Policy P9
Subject to any energy efficiency measures not going beyond the Government's requirements and being cost effective for a development (i.e. viable), Richborough Estates Limited does not object to the principle of Policy P9. However, Policy P9 should be based upon a fabric first approach to reducing energy demand and carbon dioxide emissions.

By reason of high capital and revenue/management costs, district energy schemes or similar should not be encouraged because they can become financially unsustainable to manage and maintain in the long term without subsidy.

Policy P10

To accommodate the level of growth proposed within the Borough it is inevitable that there will be some effects on the natural environment. There is a need to balance these effects against other objectives, including the priority given by the Government to the delivery of new homes.
As a sequential approach, national or regional biodiversity interests such as Sites of Scientific Interest or locations with significant protected species interest should be preserved and enhanced.

However, the National Planning Policy Framework is generally silent on local biodiversity interests, including wildlife sites. Where practicable such sites should be retained. However, where their loss is likely, and as part of the wider planning balance considerations, then the mitigation of any loss should be taken into account, whether such measures occur on or off-site. Policy P10 currently denigrates off-setting away from the vicinity of a site but this approach could provide better opportunities to enhance biodiversity interests of a greater value than what might be lost. Richborough Estates Limited consider that a less dogmatic and more flexible approach is required towards local biodiversity interests.
The adoption of a flexible approach would have a greater potential to deliver the approach identified in the White Paper Fixing our broken housing market of securing compensatory improvements to the environmental quality or accessibility of remaining Green Belt land.

Policy P11

Subject to any measures for water management not going beyond the Government's requirements and being cost effective for a development (i.e. viability), Richborough Estates Limited does not object to the principle of Policy P11.

Policy P12

For non-waste developments the level of detail required for site waste management plans or similar supporting documents should reflect the type of application, whether outline, full or reserved matters. As an example, outline applications can only realistically address the principles for waste management rather than provide details about where waste storage locations will be sited and the precise number of containers. A proportionate approach should be established in Policy P12.

Policy P14

Richborough Estates Limited consider that further thought should be given to the drafting of Policy P14. Most of the policy's criteria are addressing wider development control matters rather than just 'amenity' considerations. It may be more appropriate to separate out the living conditions of the occupiers neighbouring properties from wider design considerations. In any event, the first criterion of Policy P14 is unnecessary because of Policy P15.