Dudley Local Plan Part One

12. Climate Change

12.1The Council declared a climate emergency in July 2020 and pledged to achieve carbon net zero carbon by 2030 and a carbon net zero Borough by 2041. Alongside this, the West Midlands Combined Authority declared a climate change emergency in June 2019 and committed to net zero carbon emissions by 2041. This means that the Council will be working towards meeting these targets through the timescale of the Dudley Local Plan and beyond.

12.2Information from the Met Office^[31] indicates that under projections looking at potential climate change over land to the 2070s, a location in the middle of England is likely to experience changes in precipitation and temperature in both summer and winter^[32] equating to:

12.3 Local planning authorities are bound by the legal duty set out in Section 19 of the 2004 Planning and Compulsory Purchase Act, as amended by the 2008 Planning Act, to ensure that planning policy contributes to the mitigation of, and adaptation to, climate change.

12.4The NPPF sets out in more detail the duty of planning in helping to contend with a changing climate and the vulnerabilities it generates in the built and natural environments. This includes planning for zero and low carbon development, requiring renewable and low carbon energy supply, reducing emissions and greenhouse gases, the mitigation of flood risks and employing appropriate policy and design solutions to address rising temperatures, ventilation, the need for additional green infrastructure and the protection of the natural environment.

12.5 To help Dudley Borough become a more efficient and resilient place, policies in the DLP will encourage development to:

1. improve energy efficiency and move towards becoming carbon net zero, in accordance with national targets and with the aims of the West Midlands Combined Authority commitment to achieve carbon net zero by 2041 and the Council target by 2030.
2. help decarbonise the transport system by locating developments sustainably to reduce new trips and encouraging less energy intensive and more sustainable modes of transport (as set out in the Transport section).
3. ensure buildings and infrastructure are designed, landscaped, and made suitably accessible to help adapt to a changing climate, making efficient use of water, reducing impacts from natural hazards like flooding and heatwaves, and avoiding contributing to the urban heat island effect.
4. create a safe and secure environment that is resilient to the impacts of climate-related emergencies.
5. take an integrated approach to the delivery of strategic and local infrastructure by ensuring that public, private, community and voluntary sectors plan and work together. Factors which may lead to the exacerbation of climate change (through the generation of more greenhouse gases) must be avoided (e.g. pollution, habitat fragmentation, loss of biodiversity) and the natural environment’s resilience to change should be protected.

Increasing efficiency and resilience

12.6The Government have stated that all buildings need to be carbon net zero by 2050. Section 19 of the Planning and Compulsory Purchase Act (2004), Section 182 of the Planning Act (2008), the Planning and Energy Act (2008), and the NPPF all empower local planning authorities to enforce policies that seek to reduce carbon emissions from new homes.

12.7The NPPF, in particular states, that plans should take a proactive approach to mitigating and adapting to climate change. As part of this, new development should be planned for in ways that can help to eliminate carbon emissions, such as through careful consideration of its location, orientation and design. The following Climate Change policies aim to ensure that future development address national energy and climate change objectives.

12.8Policy DLP41 sets out how new development proposals will be required to demonstrate they are designed to maximise resistance and resilience to climate change through a range of design requirements.

12.9Buildings, services, and infrastructure need to be able to cope with the impacts of climate change. Part of this will relate to ensuring that development is able to cope with more intense rainfall, the possibility of flooding, heat waves and droughts. The design of development therefore needs to address shading, insulation and ventilation, surface water runoff and storage and the use of appropriate tree planting and landscaping, to futureproof schemes against more extreme weather conditions.

12.10Where possible and appropriate, the retrofitting of residential and other properties to achieve higher standards of energy and water efficiency will be encouraged and supported. For heritage assets, this policy should be read in conjunction with Historic England Advice Notes on retrofitting and adapting traditional/historic buildings for energy and carbon efficiency.

12.11This policy should be read in conjunction with Policy DLP46, which covers the use of renewable and low carbon energy and energy-saving measures. It should also be read in conjunction with DLP39, which promotes good design including the management of water resources, and DLP44 and DLP45 which look in more detail at the control and mitigation of flooding and the provision of Sustainable urban Drainage Systems (SuDS).

12.12DLP policies demonstrate that adaptation to and mitigation of climate change can be achieved across all forms of development. The PPG section on climate change^[34] identifies examples of mitigating climate change such as:

1. reducing the need to travel and providing for sustainable transport;
2. requiring good design to enable the focus of travel to move away from the motor car to modes of “active travel” such as safe cycling and walking routes especially on new housing estates;
3. providing opportunities for renewable and low-carbon energy technologies;
4. providing opportunities for decentralised energy production and district heat networks; and
5. promoting zero-carbon design approaches to reduce energy consumption in buildings, such as utilising passive solar design features.

Evidence

• Planning and Compulsory Purchase Act (2004)
• Planning Act (2008)
• Planning and Energy Act (2008)
• UKCP18 Climate Change Projections Overland - Meteorological Office
• UK Climate Change Risk Assessment – Climate Change Committee
• CCC Sixth Carbon Budget^[35]
• National Design Guidance
• West Midlands Combined Authority WM2041 Programme and Actions
• Historic Buildings for Energy and Carbon Efficiency - Historic England Advice Note 18 (July 2024)
• Dudley Council Climate Action Plan Phase One 2024-2027

Delivery

• Delivery will be secured through the development management processes, specifically through Planning and Design statements, energy plans and evidence accompanying planning applications.
• Planning conditions, CIL and Section 106 contributions.

Energy Infrastructure

12.13The NPPF states that plans should take a proactive approach to mitigating and adapting to climate change. Development should be planned for in ways that help eliminate greenhouse gas emissions, such as through consideration of its location, orientation and design.

12.14To help increase the use and supply of renewable and low carbon energy and heat, plans should provide a positive strategy for energy from these sources. Policy DLP42 sets out how energy infrastructure will be considered, including how opportunities for decentralised energy and communal heating will be identified.

Justification

12.15 The ways in which heating, and power are delivered to / used in development will need to change to meet the requirements of a net zero carbon future and the intended elimination of greenhouse gas emission. The use of fossil fuels and traditional forms of energy generation will need to be phased out and replaced by net zero carbon, non-polluting and energy-efficient sources. These methods will include the use of heat networks and communal heating systems wherever possible.

12.16 The policy requires that the feasibility of incorporating opportunities for decentralised energy provision is considered for all applicable development proposals. If low-carbon decentralised power and heating systems do not currently exist or are still in the process of being delivered, developers should ensure that new housing and employment schemes are provided with the infrastructure to link into those networks when they become available.

12.17 Where a link to an existing or committed decentralised energy source^[39] is not viable, the LPA will support the provision of alternative on-site zero carbon measures. This may include, for example, the provision of built-in renewable energy generation for individual buildings or other forms of decentralised energy provision within the site.

12.18 The Government is intending to introduce Heat Network Zoning in England by 2025 and the connection of certain buildings to heat networks within these zones will become mandatory on adoption of the legislation. This zoning will provide the market with a level of certainty that the demand for heat networks will be there to support investment decisions and growth in the market.

12.19 Within Heat Network Zones, large public-sector buildings, large non-domestic buildings, all new-builds and residential buildings that are already heated via communal systems (such as tower blocks) would be required to connect to the heat network within a given timeframe.

12.20 Heat networks are not limited to a particular energy source and can be delivered with a degree of flexibility to reflect local circumstances. Heat Networks can also be future proofed for transition to other fuels. Government funding is available to support the transition to heat networks and is intended to incentivise heat network market transition to low carbon heat sources via targeted financial support, which will help stimulate the increased deployment of low carbon technologies at scale.

12.21 In the Black Country, “Repowering the Black Country” is a programme of initiatives supporting Black Country businesses to take advantage of global clean growth opportunities and to make the transition to a carbon net zero industrial future. The project will initially develop four zero carbon industrial hubs in the Black Country. Within the next ten years, the aim is to reduce industrial carbon emissions by around 1.3M tCO2.

Heating and hot water systems

12.22 There is a broad hierarchy of provision that should be followed when considering and providing for communal heating systems on major residential schemes and where non-residential development would be of a scale to warrant some element of on-site provision. As an illustration, an appropriate hierarchical approach might be as follows:

1. local existing or planned heat networks;
2. use available local secondary heat sources (in conjunction with heat pumps, if required, and a lower temperature heating system);
3. generate clean heat and / or power from zero-emission sources;
4. use of fuel cells. If using natural gas in areas where legal air quality limits are exceeded, all development proposals must provide evidence to show that any emissions related to energy generation will be equivalent to or lower than those of an ultra-low NOx gas boiler;
5. use ultra-low NOx gas boilers only if more sustainable alternatives are unavailable;
6. ultra-low NOx gas boiler communal or district heating systems, designed to ensure that there is no significant impact on local air quality.

Evidence

• Powering Growth: Black Country Energy Strategy (AECOM) (February 2018)
• West Midlands Regional Energy Strategy (November 2018)
• Black Country Utilities Infrastructure Capacity Study (September 2019)
• Heat and Building Strategy (BEIS, December 2021)
• Repowering the Black Country (Black Country LEP) (2022)
• Dudley Council Climate Action Plan Phase One 2024-2027

Delivery

• Delivery will be secured through the development management processes, specifically through Planning and Design statements, energy plans and evidence accompanying planning applications
• Planning conditions, CIL and Section 106 contributions

Air Quality

12.23 Promoting healthy living is a key component of the Dudley Local Plan. Reducing exposure to poor air quality will improve the health and quality of life of the population and support the aims and objectives of the Plan. The need to address climate change and its associated impacts will include the need to tackle pollution and poor air quality, especially where it has impacts on both human and environmental health.

12.24 The World Health Organisation (WHO) published data on the impacts of ambient and household air pollution on human health for the European High-Level Conference on Non-Communicable Diseases held in April 2019. The paper stated that more than 550,000 deaths in the WHO European region were attributable to the joint effects of household and ambient air pollution in 2016, with over 500,000 being due to ambient air pollution and more than 50,000 to household air pollution^[40].

12.25 The 2023 Air quality strategy: framework for local authority delivery published by DEFRA states,

12.26 “Air quality has improved in England over recent decades. However, it continues to be the biggest environmental risk to public health, with children, the elderly and the already vulnerable most affected. Poor air quality also has consequences for crop yields and, particularly in the case of ammonia and oxides of nitrogen (NOx), significant impacts for the natural environment and biodiversity.” Paragraph 2.2 of the same publication sets out that by making people less healthy, poor air quality harms productivity and increases costs to society through medical and social care. Reducing poor air quality has direct, proven economic benefits, in many cases even when the up-front cost over intervention is high. It is estimated that reducing PM2.5 concentrations by 1 μg/m33 increases GDP by 0.8% on average in Europe.

Justification

12.27National planning guidance identifies the need for local planning authorities to address the problems created by pollution, in terms of poor air quality and its impacts on human and environmental health. Major air pollutants that impact on human health include particulate matter (PM10 and PM2.5 and fine / very fine particulates) and nitrogen oxides (NOx). These gases may also combine to create ozone, a greenhouse gas that impacts on the atmosphere.

12.28 The main cause of poor air quality in Dudley is transport related. Locations have been identified that do not comply with current national objectives and that will result in relevant exposure; there are several air quality hotspots where on-going monitoring is required. Dudley is working to reduce pollutant concentrations and to minimise exposure to air quality that does not meet with national objectives. Air quality management areas have been declared in locations across the borough to try to address the government’s national air quality objectives, which have been set to provide protection for human health.

12.29 It is important that development likely to have a negative impact on air quality is fully assessed and measures are taken to make it acceptable, particularly in parts of Dudley where air quality is, or is likely to become, a concern. The majority of developments will have a moderate air quality impact which can be dealt with through standard mitigation measures, without the need for an Air Quality Assessment (AQA), as detailed in the latest Air Quality SPD. These standard mitigation measures are designed to deal with the cumulative impact of many moderate impact developments over time and over a wide area. Particular consideration should be given when a development could lead to a deterioration of sensitive habitats and/or species and where necessary the implementation of specific mitigation will be required.

12.30 The following development types that could impact on the natural environment include (but may not be limited to):

• new transport infrastructure likely to generate increased traffic
• new housing and commercial developments likely to generate increased traffic
• agricultural development likely to generate ammonia emissions
• energy generation

12.31 All assessments of air quality impacts on biodiversity should be carried out in accordance with Natural England’s guidance on assessing the implications of road traffic on European Sites^[41] and the Air Quality PPG^[42]

12.32 AQAs should be proportionate to the type and scale of development proposed, in accordance with the guidance provided by the latest Air Quality SPD and relevant national standards for air quality. National planning policy guidance on air quality offers several examples of what might usefully be incorporated in such assessments, including baseline conditions, specific concerns, the assessment methods to be adopted, the basis for assessing impact and determining the significance of an impact and mitigation^[43].

12.33 For some developments a basic screening assessment of air quality is all that will be required, whereas for other developments a full AQA will need to be carried out, using advanced dispersion modelling software. An appropriate methodology informed by the latest Air Quality SPD should be agreed with the development management team / officer on a case-by-case basis.

12.34Where a potentially adverse impact on air quality is identified, mitigation measures may include:

1. increasing the distance between the development and the pollution source;
2. using green infrastructure, particularly trees, to help absorb dust and other pollutants (see DLP33 - Trees – care must be taken to ensure the type and location of such trees do not exacerbate air pollution by trapping it close to the street);
3. using ventilation systems to draw cleaner air into buildings;
4. improving public transport access to all development;
5. implementing travel plans to reduce the number of trips generated;
6. implementing low emission strategies; and
7. controlling dust and emissions from construction, demolition and working projects.

Evidence

• National Clean Air Strategy 2019
• Black Country Air Quality SPD
• Air Quality Action Plan for Dudley

Delivery

• Development Management, legal and funding mechanisms

Flood Risk and Sustainable Drainage

12.35 In recent years floods, storms and droughts have shown how vulnerable the UK is to extremes of weather, resulting in significant economic, social, and environmental cost. Climate change also means that extreme weather events will become more frequent and have the potential to cause damage to affected communities.

12.36 The most significant sources of flood risk in the borough are fluvial and surface water flooding. The primary fluvial flood risk lies along the river Stour and its tributaries. Surface water flooding is mostly caused by intense rainfall events. There are many areas at high risk of surface water flooding in Dudley, due to the heavily urbanised nature of the area that can impeded natural infiltration and drainage.

12.37 Climate change projections show an increased chance of warmer, wetter winters and hotter, drier summers, with a higher likelihood of more frequent and intense rainfall. This is likely to make severe flooding occur more often; effective flood risk management is one of the most important ways of adapting to intensive rainfall events. Ensuring that developments are planned to avoid vulnerability and manage risks with suitable adaptation measures where required will help to mitigate against related adverse impacts and disruptions.

12.38Dudley is a densely populated borough and, in places, steeply sloping urban area. This makes it prone to rapid surface water flooding following heavy rainfall and flooding from smaller watercourses that are tributaries of the River Severn. The industrial legacy has left complex urban drainage challenges, with many watercourses that have been heavily modified and culverted in places providing little if any biodiversity benefit and are prone to blockages. The historic canal network is also susceptible to flood risk and climate changes issues which need to be considered.

12.39Several main rivers flow through the area; these are the watercourses used to support the general requirement of 10m easement from main rivers. The main rivers in the area include:

• Coalbourne Brook,
• Dawley Brook,
• Illey Brook,
• Lutley Brook,
• Mousesweet Brook,
• River Stour,
• Swan Brook,
• Wordsley Brook.

12.40Climate change will increase the likelihood of surface water and localised flooding from smaller and culverted watercourses. Alongside this, the condition of many culverted watercourses is failing as they age, and where they lack maintenance, and therefore the likelihood of blockages or failure increases. Sustainable Drainage Systems provide an opportunity to replicate natural drainage systems through new development, which will help to reduce flood risk, improve water quality, and provide wider environmental benefits. Hence an approach is needed to new development that recognises local flood risk constraints and contributes wherever possible to wider environmental and flood risk improvements.

12.41The NPPF and Planning Practice Guidance requires that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, applying the Sequential Test and if necessary, applying the Exception Test. Where development is necessary the NPPF, and technical guidance recognises that there may be exceptions for certain at-risk sites where there are no suitable and reasonably available lower risk sites. In exceptional circumstances, where development is necessary in areas of risk and an alternative site at lower risk cannot be found, appropriate mitigation measures will be required to make it safe. These must not increase or displace flood risk elsewhere. As part of individual planning applications, the Council will have regard to, and applicants should refer to, the relevant site-specific Level 2 SFRA (2025) recommendations that should be incorporated into the development to address flood risk. Applicants should also refer to ‘The Flood Map for Planning’ and ‘Check your long-term flood risk’ portals to identify where there are flooding issues from sources other than rivers.

12.42Contributions to reducing the overall flood risk downstream and betterment may be provided through the provision of additional storage on site e.g. through oversized SuDS, natural flood management techniques, green infrastructure and green-blue corridors and / or by providing a partnership funding contribution towards wider community schemes (both within Dudley, the Black Country and in shared catchments with Southern Staffordshire and Birmingham). Consultation on the site-specific requirements should be undertaken with the Council, the Environment Agency, Canal and River Trust and Severn Trent Water (where this is a sewer flooding issue) at the earliest opportunity.

12.43 Canals may also provide developers with opportunities to dispose of surface water drainage and could be considered as part of potential SuDS infrastructure. Developers should discuss any options to use the Canal network with the Canal and River Trust prior to a planning application being submitted to the Council.

Evidence

• Black Country Level 1 Strategic Flood Risk Assessment (SFRA) 2021
• Dudley MBC Level 1 Strategic Flood Risk Assessment (SFRA) 2024
• Dudley Level 2 Strategic Flood Risk Assessment (SFRA) 2025
• Black Country Water Cycle Study Stage 1 2020
• Dudley MBC Water Cycle Study Stage 2 2024

Delivery

Through Development Management and Local Lead Flood Authority (LLFA) processes

Sustainable drainage and surface water management (SuDS)

Justification

12.44The incorporation of Sustainable Drainage Systems (SuDS) into new developments helps to manage and minimise surface water. SuDS generally are landscaped facilities such as wetlands, retention ponds, soakaways, swales and/or permeable surfaces, the primary function being to reduce the volume and peak rates of water run-off from new development, but they should also fulfil their potential to provide new wildlife habitats and amenity spaces into developments, they should be multifunctional.

12.45SuDS can also improve water quality by increasing the filtration of pollutants and thereby helping to support the objectives of the Water Framework Directive. They allow the management of diffuse pollution generated in urban areas by treating water and reducing the level of pollutants that enter rivers and other watercourses therefore resulting in less wastewater requiring treatment. Good SuDS design can be key for creating a strong sense of place and pride in the community for where people live, work and visit, making the surface water management features an integrated part of the development. Canals may also provide developers with opportunities to dispose of surface water drainage and could be considered as part of potential SuDS infrastructure. Developers should discuss any options to use the Canal network with the Canal and River Trust prior to a planning application being submitted to the Council.

Evidence

• Black Country Level 1 Strategic Flood Risk Assessment (SFRA) 2021
• Dudley MBC Level 1 Strategic Flood Risk Assessment (SFRA) 2024
• Dudley Level 2 Strategic Flood Risk Assessment (SFRA) 2025
• Black Country Water Cycle Study Stage 1 2020
• Dudley MBC Water Cycle Study Stage 2 2024

Delivery

• Through Development Management and LLFA processes

Renewable and Low Carbon Energy and BREEAM Standards

12.47It is essential for the successful delivery of the DLP that a high standard of sustainable design is secured on all new developments over the Plan period. This will reduce carbon emissions from new development, improve design quality and create a high-quality environment which will maximise economic competitiveness and housing choice.

12.48The Planning and Compulsory Purchase Act of 2004 requires local plans to include policies designed to secure the contribution of development towards the mitigation of, and adaptation to, climate change.

12.49In 2022, changes to Part L of the Building Regulations came into effect, which significantly improved energy efficiency standards for new homes and further improvements under the “Future Homes Standard” are due in 2025 and will apply to planning applications in 2024. However, given the urgency of the climate change crisis and the amount of development planned in the whole Plan period, it is vital that use of energy from non-renewable sources by new homes, and other types of development, is minimised as far as possible and as early as possible, until overtaken by any further changes to Building Regulations.

12.50 Although there is currently limited renewable energy generation in the borough, evidence shows that there is considerable untapped capacity to produce and export renewable energy at a local level. Therefore, it is important that all new developments should make the maximum contribution towards renewable and low carbon energy generation, where this is financially viable and feasible to implement. Where viability evidence is required, viability assessments should be prepared in accordance with the most up to date national planning policy guidance.

Justification

12.51Assuming energy use under current Building Regulations, it is generally not practical to provide more than 20% renewable energy generation within a site. In particular, solar power is the most suitable technology on most sites, and solar energy generation is limited by the orientation and extent of roofs within a development, such that on average 50% of roof space in a housing development can practically support solar panels. This typically limits renewable energy generation to 20% of average residual energy demand. The Dudley Viability Assessment has demonstrated that this level of requirement will not prejudice the delivery of most major developments in Dudley.

12.52 DLP46 sets out that a minimum proportion of energy within developments should come from renewables or low carbon sources, not just energy efficiency improvements. Building Regulations Part L sets minimum energy efficiency standards for new buildings, focusing on reducing carbon emissions through building fabric, heating systems, and other measures. It does not mandate a specific percentage of on-site renewable or low carbon energy generation. Future Homes Standard sets national minimum standards which will be mandatory for new developments. Future Homes Standard will supersede Policy DLP47 once fully implemented which is currently anticipated to be 2028. However, given the urgency of the climate change crisis and the amount of development planned across the borough during the Plan period, it is vital that use of energy from non-renewable sources by new homes, and other types of development, is minimised as far and as early as possible, until overtaken by further changes to Building Regulations.

12.53 To limit the financial burden on smaller developers, a lower requirement of 10% has been set for small developments. Where a number of smaller developments are taking place in close proximity and it is considered that these form phases of a major development, the 20% requirement will be sought. Residual energy demand means that the estimated energy demand for the operational development should be calculated after allowance has been made for the full range of energy efficiency measures required under Building Regulations at the time of construction. The Council and Housing Associations will lead by example by seeking to maximise energy efficiency and incorporation of renewable and low carbon energy generation through the refurbishment and redevelopment of land and buildings in their ownership.

12.54 Many types of renewable and low carbon energy generation can be developed in Dudley, including solar photovoltaics, solar thermal, air, water and ground source heat pumps and other technologies (see DLP42). The Canal network also has the potential to be used for water-source heat pumps. The Black Country Utilities Infrastructure Capacity Study concluded that there are no parts of the area that would be suitable for large-scale wind turbine development. However, there is no evidence to suggest that any other type of renewable or low carbon energy technology would not be appropriate in any part of Dudley Therefore, any renewable or low carbon energy proposal will be treated on its merits in accordance with Policies DLP46 and national guidance, and any relevant Plan policies.

12.55 The DLP includes a range of policy aspirations for high quality design and climate change mitigation and adaptation, particularly those set out in Policies DLP41, 42, and DLP39. As set out in national guidance, an effective way of ensuring these aspirations is delivered in a consistent manner is through the use of tools for assessing and improving design quality. The Building Research Establishment (BRE) administers a range of robust, national standards which can support this approach. BREEAM standards are well established and certify quality and sustainability in the built environment, including running costs, health and wellbeing and environmental impact. Minimum standards are first applied – these will include the national water efficiency and space standards for housing set out in Policy DLP39 developers are then able to choose from a menu of other measures to reach the total credits necessary to achieve certification to the required level.

12.56Application of the BREEAM New Construction standards set out in Policy DLP46 will ensure that all major developments in Dudley meet a minimum level of quality and sustainability that is independently certified throughout the planning and construction process and, in most cases, following completion. In order to allow for an improvement in standards over time, the level of certification required for medium-sized developments of 1,000-5,000 sqm gross will be increased after 2028 in line with larger developments. The use of other standards, such as Passivhaus and the BRE Home Quality Mark, which use third party assessment and certification to robustly verify that the quality of approved development is not materially diminished between permission and completion, will also be supported.

Evidence

• Black Country Utilities Infrastructure Capacity Study (2019)
• Viability Assessment Report (2023 and 2024 addendum)
• Historic England Energy Efficiency and Historic Buildings Guidance
• Dudley Council Climate Action Plan Phase One 2024-2027

Delivery

• Development management process
• BREEAM certification process

Water Quality

12.57 New developments should not adversely impact water quality. The Water Framework Directive ensures that developments do not cause a deterioration in the status of inland waterways.

Justification

12.58The protection of groundwater is an important consideration in dealing with development sites, with a particular regard to sites that are contaminated. The Local Authority have a duty to maintain and protect the quality and quantity of groundwater resources for current and future abstraction, for dependent ecosystems and indirect uses. The Environment Agency may object (through planning or their permitted controls) to development activities, where groundwater is affected. Regard to the Canal network and water quality is also required see Policy DLP36.