Chapter 5
42) Do you agree with the approach to planning for climate change in policy CC1? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI agrees with this approach to plan-making for climate change and supports inclusion of the wording in support of a radical reduction in greenhouse gas emissions. However, such strength in wording contained in CC1(1)(a)(i), needs to be better harmonised with the rest of the Framework, for example in relation to our comments on sustainability considerations in PM9(2)(b) as set out in our response to Q14(a). Similarly, the RTPI believes that CC1(1)(a) should be strengthened with explicit reference to the role of local plans in identifying development patterns which improve or seek to improve the use active travel and public transport.
Given that CC1(1) gives reference to towards the net zero transition, the RTPI believes that this policy would benefit from highlighting the role of the development plan in positively identifying a range of development opportunities to support the securing of electricity and heat from renewable, low carbon and zero emission sources, including energy storage and grid infrastructure upgrades. This includes encouraging a plan-led approach to encouraging co-location to better support application of CC2(1)(e). We welcome the inclusion of reference to the assessment of baseline carbon emission, although we would welcome the publication of a standardised methodology to this assessment in order to apply this policy in a consistent manner across the country. Furthermore, the RTPI would welcome the consideration of carbon auditing as it may provide a fuller picture of whether a plan is contributing to a radical reduction in greenhouse gases.
Regarding reference to development plan, CC1 would benefit from a clearer delineation and distinction regarding the role of SDSs and local plans on this matter.
43) Do you agree with the approach to mitigating climate change through planning decisions in policy CC2? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) If not, what additional measures could be taken to ensure climate change mitigation is given appropriate consideration?
The RTPI would recommend the removal of the words “where relevant” in CC2(1). In regard to CC2(1)(e) we would also welcome weight to be brought to proposals that contribute towards climate change mitigation.
44) Do you agree with the approach to climate change adaptation through planning decisions in policy CC3? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) What additional measures could be taken to ensure climate change adaptation is given appropriate consideration?
No further comment.
45) Does the policy on wildfire adaptation clearly explain when such risks should be considered and how these risks should be mitigated? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons
Whilst we welcome acknowledgement of wildfire risk and mitigation, we believe this should include a role for local plans to identify areas that are at heightened risk from wildfires.
46) How should wildfire adaptation measures be integrated with wider principles for good design, and what additional guidance would be helpful?
Both plan-making and decision-making on this matter would benefit from the establishment of clear means to assess wildfire risk, including metrics and methodologies. When development is coming forward in an area deemed vulnerable, specific design interventions should then be applied. We note well established mechanisms for wildfire adaptation in other planning systems globally, in particular in Australia.
47) Do you have any other comments on actions that could be taken through national planning policy to address climate change?
No further comment.
