Local plan scoping consultation

Comment

Representation ID: 1618

Received: 14/08/2026

Respondent: Mr Len Harvey

5.76 The minerals strategy should apply the waste and resource hierarchy to mineral demand by maximising reuse, recycled and secondary aggregates before allocating additional primary extraction. New mineral sites should be assessed for biodiversity, ecological connectivity, landscape, water, carbon, air quality, transport and cumulative impacts, with enforceable restoration and aftercare requirements. No new peat or coal extraction sites should be allocated, and peatland should be protected for its biodiversity, hydrological and carbon-storage functions.

Comment

Representation ID: 1619

Received: 14/08/2026

Respondent: Mr Len Harvey

5.87 Residual waste capacity should be planned on the basis that prevention, reuse, recycling and composting are prioritised before energy recovery or disposal. The Local Plan should avoid creating excess energy-from-waste capacity that depends on continued production of combustible waste and could undermine higher levels of the waste hierarchy. Any new recovery capacity should demonstrate genuine residual need, whole-life carbon performance, appropriate heat use where feasible, and no unacceptable local air-quality, transport or ecological impacts.

Comment

Representation ID: 1620

Received: 14/08/2026

Respondent: Mr Len Harvey

5.91 The proposed vision-led approach to transport is supported, but it should be translated into measurable outcomes. Site selection should favour places where everyday journeys can realistically be made by walking, wheeling, cycling and public transport, with clear accessibility and modal-share targets. Major development should provide necessary sustainable transport infrastructure from the earliest phases rather than relying on later delivery. Parking standards should support the stated objective of reducing car dependency rather than reinforcing it.

Comment

Representation ID: 1621

Received: 14/08/2026

Respondent: Mr Len Harvey

5.99 The Local Plan should explicitly retain and update the mapped ecological network established through current Policy ENV 1 and integrate it with the Local Nature Recovery Strategy. Site selection should protect ecological cores, corridors, stepping stones and restoration areas, not only designated sites. The Council should also commission evidence on whether biodiversity net gain above the statutory 10% is justified locally, while ensuring BNG complements rather than substitutes for avoidance of habitat loss.

Comment

Representation ID: 1622

Received: 14/08/2026

Respondent: Mr Len Harvey

5.103 The proposed natural-environment evidence is incomplete. Flood-risk, climate and peat studies are important, but the plan also needs an updated biodiversity baseline and ecological-network map, Local Nature Recovery Strategy spatial analysis, green-infrastructure assessment, landscape evidence, trees and hedgerows evidence, water-resource assessment and consideration of natural capital. These datasets should be available early enough to influence the land availability assessment and spatial strategy rather than being produced after potential development sites have already been shortlisted.

Comment

Representation ID: 1623

Received: 14/08/2026

Respondent: Mr Len Harvey

Climate adaptation should influence where development is located, not only how buildings are designed. Spatial options and site allocations should be tested against future climate scenarios covering river and surface-water flooding, overheating, drought, water availability and infrastructure resilience over the lifetime of development. The Plan should favour nature-based adaptation, including trees, soils, wetlands, sustainable drainage and connected green infrastructure, and avoid allocating sites where foreseeable climate risks cannot be reduced to acceptable levels.

Comment

Representation ID: 1624

Received: 14/08/2026

Respondent: Mr Len Harvey

The Plan should apply a clear carbon hierarchy: avoid emissions first, then reduce demand, maximise on-site low-carbon energy and use offsetting only for genuinely unavoidable residual emissions. Existing carbon stores must also be protected, particularly peat soils, woodland and established habitats. Peatland restoration is welcome, but development should not damage intact peat or alter the hydrology that sustains it. Carbon offsetting should not be used to justify unnecessarily high-carbon locations or development patterns.

Comment

Representation ID: 1625

Received: 14/08/2026

Respondent: Mr Len Harvey

The Local Plan should identify suitable areas and opportunities for renewable and low-carbon energy, grid reinforcement, storage and community energy rather than relying only on general supportive wording. Evidence should assess realistic generation potential and network constraints and should support rooftop and previously developed land where appropriate. Renewable infrastructure should be planned to minimise harm to biodiversity, peat, soils and valued landscapes while enabling the borough to make a measurable contribution to its carbon targets.

Comment

Representation ID: 1626

Received: 14/08/2026

Respondent: Mr Len Harvey

The ambition for very high energy efficiency is welcome, but terms such as "very high" and "wherever possible" are not measurable. Within its lawful powers and supported by viability evidence, the Plan should set clear performance requirements for energy demand, operational carbon, on-site renewable generation and embodied carbon. Current Policy ENV 7 already contains quantified requirements, so replacing measurable standards with aspiration would be a regression. Reuse and retrofit should be assessed before demolition wherever practicable.

Comment

Representation ID: 1627

Received: 14/08/2026

Respondent: Mr Len Harvey

5.120 The new Plan should retain the substance of current Policy REC 1, which protects open space unless strict tests are met. Open space should also be assessed as multifunctional green infrastructure providing biodiversity, cooling, flood management, carbon storage and access to nature, not solely recreation. The Open Space Assessment should identify inequalities in access, quality and quantity and set measurable standards for new development, with replacement space required to be genuinely equivalent or better in function, accessibility and ecological value.