Sustainability Draft Supplementary Planning Document

Comment

Representation ID: 10414

Received: 16/02/2024

Respondent: David Lock Associates

Response to North Hertfordshire Council’s Sustainability SPD Consultation, submitted on behalf of Urban & Civic

Comment

Representation ID: 10439

Received: 16/02/2024

Respondent: David Lock Associates

A sound evidence base will be required to justify a requirement to meet such a standard and it is considered that this SPD may not be the most appropriate way to secure this.

Comment

Representation ID: 10440

Received: 16/02/2024

Respondent: David Lock Associates

20% renewable energy (Silver); and 50%+ reliance on renewable energy (Gold) whilst admirable to aim for, these percentages are considered to be a very high target to achieve on major schemes.

Comment

Representation ID: 10441

Received: 16/02/2024

Respondent: David Lock Associates

Seek to achieve 50% sustainable travel – this is very hard to achieve with complex behavioural changes required in addition to provision of the schemes listed within the checklist. It is suggested therefore that ‘Gold’ would be the more appropriate level.
Digital mobility systems providing real time access to public/private transport is also a particularly onerous target.
In contrast, ensuring every home is within short walking distance of public transport; segregated cycle/footways and integrated with green infrastructure is considered good practice and may be applicable to ‘Silver’.
EV Charging point 1 per dwelling – increasing kW rating through Bronze, Silver, Gold. The increasing requirement may be hard to meet on a larger scale.
General agreement to NHC’s approach to parking, including evidence-based use of maximum parking standards where public transport provision is exemplary.

Comment

Representation ID: 10442

Received: 16/02/2024

Respondent: David Lock Associates

Completing the whole life carbon template at the pre application stage with updates at subsequent stages of the application process to demonstrate how the development will reduce overall emissions against the Silver and Gold targets will be both financially and technically onerous.

Comment

Representation ID: 10443

Received: 16/02/2024

Respondent: David Lock Associates

30%+ BNG will be a significant hurdle to meeting the ‘Gold’
standard

Comment

Representation ID: 10444

Received: 16/02/2024

Respondent: David Lock Associates

Challenging for a scheme to achieve better than greenfield
(pre-development) run off rates and for the system to not
discharge into combined sewers to meet ‘Gold’.

Comment

Representation ID: 10445

Received: 16/02/2024

Respondent: David Lock Associates

The residential and non-residential Gold targets are
technically difficult to achieve and financially prohibitive.

Comment

Representation ID: 10446

Received: 16/02/2024

Respondent: David Lock Associates

The references to a requirement for a 12m buffer around designated sites appears to be applicable to all grades on the biodiversity checklist (page 28). However in Appendices A (major residential applications) and C (major non-residential applications) this is applicable to grades Silver and Gold only.
It is recommended these measures are consistent throughout the document.

Comment

Representation ID: 10447

Received: 16/02/2024

Respondent: David Lock Associates

The references to a requirement for a 12m buffer around designated sites appears to be applicable to all grades on the biodiversity checklist (page 28). However in Appendices A (major residential applications) and C (major non-residential applications) this is applicable to grades Silver and Gold only.
It is recommended these measures are consistent throughout the document.