Section 1: responses regarding the scope and use of the DPD

  1. The Climate Change DPD should be renamed the ‘Climate Emergency’ DPD.

It’s no longer enough to talk about climate ‘change’, when the situation has become a crisis.

As the Covid-19 crisis has demonstrated, an emergency situation requires an emergency response. Though we have had more time to prepare for the climate emergency, it will hit us much harder and for much longer. Just as responding to Covid-19 has taken precedence over all other aspects of life, so our climate emergency response must equally take precedence over all other considerations. The sooner and more robustly we act, the more we can turn a climate emergency response into a new lease of life. Failure to act rapidly and radically now will leave us with far fewer positive choices down the line.


  1. Consideration should be given to climate adaptation as well as reducing carbon emissions.

Even if we achieve the ambitious target of reducing our carbon emissions to net-zero by 2030, the rest of the world is still off-track for doing the same. Though our priority should be to reduce Cornwall’s carbon emissions, we should nevertheless plan for a future in which the effects of Global Heating are felt here. In particular, both an increase in extreme weather events and the unreliability of global food supply are likely features of our future that we should begin to prepare for now.


  1. The climate emergency and the ecological crisis - through which we are experiencing rapid loss of biodiversity - are inextricably linked, and we need language that reflects that.

Though we need policies to dramatically reduce our carbon emissions, the bigger picture is that we have built an economy that relies on extracting value from the natural world - and that this has now caused two major crises that place our future under serious threat. The language of ‘eco-system services’, ‘natural assets’, and ‘natural climate solutions’ - while we recognise that these are part of the language of current national policymaking - is problematic because it perpetuates this approach, albeit while seeking to mitigate the environmental impact. Cornwall Council could take a lead in using different language that goes further in reorienting our relationship to the natural world, which can then be reflected in strategy.

We recommend the language of ‘health’ as an alternative. The Covid-19 crisis has demonstrated clearly the extent to which our collective health is really our paramount concern - and that our economy has to serve our collective health and not the other way around. What the climate and biodiversity crises require is an urgent recognition that our human health is inextricably bound up with the health of the planet’s ecosystems - and that should be the primary reason for taking ecosystems and climate impacts seriously. Failure to do so will have a much greater health impact than Covid-19.

Climate change is a threat to both human health and the health of the ecosystems with which we are interdependent. Ensuring that Planning is a function of local government that has collective health as its top priority is a way of bringing together the value of Planning to our communities with the climate and ecological emergencies that demand urgent responses - for the sake of our collective health.


  1. The Local Industrial Strategy and the ongoing New Frontiers future-planning must be integrated with a Climate Emergency response to Planning.

One area, for example, that we believe is crucial to our strategic planning is local food production. As a means of both reducing carbon emissions and adapting to likely future food shortages, Cornwall could produce a much higher proportion of our food here. Of course, this is affected by national government policies, but a Climate Emergency Local Industrial Strategy could identify provisions for which to lobby national government (as was done for other sectors with New Frontiers) as well as scoping the local infrastructure to manage a productive transition. Support for infrastructure such as Market Gardens, local abattoirs, farmers’ co-operatives, ecological land-management training should be part of this. This is not limited to Planning, but it has important Planning implications.

Another area that has a large impact on Cornwall, including on our carbon emissions, is Tourism. Planning rules around Second Homes and Holiday Lets cannot consider the Climate Emergency seriously if they are not also related to Cornwall’s strategic economic planning. We need a strategy for tourism that ensures its economic benefit doesn't come at the cost of a climate emergency response - which includes the strengthening of resilient local communities.


  1. Cornwall needs an Energy Plan that details how maximum-capacity renewable generation infrastructure will be achieved by 2030 with annual targets to drive and monitor progress. The CC DPD then needs to reflect the role of Planning in delivering it.

Collaborative development of an energy plan with targets for installation levels could help unlock many of the existing barriers to achieving the levels of renewable energy generation required to meet the objective of net-zero-carbon by 2030. The involvement of local stakeholders such as Western Power Distribution, communities, businesses, land-owners, etc., would be a significant assistance in developing appropriate targets and plans for each area.


  1. There is a need to incentivise developers and builders to undertake higher relevant training in how to meet the climate emergency standards for buildings, perhaps with the creation of an environmental standards marque.

This is to address how things *actually* get built in the absence of adequate Building Control. As a separate activity to this DPD we suggest that the Council Climate Action team develop methods of improving awareness and local building skills in low carbon building technologies and methods, as well as a basic understanding of ecosystems and ecological impact. Making this a planning condition is a proactive - and much cheaper - way of reducing ecological and climate harm through the building process. It is also crucial if this DPD is not going to apply to developments which already have outline planning or are in (or will soon move to) the ‘reserved’ matters stage - which will substantially delay its impact.


  1. We need a specific Cornish Nature Recovery Network strategy (as per the government’s 25-year Environment Plan 2018) within which natural climate and flood solutions can be mapped.

Following the government's 25-year Environmental Plan which committed to a National Nature Recovery Network, Cornwall needs to be proactive in detailing our own. This should become a vital document to inform Planning, not just in terms of detailing places to avoid building, but also as a way to better integrate local ecosystems with human habitation and work. (We have submitted a separate response to the Biodiversity Net Gain consultation, but many of those recommendations are relevant here and we have highlighted how they can support this DPD later in this response.)


  1. The new Design Guides contain a lot of very valuable recommendations for developers. However, at present they are only advisory. We would like to see these adopted as part of this DPD making them a Material Consideration in Planning.

In particular there are a lot of valuable provisions to support biodiversity which we would like to see enforced.


  1. We would welcome further consideration of the decision-making processes which will utilise this DPD.

When decisions come before Planning officers or Planning committees, decision-makers have a responsibility to weigh the various different material considerations in order to reach their decision. There is currently no mechanism in that process to reflect the Emergency nature of our climate and biodiversity crises, relative to other concerns. We recognise that this is a difficult issue to address, since each individual application requires its own individual assessment. However, we believe that this question needs further consideration in relation to the scope of the DPD. Would it be possible, for example, to establish a relative weighting to prioritise carbon-reduction considerations? We would welcome a collaborative process to address this and to be part of the discussion.


  1. Since the CC DPD is the Planning action from the Climate Action Plan, if any of these headlines are deemed out-of-scope of the DPD, they need to be considered as gaps in the Climate Action Plan itself.

We are unclear about the process for drawing back learnings from the various actions of the Action Plan in order to ensure it is tackling the most urgent issues. We would welcome clarity on this.