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Response  to planning

We know that many of our members want to respond to Planning Applications, but find the process can be unwieldy and confusing.  We really do encourage as many people as possible to consider the environmental impact of development and to be a voice for nature.  Transition members, Heath Nickels and Jan Gannaway have written this excellent summary which helps you link your appeal to evidence, in law or local policy, to support and strengthen your argument.

Energy Efficiency:

EDDC should implement an interim uplift in building standards from 2021 as a first step towards the Future Homes Standard in 2025.


HM Govt : Future Homes Standards 2021 and

EDDC Local Plan review : Objective 2: Tackling the climate emergency:

Local authorities will continue to be allowed to set higher energy efficiency standards for new homes in their area and new homes built from 2022, will need to produce 31% less carbon emissions compared to current standards .

​Exmouth Neighbourhood Plan NATURAL ENVIRONMENT Para 25-26 (Policy PN 4 AND 5)

EDDC policy : CLIMATE CHANGE ACTION PLAN 2020 – 2040 (Ten Point Plan v7):

“Having a robust policy for granting permissions for low energy buildings”

“Require new developments of at least 1000 sq. m in floor area or comprising 10 or more dwellings to connect to any existing decentralised energy network and larger scale developments to explore options to deliver such a network as part of the development”

EDDC Local Plan review : Objective 2: Tackling the climate emergency:

“incorporating measures such as better insulation, glazing and renewable technologies like solar panels in developments”


Sustainable Transport:

EDDC “Plans and decisions should apply a presumption in favour of sustainable development”

( National Planning Policy Framework 2021 (NPPF )   P6)


HM Govt : NPPF (2021) Page 6

EDDC policy : CLIMATE CHANGE ACTION PLAN 2020 – 2040 (Ten Point Plan v7):

“Encourage the development of a transport infrastructure that supports more low carbon travel options for people in East Devon.

Install electric car charging points in all car parks and explore the opportunities for charging points in other public spaces, street furniture etc.”

EDDC Local Plan review : Objective 9: Promoting sustainable transport:

“To prioritise walking, cycling and public transport and make provision for charging electric vehicles, whilst reducing reliance on fossil fuelled vehicles”.

“New development ....designed to promote walking, cycling and public transport by incorporating attractive and easy to use routes within sites themselves and connecting destinations with a direct network of safe, convenient walking and cycling routes.”

Exmouth Neighbourhood Plan: GETTING ABOUT Para 45-46 ( Policy GA2)


Biodiversity Net Gain:

EDDC should implement biodiversity net gain policies and demand:

At least 10 % net gain for biodiversity from pre development baseline, using the metrics set out in the Environment Bill (2021)



HM Govt: Environment Bill ( Natural England The Biodiversity Metric 3.0 (JP039) (July 2021)

HM Govt: National Design Guide Page 26 ( Jan 2021)

HM Govt: Planning for the Future (October 2020)

HM Govt: The England Trees Action Plan 2021-2024 ( May 2021)


Net gain policies should demand:

  • 25% tree cover including street trees ( including the RETENTION of existing mature trees)

  • At least 30% open space

  • Hedgerow retention that maintains wildlife corridors

  • Bird / bat brick integral installation for every single dwelling, but grouped according to EDDC ecologist / RSPB advice

  • Hedgehog highways through fences

  • Sustainable Drainage Systems (SUDS)

  • Wildflower planting to improve pollinator / invertebrate biodiversity


EDDC Local Plan review Objective 8: Our outstanding natural environment:

“Set minimum standards for the amount and quality of green space in development sites.  Encourage new and existing green spaces to be more wild and nature friendly and less manicured and carefully managed”

“Promoting and incorporating wildlife friendly schemes and elements into developments”.......

“future development should now lead to a net increase in biodiversity of at least 10%.

​“Support designation of open spaces (for example green wedges) between settlements and local landscape protection areas”


Exmouth Neighbourhood Plan: NATURAL ENVIRONMENT Para 18 (ACTIONS NEA 5 and 6)


EDDC policy : CLIMATE CHANGE ACTION PLAN 2020 – 2040 (Ten Point Plan v7):


“Improve the quality and connectivity of natural habitats and.... ensure that we address biodiversity and environmental issues as part of our climate change response”

“Require the landscaping proposals incorporated within new developments in the district to incorporate a mix of new tree and other planting that can adapt to climate change”

Light Pollution:

EDDC should require  a  Lighting Management Plan taking into consideration -

‘”Will a new development, or a proposed change to an existing site, be likely to materially alter light levels in the environment around the site and/or have the potential to adversely affect the use or enjoyment of nearby buildings or open spaces?

Is the development in or near a protected area of dark sky or an intrinsically dark landscape?

Is a proposal likely to have a significant impact on a protected site or species? 

Local planning authorities and applicants should think about:

  • where the light shines;

  • when the light shines;

  • how much light shines; and

  • possible ecological impacts .”

from  Planning Guidance on Light pollution  1 November 2019


‘Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment

In doing so they should:......

  • c) limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation’

from   National Planning Policy Framework  July 2021

p.53  para, 185


(Background information Why is light pollution important?

Buglife  Light Pollution

Bat Conservation Trust 'Landscape and Urban design for Bats and Biodiversity'  Outdoor Lighting   p.28

“We recommend ... that efforts are made to retain or create dark skies over urban areas so that people in major centres of population may have access to the night sky”

Royal Commission Report - Artificial Light in the Environment    ch 6  )

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