First Draft Watford Local Plan 2020-2036
Chapter 6: Tackling Climate Change, Adaptation and Resilience
6. 1. Introduction
6. 1. 1. Recognising the importance of climate change and how this will affect future generations, the Government, as part of the Climate Change Act (2008) set out a legally binding target to reduce the UK's greenhouse gas emissions to 80% below 1990 levels by 2050. The overall objective is for all new development to be 'zero carbon' in the future. This is reflected in the latest recommendations by the UK Committee on Climate Change in the report 'Net Zero – The UK's contribution to stopping global warming (2019).
6. 1. 2. The United Nations' Conference on Climate Change, Paris 2015, has provided a starting point for this, along with the United Nations' Sustainable Development Goals1, both of which the UK government has committed to. Goal 11 of the Sustainable Development Goals considers 'Sustainable Cities and Communities'2, and is the goal most relevant for local authorities in terms of their land use planning functions. How we manage job growth, housing and transport will play an important part of meeting climate change goals.
6. 1. 3. Planning has an important role to play in meeting the challenges of climate change. There is a need to meet the challenges of climate change in terms reducing greenhouse gas emissions (mitigation) and to improve resilience (adaptation). While the framework for reducing these emissions is set out through national guidance, much of the implementation will need to be at the local level.
6. 1. 4. The draft Local Plan is seeking to address the issue of climate change by making the achievement of sustainable development a central theme throughout the document. This is reflected in policies that:
- focussing new development in the most sustainable locations where there is good access to public services, facilities and public transport;
- encouraging higher density development in the most suitable areas of the borough;
- requiring new development to make better use of limited resources by being more energy and water efficient;
- supporting new infrastructure to encourage walking and cycling to reduce reliance on private vehicles for local journeys;
- setting out a more balanced approach to car parking; and
- protecting our green spaces to support biodiversity, encouraging people to have healthier lifestyles and to mitigate the potential impacts of climate change such as urban heating and flood risk.
6. 1. 5. Watford Borough Council declared a Climate Change Emergency in July 2019 in an effort to respond to these challenges. A key objective of this declaration is for the council to be carbon neutral by 2030. To understand the scale of greenhouse gas emissions and the challenges facing the borough, emissions for local authorities are monitored annually. This provides a benchmark against which Watford Borough Council can monitor progress towards becoming carbon neutral in the future.
6. 2. Sustainable Construction and Design
Why is this policy needed?
6. 2. 1. To tackle climate change the Local Plan will seek to reduce water stress, risks from overheating and work towards ensuring buildings are more energy efficient.
6. 2. 2. Reducing domestic and commercial energy use through the inclusion of energy efficiency and low carbon technologies as part of new developments can aid progress in this matter. This can reduce the cost of operating new homes, which in the process will use less energy to benefit the environment. To achieve this, the following energy hierarchy needs to be considered:
- Be lean: use less energy
- Be clean: supply energy efficiently
- Be green: use renewable energy
6. 2. 3. The first priority is to use less energy. Therefore, the importance of ensuring maximum energy efficiency in domestic and commercial buildings to reduce the amount of energy and natural resources being consumed is the starting point for the policy.
6. 2. 4. Current national policy notes that local plans should take account of the long term implications for water supply in terms mitigating and adapting to climate change. The 2013 Water Stress areas – Final Classification states that the Thames Water Area and the Affinity Water Area are areas under Serious Water Stress (Environment Agency, 2013). Water stress will be a critical issue going forward in Watford and the South West Hertfordshire area, particularly should the trend of rising temperatures continue.
6. 2. 5. If not well designed, buildings can create living spaces that can be uncomfortable and unhealthy. In these circumstances, people can experience overheating. It is important that energy efficient buildings not only include building techniques and materials to reduce energy consumption but are designed to have quality interior living spaces and structures (walls, ceilings, roofs) that provide good air circulation where interior temperatures and humidity can be easily and naturally regulated.
What is the policy intended to do?
6. 2. 6. This policy seeks to set out the requirements that new proposals have to meet in terms of sustainable construction and design. More specifically, in relation to energy efficiency and low carbon technologies, water supply and overheating to provide high quality homes and work premises and reduce the potential impact on the environment. How proposals will comply with this policy will need to be detailed in a Sustainability Statement.
Policy CC6.1 Sustainable Construction and Design
Proposals will be supported where they demonstrate they have provided appropriate design and other measures to address climate change, complying with the standards below, through energy efficiency, water efficiency and overheating.
Residential proposals for 5 or more units and/or non-residential proposals for 1000 sqm or more will need to provide a sustainability statement. The statement will detail how the requirements below on energy efficiency, water efficiency and overheating have been met.
Low Carbon Energy and Energy Efficiency
The following is required as a minimum unless it can be demonstrated that it would make the scheme unviable:
- All residential development of 5 units or more should achieve an energy performance standard equivalent at least 19% carbon emission reduction improvement against Part L of the Building Regulations (2013);
- Non-residential development of 1000 sqm or more should achieve BREEAM Very Good standard.
The layout, orientation and design of all proposals should maximise energy efficiency and conservation of energy. Proposals for residential and non-residential development which incorporate renewable energy and low carbon technologies to contribute to clean energy supply will be supported.
Development should ensure efficient use of water. Proposals which include water saving measures and equipment will be supported. All residential development should be designed to achieve water consumption rates of 110 litres or less per person per day.
New Developments will need to demonstrate how measures have been implemented to avoid overheating. This should include measures such as:
- Energy Efficiency Design including orientation and planting;
- Orientation and a material palette which reduces heat retention;
- Avoiding single aspect south facing units;
- Building design including building height, fenestration, green roofs and wall;
- Passive ventilation and shading solutions.
Air conditioning and mechanical ventilation should not be provided unless all other options have been exhausted.
6. 3. Flooding and Drainage
Why is this policy needed?
6. 3. 1. The National Planning Policy Framework requires the planning system to minimise vulnerability and improve resilience to the impacts of climate change. For plan making this should ensure a proactive approach to adapt to climate change, taking into account the long-term implications for flood risk.
6. 3. 2. Development should be directed away from areas at the highest risk (existing or future). Watford is a constrained administrative area with limited land potential for development. The site allocations for the local plan have been informed by a Strategic Flood Risk Assessment Level 1 and Level 2.
6. 3. 3. Windfall development (sites not allocated in the Local Plan) that may come forward in Flood Zones 2 and 3, will not have undergone the required Sequential and Exception Test in the Strategic Flood Risk Assessment.
What is the policy intended to do?
6. 3. 4. The policy seeks to establish the flood risk assessment requirement for development proposed on sites with land wholly or partially located in Flood Zones 2 and 3. Allocated sites can be presumed as having gone through the required Sequential Test. However, the Exception Test may need to be reapplied if relevant aspects of the proposal had not been considered when the test was applied at the plan making stage, or if more recent information about existing or potential flood risk should be taken into account.
6. 3. 5. The policy also sets an expectation for the treatment of surface water flood risk and establishes the requirements for sustainable urban drainage systems.
Policy CC6.2 Flooding and Resilience
A site specific flood risk assessment is required for all development in Flood Zones 2 and 3.
Proposals on sites allocated for development in the Local Plan that are located in Flood Zone 2 and 3 are required to demonstrate that the exception test has been complied with. For all other sites both the sequential test and the exception test needs to be satisfied.
In Flood Zone 1, an assessment should accompany all proposals involving:
- Sites of 1 hectare or more; land that has been identified by the Environment Agency as having critical drainage problems;
- Land identified in a strategic flood risk assessment as being at increased flood risk in future; or
- Land that may be subject to other sources of flooding, where its development would introduce a more vulnerable use.
Development should only be allowed in areas of flood risk where the site specific flood risk assessment has demonstrated that:
- Within the site, the most vulnerable development is located in areas of lowest flood risk, unless there are overriding reasons to prefer a different location;
- The development is appropriately flood resistant and resilient;
- It incorporates sustainable drainage systems, unless there is clear evidence that this would be inappropriate;
- Any residual risk can be safely managed; and
- Safe access and escape routes are included where appropriate, as part of an agreed emergency plan.
Sustainable drainage systems should be incorporated into the landscape design of the site.