Object

Representation ID: 8137

Received: 28/11/2024

Respondent: Francis Jackson Homes Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Criterion b) places a significant burden on smaller developers - and could delay occupation and delivery of housing if there are not sufficient independent firms available to produce such calculations. Will this data need to be sent to the Council for review? Is there the resource, funding and expertise in the Council to fully assess and understand the implications of such 'as built' data. What are the implications (what will happen?) should the 'as-built' calculations be different to the design stage estimates?

Object

Representation ID: 8287

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The requirement of Policy CC4 for new developments to “provide the maximum generation of renewable electricity as practically and viably possible on-site (and preferably on-plot)” is appropriate in that it is sufficiently flexible in taking account of the feasibility and viability of renewable energy solutions.

However, the policy name is “net zero carbon (operational)” which is not actually a requirement of Policy CC4. It is suggested, therefore, that the policy name changes to ensure that the policy as a whole is “clearly written and unambiguous” as required by NPPF paragraph 16d, and that the policy is applied consistently.

Object

Representation ID: 8304

Received: 02/12/2024

Respondent: Define (on behalf of Mr PJSR Hill and Pikerace)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is noted that the policy name is referred to as “net zero carbon (operational)” which is not actually a requirement of Policy CC4. It is suggested, therefore, that the policy name changes to ensure that the policy as a whole is “clearly written and unambiguous” as required by NPPF paragraph 16d, and that the policy is applied consistently.

Object

Representation ID: 8311

Received: 02/12/2024

Respondent: Persimmon Homes East Midlands

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst the re-consultation on the Future Homes Standard does not include embodied carbon the government has set out in its consultation that it intends to consult in due course on its approach to measuring and
reducing embodied carbon in new buildings. Persimmon Homes are still of the view that requirements in respect of embodied carbon should come through Building Regulations. Notwithstanding the above, Persimmon Homes do support the flexible wording of this policy.

Object

Representation ID: 8312

Received: 02/12/2024

Respondent: Persimmon Homes East Midlands

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Persimmon Homes are still of the view that climate change matters need to be led centrally through Building Regulations.

Object

Representation ID: 8346

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Regulation 19 Viability Note (September 2024) confirms that the Council are not mandating Zero Carbon standards, the viability of which should not be deferred to the planning application stage and could delay the delivery of development. Policy CC4 is not justified and should be deleted.

Object

Representation ID: 8365

Received: 02/12/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Legally compliant? No

Sound? No

Duty to co-operate? No

The policy is not justified by an assessment of viability

Object

Representation ID: 8436

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CC4 is not considered to be sound as it is not justified, not effective and not consistent with national policy for the following reasons:

The policy outlines the maximum generation of renewable electricity on-site for development proposals, with proposals supported by an energy statement requiring updated calculations of energy performance. However, the HBF is concerned that this focus may not be the most sustainable option for all developments. The Council should apply this policy flexibly to achieve the most appropriate outcomes, rather than following requirements. The HBF also questions the unnecessary duplication of energy statement calculations with building regulations.

Support

Representation ID: 8461

Received: 02/12/2024

Respondent: RWE Renewables UK

Agent: Stantec

RWE is highly supportive of this policy, which suggests support for the principle of overplanting on development sites for ground mounted solar PV.

Object

Representation ID: 8519

Received: 02/12/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The broad principles of this policy are supported and align with the NPPF (2023) (Paragraph 159). However, whilst the principle of on-site generation is broadly accepted and is consistent with the NPPF (2023), the
policy must incorporate additional flexibility to address site specific circumstances where there are opportunities for renewable generation adjacent or very close to a site, allowing a direct connection to the
site.

Object

Representation ID: 8606

Received: 02/12/2024

Respondent: Anglian Water

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

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, which have low potential for renewables generation due to their small roof area, are excluded from the CC4 requirement on renewable energy generation