Regulation 18 Draft Local Plan
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Regulation 18 Draft Local Plan
Local Plan Preparation
Representation ID: 2064
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
We are concerned that the consultation is opaque. There is no guidance on how to interrogate the documentation. Wild Justice has recently won a court case against Defra for not providing a comprehensible consultation, so clearly the courts are concerned about consultation being valid. We cannot see the difference between the attachments, “Climate Change Study”, “Legislation and “Carbon Reduction".
Some of the evidence base is very old e.g. the Landscape Character Assessment (dated 2007, but written in 2005). It’s mentioned that this should be used as a baseline for assessing agricultural policies, so a refresh would be helpful in assessing this.
We note that in the Supplementary Planning Document (para 2.16.3) refers to the Living Landscapes Approach. This document was dated 2014 and I have been unable to verify that it is still current.
Object
Regulation 18 Draft Local Plan
Chapter 5 – Climate Change and Energy
Representation ID: 2065
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
Given that the climate change projections, based on the InterGovernmental Panel on Climate Change assessments demonstrate that we are now on the high emissions scenario, sea level rise is calculated to have risen by 12cm, against the 1990 baseline and will probably increase to 24cm by 2030. And given that the protection of the low lying fenland is already at risk due to ancient pumping systems, as demonstrated by recent flooding, it seems unlikely that this land will be suitable for building on now/in the near future. We would like to suggest that a better evidence base is obtained to ascertain risk. This will particularly impact on the Deepings, Bourne, Baston, Langtoft, Thurlby. We cannot rely on sea defences, as they have not been maintained and groundwater levels are so high that they would not be effective anyway. There is a risk of back flooding via the Humber and the Trent. To make developments viable there will need to be a lot of work done. It would be better to allow the dried and shrunken peat to re-wet, so that is expands and acts as a sponge to hold back sea water. Once the sea has inundated the land it is useless. This has recently been the subject on concern for a proposed development in Skegness, which might now be abandoned.
Object
Regulation 18 Draft Local Plan
SP1: Spatial Strategy
Representation ID: 2066
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
Housing demand is driven by the need to invest and need. There are sufficient buildings to supply the latter. The Green Party would like to see the creation (not necessarily building) of more homes for social rent in the Local Plan. This could be achieved by negotiating Joint Venture Agreements with the private sector, as well as the more conventional financing of schemes. The private sector should be incentivised to focus on refurbishment e.g. insulation and other retrofit.
Object
Regulation 18 Draft Local Plan
EN3: Green Infrastructure
Representation ID: 2067
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
EN3: green infrastructure: does not focus enough on existing settlements and the Biodiversity Opportunity Mapping seems to trump the Green Infrastructure (possibly because the former is in legislation). Green Infrastructure can help with flood mitigation, urban heat island effect, air quality etc and it’s critical that adapting to climate change is not overlooked, given that we are already tied into the impact of an over 1.5oC increase in temperature, and there is no sign of any major political Party having a mind to do anything about this.
The UK’s adopted policy (often called 30x30), as signed up to by Boris Johnson, following the Biodiversity COP15 is to set aside 30% of all land and water to be devoted to biodiversity, as a priority, and in perpetuity. This means that even where indigenous people’s have used the land or land has been used historically for for cultural reasons, biodiversity need must take priority. Biodiversity net gain is insufficient to reach this target - it is simply a distraction. Policy in the Local Plan should be aiming to help the UK government’s commitment to the UN target. The Wildlife Trust have strong documentation and policy on how to achieve this.
Object
Regulation 18 Draft Local Plan
EN6: The Historic Environment
Representation ID: 2068
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
Has anything been done to close the loophole that permits people to pave over their driveways?
Object
Regulation 18 Draft Local Plan
Sustainable Building and Construction
Representation ID: 2069
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
"poor and mediocre development should be refused"!! Quote from NPPF
We sincerely hope that this quote is taken note of. But we do not know what it means.
Support
Regulation 18 Draft Local Plan
DE1: Promoting Good Quality Design
Representation ID: 2070
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
Is interesting. It has been amended and we hope it is adhered to.
Object
Regulation 18 Draft Local Plan
SB1: Sustainable Building
Representation ID: 2071
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
Given the various restrictions imposed by government edicts and viability, how will new developments be 1. zero carbon. 2. water neutral? 3. Low carbon travel?
NB Net Zero by 2050 is too late.
Object
Regulation 18 Draft Local Plan
GR2: Sustainable Transport in Grantham
Representation ID: 2072
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
Points to Grantham Transport Strategy which points back to the local plan. This needs rectifying. The Transport Strategy is a load of woffle. What about the rest of the area? This is not a strong enough policy to depend on for the local plan!
Object
Regulation 18 Draft Local Plan
SKPR-278 (GR3-H1): Spitalgate Heath - Garden Village (Mixed Use Allocation)
Representation ID: 2073
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
No mention of River Witham, which is a pristine river with white clawed crayfish which are protected. No mention of potential flooding impacts. Houses will be built built on springs with the river at the foot.