Object

Representation ID: 8070

Received: 14/11/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This policy should be strengthened to particularly identify the need to apply these principles to heritage buildings - especially where these have suffered a loss of their original function and so are in danger of falling into disrepair or dereliction.

Object

Representation ID: 8228

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

In our previous submission we noted that the Rutland County Council Whole Plan Viability Assessment, August 2023 did not appear to include a cost for the embodied carbon policy. We expressed our concern as embodied carbon will have a cost that should be accounted for in any Viability assessment. We are disappointed to see that this policy has again not been tested in the Regulation 19 Viability Note (September 2024).

New development will often be far more sustainable in many circumstances including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site and more able to meet the council’s zero carbon aspirations. The Council also need to verify that embodied carbon figures are available to developers from suppliers through an Environmental Product Declaration as in our experience this is not yet readily available from the majority of suppliers.

Object

Representation ID: 8313

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: 8437

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is ambiguity regarding how developers can demonstrate compliance with the policy, particularly concerning embodied carbon assessments. Questions arise about the Council's capability to evaluate carbon assessments and whether qualified personnel have been identified for this task. The HBF highlights a lack of accurate data on embodied carbon across building materials, questioning the robustness of any assessments made under this policy. The policy may disproportionately affect small to medium-sized enterprise (SME) developers and could hinder the overall deliverability of housing developments.

Support

Representation ID: 8607

Received: 02/12/2024

Respondent: Anglian Water

Welcome the policy CC5 on Embodied Carbon.

Note that the supporting text of policy CC5 has been updated to include commentary on embodied (capital) carbon and we welcome the conclusion, supported by recent case law, that this local attribution and action is a matter for Local Plan policy in the absence of national
regulations and targets.

In addition to AWS’s inputs to the infrastructure delivery evidence, AWS is able to provide tCO2e figures for each of the allocations proposed should this information be requested by the Council, as offered in our Regulation 18 submission.

Object

Representation ID: 8695

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

we are disappointed to see that our previous comments in respect of draft Policy CC5 – Embodied Carbon, have not been addressed.