The Plan doesn't recognise climate change being one of the key challenges the borough as whole faces, climate change should be added as a key challenge to the plan.

Support the sentiment in policy requiring new major developments to reduce emissions beyond the minimum requirements or meet a percentage of their energy needs from renewable or low carbon energy sources. We also back the requirement for large residential developments to consider district heating systems where it is feasible and viable to do so, noting the council has recently secured HNDU funding for heat mapping to help establish the feasibility of potential heat networks locally. Env7 Policy should be strengthened to include sufficient acknowledgement of the future homes standards that will be effective in building control part L regulations from 2023. Interim arrangement from 2020 are in place and these should also be referenced including the ban of gas boiler sales from 2035. Policy should provide for heat pumps in the policy/ plan. The policy should aim to go over and above current standards for new no residential buildings. Community led initiatives should be positively supported and consider use of Greenbelt for renewables as very special circumstances. New employment developments could be required to identify solar sites to support a change to solar energy for e.g. HGV charging.

The NPPF. Identifies that local plans should ?Consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure, where this would help secure their development? (Section 14, p. 45).' There is a lack of identification of sites for renewable energy in the draft plan. We believe it justifiable that some land in the green belt is appropriate for renewable generation projects, particularly solar farms, where the nature of such developments and the climate emergency benefits of producing clean energy can be justified in the context of the climate emergency.

We welcome Part 4 of Policy DC6 (Section 8.6, p. 139) requiring new developments to have integrated climate change adaption measures and energy efficient design. We feel this could be built on within the Plan to include specific examples of measures that can be considered on a case-by-case basis where they might be feasible. The NPPF outlines how the approach of plans to mitigate and adapt to climate change should take into account long-term implications such as the risk of overheating from rising temperatures. In spite of this, the revised Local Plan does not mention overheating or rising temperatures in relation to building adaptation. Reading Borough Council?s Local Plan provides detailed suggestions of how new and existing buildings should demonstrate that they have considered measures such as solar shading, thermal mass, heating and ventilation, appropriately coloured materials, green and brown roofs, green walls, tree planting and other green networks that provide shading for new-builds. It should be mandatory for developers to demonstrate how they have considered and included these measures. The intention of including this in the Local Plan is to avoid the need to retrofit these buildings in the future, as extreme weather events will only become more frequent and intense. All new developments should present climate statements.

The policy should be amended to require the consideration of green infrastructure in urban areas including green walls etc.

The view of the WCEC is that the extraction of hydrocarbons for energy is environmentally unacceptable. The policies are too permissive in relation to the Paris Climate Agreement and UK targets for carbon emission reduction. It is suggested a more rigorous approach is taken and that hydrocarbon extraction is treated the same as peat extraction.

Section 9.7 (p.170) refers to the 2015 Paris Agreement and 2008 Climate Change Act in relation to UK emission reduction targets. They feel the policies embedded throughout the Plan could be more aligned with such targets. If Warrington are to contribute to legally set net-zero targets, the plan should set out a science-based carbon budget for the local area compatible with these. We maintain that there is a lack of current data in Section 9.7 of the Plan relating to Warrington?s emissions and recommend adopting the Tyndall Centre?s Local Authority Carbon Budget report tool which outlines Warrington must meet reductions in CO2 emissions on the scale of 13.7% per year [5]. This would provide current policies with greater justification and any additions or changes can be made in line with these figures. We feel taking an evidence-based approach to reduction targets for new developments is crucial to make policies more effective and would be invaluable to the Plan as a whole.

Targets and monitoring indicators relating to Policy ENV7 (Appendix 2, p.277) could be strengthened. While we support measuring the installed renewable energy capacity and targets to promote renewable infrastructure, we feel some indicators could be made more explicit. It is proposed that there are quantifiable targets in relation to low-carbon policies, such as a target tonnes of CO2 per capita for new developments. These can be monitored more easily and present more meaningful information when comparing new developments. Likewise, Policy INF1 relating to sustainable transport could exercise more explicit monitoring metrics for low-carbon transport. For instance, the percentage of journeys made by bike or on foot, rather than the fluid measure of ?levels of cycling?

The natural environment has immense value for its carbon storage capacity; a store that will play a vital role in efforts to reach net zero emissions. There is a need to improve the capacity of these natural stores. Encourage the consideration of the degree to which the Local Plan can facilitate the increase of natural carbon storage, which in turn may support a net gain in biodiversity. The particular mention in the text associated with Policy DC4 of the need to restore peat bogs wherever possible in the Borough is welcomed. Suggested further mention of the general need to enhance soil health and woodlands wherever possible to improve natural carbon storage. It is important to flag up the role of mature trees for carbon storage and the need to avoid their loss through development. Replanting trees in compensation sites may not deliver the same immediate CO2 removal benefits. We believe policy should aim to promote the incorporation such trees into scheme designs without the need for removal.

The WCEC support the requirement for new developments to integrate electric vehicle charging infrastructure. They suggest the Plan set requirements relating to electric vehicle charging that exceed the minimum requirements set out by the Council?s Parking Standards. This would additionally correlate with policies outlined in the fourth Local Transport Plan [9] and contribute to LTP4 targets. Overlap with the LTP4 could be cross-referenced within the Local Plan in its justification of Policy INF1, to provide a more holistic outlook and align targets across different Council?s strategies.