Southampton City Vision Local Plan Chapter 5 - Environment

Decentralised and Renewable Energy Infrastructure Policy Options

Theme: Environment
Policy Name: Decentralised and Renewable Energy Infrastructure
Policy Number: EN1(S)
Options Y/N: Y

Summary of responses (43 received)

The consultation responses were mainly in support of the policy approach by using a bold and clear vision of how to decarbonise and decentralise heat energy supply. It was evident from responses about energy efficiency and renewables that there was an element of confusion between the focus and application of other sustainability policies in the City Vision, and what kind of energy supply this policy was specifically targeting. There were questions on how the energy strategy will interrelate with standards under Building Regulations and how users of communal systems are protected from fuel prices outside Ofgem regulation and the burden of servicing costs. The uncertainty surrounding the timeline to switch the CHP geothermal plant from gas called into question the overall effectiveness of the decarbonisation strategy. Suggestions were made to resist using gas boilers in the future as steppingstone option and only allow green hydrogen energy is there was no other alternative options.

A number of comments and suggestions were received in response to the policy options. Whilst there is a stronger preference expressed for Option 1a, comments were received seeking greater flexibility by major developers in the application of energy masterplans to ensure viability of development sites in line with Option 1b, and to require submission of energy and sustainability statements to be proportionate to energy demand of smaller scale developments. Others would like to see the energy masterplan policy give greater clarity over which energy supply options are the most effective in saving carbon and whether preference will be given to these options. Greater involvement between developers and VSCE expertise and knowledge was suggested as a way to improve issues around energy supply issues and fuel poverty.

There was a strong preference for Option 2a in acknowledging the impracticalities of retrofitting developments and ensuring consistent design approach to support the future system performance and design & investment into a DH scheme. Others consider that the network mapping should be used to prioritise most deprived communities and those that struggle with social and health inequalities. Suggestions were made how to implement heat network by putting the onus on developers to provide evidence from network operators that there is capacity to serve the new development, and the developer should commit to network connection through a S106 agreement. Caution was aired by large developers with preference of Option 2b suggesting that communal low-temperature heating systems more appropriate on larger developments using the threshold 100 dwelling developments, as this is likely to be more achievable and required viability testing under the City Vision.

Further comments were made on different aspects of the policy. Concerns were raised that decarbonization of heat networks is not guaranteed, so there should be flexibility under part 3a to adjust priority of (i) and (ii) depending on the progress of switching heat networks away from natural gas CHP and boiler farms. Concerns were raised on the lack of meaningful targets set that can be appropriately monitored over the plan period to demonstrate the effectiveness of the City Vision and policy in addressing climate change and to ensure appropriate remedial action can be taken as necessary. It was suggested redevelopments/infrastructure projects (for example, bridge proposals) are required to demonstrate that a provision is included to accommodate utilities networks, including where appropriate, heating and cooling network pipes.

Biodiversity Policy Options

Theme: Environment
Policy Name: Biodiversity
Policy Number: EN2(S)
Options Y/N: Y

Summary of responses (69 received)

The consultation responses recognised and were broadly supportive of the approach suggested in the policy recognising a need to conserve and enhance biodiversity in the city. There were however mixed opinions on how this enhancement should be achieved through the application of Biodiversity Net Gain (BNG). Some comments, particularly those from the public and VCSE organisations, showed strong support for Option 1b and requiring a BNG target greater than 10%. There were a few comments suggesting that the target should be a requirement for all developments, including those allowed under permitted development such as conversions to residential dwellings. Other comments, particularly those from developers and those with large landholdings in the city, showed strong support for Option 1a and requiring a BNG target of 10% in line with the requirements of the Environment Act 2021. Concerns around viability were often cited as a reason for not requiring a target above the national 10% minimum. Some comments highlighted that other types of biodiversity enhancement not included in BNG assessment should also be required, such as nesting bricks.

There was interest in having further information in the policy on how BNG will be measured, secured and monitored in the long-term, and what measures will be taken where developments do not deliver the biodiversity improvements that were expected. A few considered that BNG should be delivered through larger scale strategic enhancements rather than onsite enhancements as part of development that will be piecemeal and isolated from wider ecological networks.

The policy's proposed requirements in relation to green roofs also received a mixed response. Some considered the approach did not go far enough and should be applied to developments with pitched roofs that have a slope able to accommodate a green roof. The recognition that green roofs and rooftop photovoltaic panels do not have to be mutually exclusive and can be delivered together on the same roof was welcomed. There were concerns raised about the proposed requirement that all flat roofs should be green roofs. These concerns, particularly from developers, focused on issues of viability and their effectiveness in the long-term due to issues around upkeep and maintenance. It was suggested the proposed requirement for green roofs should be more flexible to better respond to site specific circumstances and that other options could be used to deliver additional greenery and habitat.

As the policy needs to address a number of issues related to biodiversity it was suggested by some that certain issues should be split out into their own separate policies. Examples given included addressing nutrient and recreational impacts on designated sites and protecting the sites identified in the Solent Waders & Brent Goose Strategy. There were also suggestions that greater reference should be made in the policy to relevant national and

regional biodiversity strategies including the Nature Recovery Network, the Local Nature Recovery Strategy and the Solent Recreation Mitigation Strategy.

A few comments specifically raised the issue of pollution in rivers and its impact on wildlife asking for the policy be amended to address this. A few other comments emphasised the need to deliver more greenspace in the city or greening up movement corridors both as a means of creating more wildlife habitat.

Green Infrastructure and the Green Grid Policy Options

Theme: Environment
Policy Name: Green Infrastructure and the Green Grid
Policy Number: EN3(S)
Options Y/N: Y

Summary of responses (44 received)

There was strong support for increasing green infrastructure across the city alongside protecting and enhancing existing green infrastructure. Whilst a majority supported Option 1a which would focus improvements and new green spaces on the Green Grid, some made a case that it would be better to have a combination of both options focusing on the Green Grid but responding to other opportunities for delivering new green infrastructure outside the Grid as they arise. There were concerns raised that it may not be possible to deliver the Green Grid whilst also meeting other development needs but nevertheless brownfield sites should be prioritised for redevelopment.

Some comments wished to see more greenways and greenspaces improved than just those listed in the policy or otherwise wished to understand why those greenspaces listed in policy were being prioritised. There were also various suggestions as to specific greenspaces in the city that should be listed in the policy. There was also a suggestion regarding a space that should be removed from the Green Grid as it is currently the subject of a planning application for new housing. Several comments highlighted the need to consider how the Green Grid would integrate with blue infrastructure and in particular the River Itchen. There was also a desire to see the Southampton Common Plan integrated into the policy or used more clearly as an evidence base document.

It was suggested in some comments from organisations that have a focus on the natural environment that the policy needs to incorporate standards for assessing and monitoring green infrastructure. The need to ensure adequate maintenance for green infrastructure and ensure long-term funding for this, including through developer contributions, was also raised. Interaction between the natural and historic environments should be considered further, including the impact new planting can have on heritage assets, particularly archaeological assets.

In terms of the approach to the Green Grid, it was noted in some comments that the Grid would follow transport corridors. In these corridors it was noted that significant greening would need to occur to be beneficial to wildlife and there were some concerns about how wildlife would interact with major road crossings.

Protecting Existing Open Space and Green Infrastructure Policy Options

Theme: Environment
Policy Name: Protecting Existing Open Space and Green Infrastructure
Policy Number: EN4(S)
Options Y/N: Y

Summary of responses (31 received)

Comments received indicated a strong desire to protect the city's existing open spaces highlighting the benefits these spaces can provide to wellbeing and wildlife. These spaces were identified by nature organisations as being important for alleviating recreational pressure on designated nature conservation sites whilst others reiterated the city's open spaces themselves are under increased pressure due to a growing population and few new open spaces being delivered.

There were however mixed opinions around how this should be achieved whilst also addressing other strategic priorities. Some considered Option 1b to be preferable in order to take a strong position and prevent the loss of open space for development. Others preferred Option 1a taking a pragmatic approach that development needs may on occasion result in a loss of existing open space, but it was emphasised that when this occurs, suitable replacement must be provided. There were also mixed opinions on the form of such replacement open space. Most agreed that such replacement space should be higher quality and provide improved accessibility but some, particularly developers, considered that replacement open space that delivers improvement on previous provision should not have to deliver exactly the same quantity of open space.

There were also mixed opinions regarding Key Option 2 with some expressing preference for using the exceptional circumstances as set out in the policy as drafted as per Option 2a.

Although some did suggest that such development should only occur when other options have been exhausted. A common example was that schools should build upwards before extending onto their sports pitches. Others expressed a preference for a more flexible approach as per Option 2b or alternatively widening out the types of development that would be permitted, for example affordable housing provision or essential utility

infrastructure. However, a significant number of comments did not support any choice under Key Option 2 as they did not want to see any development on open spaces or otherwise considered such policy to be a risky gateway to more extensive forms of development on open spaces. Some comments argued that the phrasing of an 'exceptional circumstances' approach was not compliant with the approach to open space dictated in national planning policy.

There was notable support for the retention of settlement gaps to neighbouring towns although there were concerns raised about the long term retention and enforcement of the gaps when large parts of them are under the control of other Local Planning Authorities.

A number of comments suggested that parts of the policy needed tightening up or to be better defined to ensure open spaces are protected and development does not occur by a loophole. Some raised the issue that the evidence base for the policy needs to be expanded or refreshed, such as by incorporating the adopted Common Plan or by updating the Open Spaces Study.

New Open Space, Green Infrastructure and Quantity Standards for New Provision Policy Options

Theme: Environment
Policy Name: New Open Space, Green Infrastructure and Quantity Standards for New Provision
Policy Number: EN5(S)
Options Y/N: Y

Summary of responses (32 received)

There was strong support for the overall intention of the policy to deliver new and enhanced open spaces in the city. Some comments suggested prioritising the delivery of new open space in areas of greatest need such as the city's more deprived neighbourhoods. Others highlighted a pressing general need for new open space given the city's growing population and high development targets. It was suggested that some open space should be leti to nature rather than be made publicly accessible to better support wildlife on those sites.

With regards to options, there was a mixed response between comments that were content to progress the standards set out in the policy as per Option 1a and those comments who sought a higher set of standards as per Option 1b. No comments sought a lower set of standards as per Option 1c. Some comments from natural environment organisations suggested adopting open space standards put forward by organisations such as Natural England and the Woodland Trust. There were also some comments suggesting that the thresholds for providing onsite open space or play areas should be lower than currently proposed in policy. There were some concerns raised about the draft policy allowing viability to be a consideration in delivering new open space as it was thought to provide developers with a route to not deliver new open space. Responses from developers meanwhile focused on the need to ensure a contribution system was made available as an alternative to onsite provision where this would not be the most appropriate design response to making best use of the site. These comments emphasised that any financial contribution would need to be made to a named improvement scheme. They also requested additional information and supporting evidence around the type and amount of open space that would need to be provided on the development sites specifically named in the policy.

Several comments highlighted the need to incorporate blue infrastructure where possible into new open spaces or to make better use of waterfront areas to provide new active travel routes. There were also suggestions regarding specific locations where more open space should be provided or existing areas that should be designated as open spaces. Some identified areas that are used informally but should be left predominantly wild rather than be enhanced for formal recreational purposes. There were requests that certain elements of the policy or supporting text be more clearly defined in order to make the policy more robust and less open to differing interpretation.

Historic Environment Policy Options

Theme: Environment
Policy Name: Historic Environment
Policy Number: EN6(S)
Options Y/N: Y

Summary of responses (24 received)

Comments recognised the need for policy to govern development in relation to the city's many heritage assets and that development should carefully integrate with nearby heritage assets. There was support for preparing further evidence to support the policy as well as for revising and updating heritage related documents such as the Conservation Area Management Plans. However, there were some concerns raised around any attempt to amalgamate the plans for neighbouring Conservation Areas into fewer ones as it was considered these amalgamated plans would be less place specific and more generic subsequently weakening their effectiveness. It was suggested that commitments should be made to implementing the Southampton Common Plan since this included heritage related actions as well as landscape ones.

Some comments raised concerns that not enough has been done previously in policy to protect non-designated heritage assets, particularly those on the Local List, and that more should be done now to protect them. It was also emphasised in some comments that stronger heritage protections are needed for Old Town and that partly for this reason Old Town should not be included as part of any night time economy zone. Instead some suggested that Old Town should become a Heritage Action Zone. Other development proposals in this part of the City Centre, such as around Mayflower Park, were also considered to conflict with the aim of protecting heritage in Old Town. There was also a perceived conflict between this policy's desire to protect the city's historic parks and gardens and other proposed policies which would allow new taller buildings adjacent to the edges of the Central Parks.

Other comments identified difficulties in interpreting the city's heritage assets and that this policy should ensure more is done on interpretation to help connect local communities to their area and support tourism. It was suggested that the VCSE sector could help play a role in increasing awareness of the historic environment to create greater sense of pride in place.

There was a mixed response to the proposed options with a relatively even split between option preferences in the comments. Some comments even suggested pursuing both options under Key Options 1 and 2 since they would deliver different kinds of benefits for heritage.

There were various suggestions made regarding the policy text and how this could be improved, particularly from Historic England. This included suggestions for amended wording so that the policy would be more aligned to the approach set out in national planning policy. There were suggestions in some comments that flexibility should be applied to support other policy aims. This was preferred over a blanket ban approach, with regard to items like installing photovoltaic panels in Conservation Areas as it was considered these could be installed in appropriate, less prominent positions. Some developers suggested that the policy should be more flexible with regards to development within the curtilage of heritage assets, particularly where there is no visual connection between the two or the condition of the asset is poor.

Archaeological Heritage Assets Policy Options

Theme: Environment
Policy Name: Archaeological Heritage Assets
Policy Number: EN7(S)
Options Y/N: Y

Summary of responses (8 received)

There was overall support for this policy as there was a recognition of the need to showcase heritage assets from both above and below the ground. Recent work to repair and maintain the Town Walls was highlighted and it was emphasised that this policy should be used to ensure such work continues to be carried out in future.

In the comments there was clear support for Option 1a, which relates to the preparation of a heritage topic paper to support this policy, and for Option 2a, which relates to providing additions to draft policy regarding the city's scheduled monuments.

There were specific amendments to the policy and supporting text suggested by Historic England. This included a need to ensure all scheduled monuments are considered in policy through a consistent approach, not just a singular focus on the Town Walls, better aligning the policy's proposed approach to Desk Based Assessments with that used in national planning policy, and a suggestion that commitments to maintaining the Historic Environment Record would be better made in a strategic heritage policy.

Water Resource Management Policy Options

Theme: Environment
Policy Name: Water Resource Management
Policy Number: EN8(S)
Options Y/N: Y

Summary of responses (25 received)

There is a general support for the policy approach to set a target to lower water use below Building Regulations standards, however, a number of respondents considers that the water use target should be lower and compliance with the targets should be less flexible.

There was general support for providing on-site water recycling facilities. Concerns were raised that the assessment of the word feasibility in criterion 2 is not clearly defined so developers could solely use economic reasons to not comply with the requirements. Others considered that more intensive water saving measures should be required such as rainwater harvesting for toilet flushing. In addition, respondents suggested that the policy should focus on behavioral changes and educational initiatives to encourage less water use. Concerns were raised that water leakage resulting from poor quality or poorly installed water efficiency appliances and fittings such as low flush toilets will compromise the water saving measures put in place.

Concerns were raised by Southern Water in relation criterion 3 with regards to limited capacity to connect future homes to existing wastewater networks, so the phasing of housing delivery on major sites will need to be delivered in tandem with Southern Water’s work on each site to reinforce the network prior new homes being occupied. Others highlighted the need for further investment by Southern Water to reduce water leakage through their network, whilst improve water quality and reduce water pollution at their water treatment plants.

There were suggestions that water supply should be sourced through other means such as desalination. Given the pressure from water abstraction on the city’s rivers and their environmental importance, it was suggested to add provisions to this policy or create a designated policy on the protection of chalk streams. The policy should consider impacts to the rivers and increased weight within this policy to give chalk streams a higher level of protection from damage.

Summary of responses (14 received)

Theme: Environment
Policy Name: Flood Risk
Policy Number: EN9(S)
Options Y/N: N

There were mainly mixed responses to this policy with a large number wanting greater emphasis on the role of natural flood management measures. A number of detailed suggested amendments have been made on how national policy is applied locally and the need for site assessment and linking with other plans/policies in the region.

Summary of responses (13 received)

Theme: Environment
Policy Name: Sustainable Drainage
Policy Number: EN10(S)
Options Y/N: N

The policy approach was generally supported by respondents, however, concerns were raised over the practicality of implementing particular elements of the policy, whilst others have suggested that the approach should not be only limited to large scale development. It was suggested that the policy should apply greater flexibility to enable developers to use SUDS solutions where they are practicable and viable, and in a manner most appropriate on a site-specific basis. Furthermore, a separate requirement in criterion 1(d) to provide a green roof on major sites should be removed, whilst it is ambiguously worded how green roofs should be incorporated across the whole development.

Southern Water supports the policy approach as this aligns with the forthcoming surface water drainage provisions being enacted under Schedule 3 of the Flood and Water Management Act 2010, however, in the interim they suggest strengthening the wording of criterion 1(a) to not support surface water drainage into combined sewers. Natural England suggest consideration should be given to water quality impacts of phosphates discharged from SUDS that are hydrologically linked to designated sites, such as the River Itchen SAC and Southampton Water SPA, in the northern part of the city around Mansbridge and Swaythling.

Other respondents considered that strategic steps should be taken to increase SUDS features as part of city-wide drainage scheme and should link up with the green grid, with reduction of hardstanding in the City Centre to reduce run off and increase green space. In addition, there should be more focus on using nature-based solutions to plant more trees especially around walking and cycling routes, increase soil levels on development sites to improve infiltration, and use bioswales and areas of wet woodland. It was suggested that removal of permeable areas within front gardens to create car parking should be stopped.

Air Quality Policy Options

Theme: Environment
Policy Name: Air Quality
Policy Number: EN11(S)
Options Y/N: Y

Summary of responses (14 received)

The consultation responses generally supported the proposed policy approach to assess air quality impact. These comments recognised the significant health and environmental impacts of new development associated with poor air quality management. Others considered that the policy should go further to tackle and monitor the wider air quality pollution affecting the city associated with the emissions from the airport, port, and vehicle traffic.

There were limited representations about preferred policy options. Some writen comments supported Option 1b to use a bespoke approach to mitigate air quality impacts for new development to offer more flexibility on different projects, and supported Option 3a to secure additional measures to address poor air quality including standards for construction and demolition.

Additionally, various policy text suggestions were received in response to the consultation. It was suggested that there should be a greater reliance on using ‘natural solutions’ to mitigate impacts and improve poor air quality such as with tree planting and green walls. Others suggested setting a threshold to prevent new development in areas which currently exceed the WHO guidance on PM and NO2 levels. It was suggested there should be a specific requirement to encourage the resources for on-shore power connections for shipping.

Summary of responses (8 received)

Theme: Environment
Policy Name: Noise and Lighting
Policy Number: EN12
Options Y/N: N

There were mixed responses to this policy. Some felt it was too prescriptive but then some terms were too vague, therefore further work is needed on these elements. There was concern about noise and light pollution from the port and airport, and how this is considered for new development in close proximity to these sites. Further consideration is needed on the impact of noise and light on wildlife. There is a need for a lighting plan for the City Centre to ensure safety and highlight public spaces and landmarks.

Summary of responses (2 received)

Theme: Environment
Policy Name: Hazardous Substances
Policy Number: EN13
Options Y/N: N

There was support for this policy which was considered to provide an appropriate means to maintain MoD safeguarding requirements. There is a need to remove the reference to Netley Anchorage, as this is no longer in use.

Summary of responses (2 received)

Theme: Environment
Policy Name: Contaminated Land
Policy Number: EN14
Options Y/N: N

Responses suggested this policy needs to be broader, rather than just focussing on the Britannia Road site. A couple of amendments to the overall approach have been suggested.

Summary of responses (2 received)

Theme: Environment
Policy Name: Land Stability
Policy Number: EN15
Options Y/N: N

No comments were made on the policy, just on the overall approach. Consideration needs to be given on a range of development scales, from householder upwards and needs to consider neighbours and railway infrastructure.