Policy CC4 - Net zero carbon (operational)
Support
Regulation 18 draft Local Plan
Representation ID: 4753
Received: 13/12/2023
Respondent: Mr Andrew Lunn
Solar panels should be a must and not an option. Design of buildings can make sure these are standard fitment and not design estates for maximum financial gain by the developer.
Support
Regulation 18 draft Local Plan
Representation ID: 4954
Received: 31/12/2023
Respondent: Mrs Jayne Williams
This is the most sensible way to roll out solar energy. Rooftops, both commercial and domestic should be utilised before farmland.
Object
Regulation 18 draft Local Plan
Representation ID: 5026
Received: 02/01/2024
Respondent: Pigeon Investment Management
The requirements of this draft policy go beyond that of the draft consultation stage requirements of the Future Homes Standards (FHS). This sets out that systems should be an appropriate size for the site, available infrastructure and on-site energy demand. The Council may wish to reconsider this policy in the context of the consultation version of the FHS.
Support
Regulation 18 draft Local Plan
Representation ID: 5065
Received: 02/01/2024
Respondent: Mary Cade
This policy should apply to all new buildings - individual, estate, commercial - with roof mounted solar panels mandatory . The phrase 'practically and viably' is too vague and provides an easy way for a developer to argue their way out of fulfilling the policy. What expertise will be available to aid developers and planners to produce and assess Energy Statements?
Support
Regulation 18 draft Local Plan
Representation ID: 5470
Received: 05/01/2024
Respondent: Ms Janet Taylor
All properties, residential and commercial, should have solar generation and storage. Combined with proper insulation and heat recovery systems it is possible to make houses pretty much energy self-sufficient
Object
Regulation 18 draft Local Plan
Representation ID: 5505
Received: 05/01/2024
Respondent: Francis Jackson Homes Ltd
This policy as drafted places a huge burden on applicants for housing. Does this mean every planning application from a single plot to 1,000 houses (say) will have to provide a viability report to set out the level of renewable energy generation is the "maximum" viably possible on site? How else would the Council assess this. Criterion 2. is especially challenging as this level of post-development testing is not a function of national policy, where such matters are generally caught anyway by Building Regs and EPC's. What is the evidence to support the need for this?
Support
Regulation 18 draft Local Plan
Representation ID: 5562
Received: 05/01/2024
Respondent: Mrs laura alcock
agree
Support
Regulation 18 draft Local Plan
Representation ID: 5802
Received: 06/01/2024
Respondent: Mrs Sue Scarrott
Every new house should have solar panels on the roof - this needs to be added to the Plan.
Object
Regulation 18 draft Local Plan
Representation ID: 5841
Received: 06/01/2024
Respondent: RCC Expert Panel on Carbon Reduction
The requirement for an Energy Statement is welcomed. However the phrase “practically and viably possible” is vague, non-specific and immeasurable. It should be backed up by cross-reference to policy CC2.
Add “Where on-site renewable energy is not practical or viable, equivalent off-site renewable energy should be provided or an offset price of £5-15K per dwelling should be paid to RCC”, as recommended in the Bioregional Report and in the Central Lincs Local Plan (2023).
It is important to emphasise the Local Plan Vision by stating “The Vision implies that no energy systems will be based on fossil fuels.”
There is no need to state here (as it is in no other policy!) that “cost evidence is needed that this will not impact the viability of new developments.” Surely policy evidence should be more important in a Local Plan than cost evidence.
Support
Regulation 18 draft Local Plan
Representation ID: 6049
Received: 07/01/2024
Respondent: Mr David Lewis
I support the policy aim but would like to see stronger wording. The current wording of "as practically and viably possible" is not strong enough. Solar panels should be a requirement for all new homes and commercial buildings, providing more affordable heating and hot water for Rutland's residents and businesses.
Support
Regulation 18 draft Local Plan
Representation ID: 6285
Received: 07/01/2024
Respondent: Mr Chris Read
support
Object
Regulation 18 draft Local Plan
Representation ID: 6591
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
This policy, as drafted, is placing an extra burden and cost on housebuilders and developers to prove the energy efficiency of new homes, which is unnecessary when this is already covered by BRegs.
Support
Regulation 18 draft Local Plan
Representation ID: 6780
Received: 08/01/2024
Respondent: Wendy Dalton
New Housing - all new housing to meet Passiv accreditation and all new housing to be fitted with solar panels and storage batteries. This will reduce to reliance on overseas companies for energy security in Rutland. No carbon offsetting as an alternative.
Object
Regulation 18 draft Local Plan
Representation ID: 7172
Received: 08/01/2024
Respondent: Persimmon Homes East Midlands
This policy is a duplication of Building Regulations and as such is not required and should be removed from the plan.
Climate change matters need to be led centrally thorough Building Regulations.
The incorporation of renewable energy on site needs to be realistic, for example, there are only so many roof spaces that photovoltaic panels can be installed and issues associated with wind turbines are well documented.
Furthermore, the preference for renewable energy to be provided on plot goes against heat networks which are being pushed forward as part of Building Regulations.
If this policy requires any additional requirements above Building Regulations, these additional costs need to be set out in the ‘Whole Plan Viability Report’ undertaken by HDH Planning and Development Limited.
Ministerial Statement dated 13th December 2023 on energy efficiency makes it clear that local plan policy should not go beyond Building Regulations which further supports the removal of this policy from the Local Plan.
Object
Regulation 18 draft Local Plan
Representation ID: 7224
Received: 07/01/2024
Respondent: Mr Harold Dermott
Excellent, but there is also no indication of what size of solar array would be “practically and viably possible on-site (and preferably on-plot)”.
Whilst I appreciate that this will depend on the
design efficiency of the dwelling, developers in Rutland have a long history of just installing a token number of PV panels, fewer that there is space for, and producing less energy than the building uses. Leaving size of solar PV unspecified in this plan would mean this is likely to continue.
There can be no downside to fitting the largest solar array possible on every roof, other that capital cost. If the objective is for Rutland to generate as much renewable energy as possible,
RCC cannot ignore the significant area of domestic and commercial roofing it will be authorising
to be built during the life of this plan.
With regard to the extra capital costs, there should be no automatic assumption that solar PV system will belong to the owner of the building.
Energy costs will only reduce either when the lower cost of renewables is allowed to be passed on to the consumer or by generating your own electricity, the technology to do this is available NOW and is already being used in Rutland.
Thus a high level of ‘standard’ array for each class of building is critically important for meeting Rutland’s Climate Change targets.
Object
Regulation 18 draft Local Plan
Representation ID: 7250
Received: 08/01/2024
Respondent: Manton Parish Council
Residential development to incorporate renewable energy but must maintain character of the location. How do you address actual performance which falls short of design performance?
Object
Regulation 18 draft Local Plan
Representation ID: 7278
Received: 08/01/2024
Respondent: Manor Oak Homes
Agent: Mr Andy Moffat
The proposed approach which does not set out prescriptive standards is supported, but the requirement for maximum generation of renewable electricity as practically and viably possible on-site (and preferably on-plot) needs to be clarified. Will this require practicality and viability assessments for all major developments? Such a requirement would not be proportionate or justified.
Object
Regulation 18 draft Local Plan
Representation ID: 7315
Received: 08/01/2024
Respondent: Avant Homes
This policy is ambiguous and does not provide enough detail as to how it can be proven that that all residential proposals provide the maximum generation of renewable energy that is viable on site. This implies that developers will need to submit a scheme viability with every application, which is not considered achievable or realistic and will cause unnecessary delays during the application process. This policy should be deleted and simply dealt with via Building Regulations.
Object
Regulation 18 draft Local Plan
Representation ID: 7344
Received: 08/01/2024
Respondent: The Society of Merchant Venturers
Agent: Savills
Whilst the principle of on-site generation is broadly accepted, the policy must incorporate flexibility to
address site specific circumstances where there are opportunities for renewable generation adjacent/ very
close to a site. The Council must ensure there are full resources to enable site specific circumstances around energy provision to be properly assessed to pragmatically enable the most appropriate option to be considered and progressed.
The policy also sets out what ‘proposals supported by an Energy Statement should cover: Whilst the overall aspirations of the policy are understood and broadly accepted, the detail within the policy is not clear. There is currently no industry accepted definition of ‘net zero carbon’. This should therefore be explicitly set out within the policy or elsewhere within the emerging Local Plan, with details on methodology and expectations also clearly set out to ensure there is certainty around implementation.
Additionally, further clarification is needed on what is meant by ‘independently verified calculations’.
Furthermore the policy must ensure it is aligned with the Written Ministerial Statement made on 13
December 2023 entitled, ‘Planning – Local Energy Efficiency Standards Update’.
Object
Regulation 18 draft Local Plan
Representation ID: 7503
Received: 08/01/2024
Respondent: Wing Parish Council
This should be worded more strongly to require that all new
developments must provide all their own energy needs and achieve the net zero carbon targets. The policy is simply not ambitious enough to address the objectives outlined at the start of the Plan.
Object
Regulation 18 draft Local Plan
Representation ID: 7538
Received: 08/01/2024
Respondent: House Builders Federation
HBF would question what this policy is seeking to achieve and what it adds to Building Regulations. What will the Council do with the information of the ‘as built’ calculations when they receive it? What action could or would be taken once the homes have been completed? HBF note that Plan explains that consideration is being given to the viability of this approach and agree that energy efficiency requirements (and other policies) need to be subject to robust viability testing. However, this policy seems unnecessary and should be deleted.
Object
Regulation 18 draft Local Plan
Representation ID: 7549
Received: 08/01/2024
Respondent: Mr Roderick Morgan
CC4
The presumption in favour of repair and reuse of a building is not strongly stated enough - currently it is 'easier' to demolish and rebuild than it should be, because this is how it has been for decades - even GDP is biased towards greater consumption and waste in development. There needs to be a very a very high bar based on serious feasibility challenges, not just a financial justification, however slight.
Object
Regulation 18 draft Local Plan
Representation ID: 7668
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Roof mounted PV is mentioned for any new development, what consideration or derogation was considered where development falls within conservation areas. Building Control/management can this be undertaken with existing resources?
Support
Regulation 18 draft Local Plan
Representation ID: 7730
Received: 08/01/2024
Respondent: Anglian Water
We would comment that utilities infrastructure is not standard development therefore the policy and associated validation requirements which will be needed should be applied proportionally. All waste development is deemed to be major development and so we would ask that small kiosks, for example are excluded from CC4 requirement on renewable energy generation and instead that we submit a summary of the renewable energy projects delivered across the Anglian Water estate in Rutland and the wider Anglian Water estate.
Object
Regulation 18 draft Local Plan
Representation ID: 7874
Received: 08/01/2024
Respondent: Ryhall Parish Council
CC4 Net Zero Carbon (operational) – only Support subject to a change so that new proposals must [not should] provide Net Zero.
Surely this “Should” must be changed to “Must”?
Support
Regulation 18 draft Local Plan
Representation ID: 8015
Received: 08/01/2024
Respondent: Mr PJRS Hill and Pikerace Limited
Agent: Silver Fox Developments
We support the objectives if this policy.