Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99138
Received: 11/11/2022
Respondent: Broads Authority
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
It is good that light pollution is mentioned in terms of amenity, but situations could arise where a site is isolated and there would be no impacts on amenity, but light pollution could be caused. The policy needs to consider the impact of light pollution in all instances – on people, landscape, dark skies, wildlife. The current wording is narrow in scope - only impact on people (amenity). Addressing light pollution is not necessarily about not having lighting, but a good design, doing what is needed at the right intensity and for as long as needed. Particularly in or near the Broads which have intrinsically dark skies. As worded, the policy means that schemes that have external lighting that does not cause amenity issues, but could cause other light pollution issues, fall through the gap.
Soundness test: Not justified
Another criterion needs to be added that specifically talks about light pollution. Para 6.12 is very good, but that is not policy – adding that wording as a new criterion would address our comment. Noting our comments on para 6.16 (see other comment), lighting needs to be fully justified as well.
Referring to this guide would also address our comments: “Towards A Dark Sky Standard” [https://www.southdowns.gov.uk/wp-content/uploads/2021/08/Towards-A-Dark-Sky-Standard-V1.1.pdf]. This is a general guide and overview of the key considerations needed for good lighting design and the protection of dark skies.