We generally support the ambitions of the Council set out in policy DM2. Given the pressures on water resources in the region, we particularly support the measures to increase water efficiency in new development and promote retrofitting in existing development. It is also pleasing that the multiple benefits of urban greening have been acknowledged in the supporting text such as absorbing rainfall, filtering pollution and promoting biodiversity. Given the highly urbanised nature of the Borough, it will be necessary for developers to consider innovative measures to achieve this such as green/ brown roofs and walls.

We are however disappointed that the part of the policy addressing waste efficiency in the Issues and Options consultation has been removed (point 5 of I&O policy DM4). The Development Management DPD provides an opportunity to promote the consideration of waste as early as possible during the development design phase to ensure that minimal volumes of waste arise during the construction of the development, and the demolition at the end of its life. Developers should also be encouraged to consider how they will incorporate recycled/recovered materials into the building programme, including the use of secondary and recycled aggregates, and re-use of any on-site demolition waste. It is unclear why this part of the policy has been removed. We note that the Sustainability Appraisal has also raised this concern.