BASE HEADER
Gwrthwynebu
Net Zero Carbon Development Plan Document - Regulation 19
ID sylw: 72208
Derbyniwyd: 08/06/2022
Ymatebydd: IM Land and IM Properties
Asiant : Turley
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
IM have reviewed the Net Zero DPD and have presented a number of concerns which without amendment, the draft DPD can only be considered unsound. 
These concerns are: 
•	Unsound viability evidence base which does not meet the requirements of Paragraph 31 of the NPPF. 
•	Further detail is needed with respect to the offsetting fund proposed to ensure that any funds received by the council will be spent on effective and deliverable carbon offset projects; and 
•	The need to introduce transitional arrangements given that Policy NZC1 is introducing the full FHS two years before the Governments proposed timetable.
Please see attached.