Full text:
The wording of this objective is vague and does not clearly define what the plan aims to achieve. Consider rewording this to say “Support the achievement of a net zero carbon Medway and tackle the negative impacts of climate change through adaptation” or “Working together for a net zero carbon and resilient future.”
• The first bullet point feels like a list of buzzwords. Please revisit some of the comments made previously around the vision in Section 3, for example:
o Establish the Local Plan as a framework to achieve significant reduction in carbon emissions. This should be the driving principle, not just environment as a theme; likewise
o elevate the significance of having clear adaptation plans to minimise the effect of the impacts of climate change (not just “seeking” measures) on people and places most at risk.
o the term “net zero carbon” should be used consistently through the document rather than intermittently with terms such as “zero carbon” or carbon neutral.
o adaptation measures are not limited to mitigating flood risk; it should also include overheating and droughts
o To deliver on Medway’s net zero carbon targets, “Drive reductions in the carbon impacts of new homes by setting minimum requirements for developers to ensure that whole life carbon costs are considered (embodied carbon of materials and processes).
o We welcome the consideration to protect vulnerable communities as these groups are most likely to feel the effects of climate change. This should be its own bullet point (perhaps under the objective around communities).
o Nature based solutions and transport are mentioned in the first bullet but should be removed from here and warrant having their own bullet point so as not to dilute the significance of them.
o Energy needs its own bullet point and there should be a commitment to determining the future energy requirements based on the development needs of Medway to support a clear and comprehensive Local Area Energy Plan, including large scale and localised renewable energy solutions. It is essential that consideration should be given to the most and least environmentally sensitive sites for deployment of solutions to avoid negative impacts.
o In the bullet about transport, it should reference the travel hierarchy to include minimising the need for travel in the first instance through spatial planning.
o In the bullet about green and blue infrastructure, more emphasis is required around addressing resilience through the creation and protection of natural assets. The current statement doesn’t quite make sense, “providing resilience for nature through better connectivity and conditions.” Also, bring in the co-benefits of enhanced biodiversity, good air quality and improved public health being realised.
o See previous comments about waste (Section 3).
o A final bullet should be to establish clear guidance and high standards for developers to adhere to which reflect the aspirations of net zero carbon and adaptation. Also, to prioritise climate change when determining development applications.