewage systems and preventing river/marine pollution. See comment on water pollution (Policy C1.10) above. 2. Policy CC3.2 We particularly welcome the requirement for exceedance flow mapping to be included in drainage statements. Policy CC4.7 The continuing failure of central government to enact Schedule 3 of the Flood and Water Management Act 2010 means there is no statutory responsibility for ongoing management of SuDS systems. So while it is positive that Policy CC4.1 requires the provision of a plan and mechanism for ongoing maintenance, local communities need


reassurance that such plans and mechanisms are viable and enforceable over the lifetime of the development. Development proposals should demonstrate that adequate contractual and funding arrangements are in place to ensure the continuity of the plan over the lifetime of the development, in order to avoid future liability for public bodies and the community.

198 3. Draft policy CC1 Point 2 of the draft policy refers to private sea defences being pursued only if there is public benefit and it is in line with the SMP. This can be greatly simplified if the requirement is set as “no adverse consequence elsewhere”. CC2 The Coastal Change Management Areas are not defined in this consultation document and therefore it’s not possible to understand whether or not these are different from the areas identified in the Shoreline Management Plan. In turn, it is not possible to comment on the emerging policy in any detail. In terms of Coastal Change, the Shoreline Management Plan provides an important starting point. However, the SMPs are updated very infrequently, and certainly not as frequently as Development Plan Documents do. As such, they do not respond to changing circumstances or opportunities. It is important that Development Plan Documents use up to date information and not solely base the strategies on dated SMPs. The policies should provide flexibility for landowners to protect their interests (including business, jobs, etc for the local economy), where this is possible without unacceptable adverse impacts further along the coastline. The emerging policy should provide this flexibility." CC3 - Part 3 of draft Policy CC3 requires proposals to be informed by an assessment of the general drainage and impact of flooding on both existing and proposed development. This should not be required for all proposals. The consideration of flooding should only be required in line with the thresholds set out in the National Planning Practice Guidance. The policy needs to clarify this so it is not a blanket requirement for an assessment which will not be required in all cases. The Environment Agency maps should be a starting point and not the be all and end all in consideration of such matters. We know they not fine grained enough and/or can be inaccurate."

019 1. The Introduction to this section notes Cornwall’s distinctive and large coastline but does not consider the historic character of the landscape and seascape, nor the that of its historic ports and harbours, and villages and other settlements (many of which are conservation areas) let alone the many individual designated and non-designated heritage assets that are located on coast and public access to enjoy them (where appropriate). It also does not consider the role of upland mires, e.g. Bodmin Moor, in relation to basin and catchment level water management and the potential for peatland restoration for carbon capture. Intertidal peats are also particularly vulnerable to coastal changes and episodic damage due to storms and tidal surges. In the same way that dunes should not be impacted by permanent and fixed structures, neither should intertidal peats. The peats provide important habitat zones and are a source of palaeoenvironmental data and potentially evidence of past human activity. Intertidal peats can be recorded on a national database. Some of these are at threat of coastal change and flooding and are on Historic England’s Heritage at Risk Register. We consider these matters should be addressed in the Introduction to this section. 2. We note the intent of Policy CC1 but it is unclear is the Coastal Vulnerability Zone is already designated or not. Paragraph 19.4.2 implies that it is. However, the Interim SA Report states that it being considered at paragraph 3.71. Coastal areas contain a wealth of


heritage assets, especially non-designated heritage assets of archaeological interest. Heritage assets (designated and non- designated) will be present in a Coastal Vulnerability Zone and can be affected by natural erosion, flooding, infrastructure and management schemes intended to address coastal change as well as by new development (temporary and permanent). We seek assurance that the designation of a Coastal Vulnerability Zone will be informed by a proportionate heritage impact assessment. Further information can be found on our website about how to approach this type of work in the context of Shoreline Management Plans, which will still be of relevance. This work will also need to consider how existing Heritage at Risk will be addressed in the Coastal Vulnerability Zone, as well as whether any other heritage assets could potentially become ‘at risk’, how their conservation will be approached and who any whole or partial loss will be recorded and made publicly available. We would welcome further discussion on this matter. We consider that parts 1, 2 and 3 of this Policy should have new criteria that require new and replacement development and infrastructure, including sea defences and cliff stabilisation works, to conserve and enhance the significance of heritage assets, including their settings, and the wider townscape, landscape and seascape. These criteria should also enable development other works that are intended to conserve heritage at risk. In relation to part 3, it should also be noted that any changes to hydrology in wetland areas, including floodplains, mires and peats, will have a potential impact on the buried archaeological and palaeoecological resource. This may be positive if desiccation of sensitive sites or erosion of vulnerable buildings or archaeology is prevented, but in the case of already compromised resources, rewetting may be highly destructive. Programmes of base level recording and on-going monitoring may be needed where proposals affect wetland areas, mires and peat. We do not yet fully understand the impact of peatland restoration on sensitive archaeology. Historic England is actively considering how heritage can be integrated in proposals for peatland works/management in advance of publication of the England Peat Strategy later this year. Appropriate methods for peatland restoration should therefore be devised with input from historic environment specialists from the outset. We would welcome further discussion on appropriate actions together with your local authority conservation and archaeology staff to address these points As such, we consider that a new criterion is required here to reference to the need for appropriate assessment, recording and monitoring of buried archaeological and palaeoecological resource where relevant. 3. We note from the explanatory text in paragraphs 19.2.3 and 19.5.1-3 that the Council intends to identify candidate Coastal Change Management Areas (CCMAs) on the policies map but leave communities to prepare Coastal Change Management Plans (CCMPs) and include them in Neighbourhood Plans. Coastal areas contain a wealth of heritage assets, especially non-designated heritage assets of archaeological interest. Heritage assets (designated and non-designated) can be present in candidate and designated CCMAs. Heritage assets can be adversely affected by natural erosion, flooding, infrastructure and management schemes intended to address coastal change as well as by new development (temporary and permanent). Areas identified for relocation of dwellings and infrastructure can also contain heritage assets. These changes may also affect wider areas of townscape, landscape and seascape. This should be recognised in the explanatory text for this Policy. We also seek assurance that the designation of candidate CCMAs and designated CCMAs and the preparation of CCMPs have been informed by a proportionate heritage impact


assessment and include designated and non-designated heritage assets. Further information can be found on our website about how to approach this type of work in the context of Shoreline Management Plans, which will still be of relevance. This work will also need to consider how existing Heritage at Risk will be addressed in candidate and designated CCMAs, and CCMPs, as well as whether any other heritage assets could potentially become ‘at risk’, how their conservation will be approached and who any whole or partial loss will be recorded and made publicly available. We would welcome further discussion on this matter. In respect of Policy CC2 itself, we would like to see the introduction of new criterion that requires relocated development and infrastructure to conserve and enhance the significance of heritage assets, including their settings, and the wider townscape, landscape and seascape. 4. We support the intent of Policy CC3 as heritage assets can be damaged or even destroyed by flooding. Some heritage assets may be ‘at risk’ due to flooding and/or addressing flood risk may be a contributing factor to finding long-term solutions to their conservation. We offer a lot of information advice about flooding and historic buildings and older homes on our website, including on resilience and recovery, and on flood remediation measures. Please be aware that any changes to hydrology, including in adjacent wetland areas including floodplains, will have a potential impact on the buried archaeological and palaeoecological resource. This may be positive if desiccation of sensitive sites or erosion of vulnerable buildings or archaeology is prevented, but in the case of already compromised resources, rewetting may be highly destructive. Programmes of base level recording and on-going monitoring may be needed where proposals affect wetland areas, mires and peat. Given the above, we consider that a new criterion should be introduced into this Policy that requires the impacts of flood risk reduction development proposals to consider the impacts (positive and negative) on the significance of heritage assets, including their settings, as well as on the wider townscape, landscape and seascape. The criterion should also encourage the proposals that deliver resilience for heritage assets that are at risk from flooding and other climate change related effects. It should include reference to the need for appropriate assessment, recording and monitoring of buried archaeological and palaeoecological resource where relevant. Further information and advice can be found on preserving archaeological remains in situ in Preserving Archaeological Remains (2016), particularly Appendix 3 on Water Environment Assessment Techniques and Appendix 4 on Water Monitoring for Archaeological Sites and in the following draft scientific review on Peatlands and the Historic Environment (2010). Other relevant advice can be found in Streets for All (2018) and the South West version (2018), The Settings of Heritage Assets (2017). 5. We note the intent of Policy CC4. The provision of SuDs may, however, have unintentional effects on the historic environment. As such, we are seeking the introduction of a new criterion into this Policy (with additional explanatory text as required) that requires the significance of heritage assets, including settings, and the historic environment to be conserved and enhanced. This will help to reduce the risk of any detrimental impacts on the historic environment as a result of engineering, urban and


landscape design responses to problems of surface water run-off and flooding, by helping to ensure the heritage dimension is included in SuDS decision-making and design. Relevant advice can be found in Streets for All (2018) and the South West version (2018), The Settings of Heritage Assets (2017). 6. Coastal Vulnerability Zones: Coastal areas contain a wealth of heritage assets, especially non-designated heritage assets of archaeological interest. Heritage assets (designated and non-designated) within a Coastal Vulnerability Zone can be affected by natural erosion, flooding, infrastructure and management schemes intended to address coastal change as well as by new development (temporary and permanent). While we agree with the Historic Environment appraisal that there is the potential for a Coastal Vulnerability Zone to contain policy provisions that would support the management of heritage assets within this Zone and their conservation and enhancement, the associated draft Policy CC1 in the DPD does not contain such provisions.

168 1. Yes, about right. 3. CC2 point 2- Should biodiversity be mentioned here? We have seen proposals for cliff stabilisation work previously that were not assessed for biodiversity as the cliff required separate consent from the Marine Management Organisation but it was not within their remit to comment on terrestrial biodiversity (a possible bat roost) so this is a potential loophole.