Object

Representation ID: 4946

Received: 31/12/2023

Respondent: Mr Neal Ince

Should there not be a statement that prioritises use of brownfield sites over greenfield sites? That seems obvious.

Strategic Objective 9: Make effective us of land and natural resources, and Spatial Strategy and Housing policies all seek to make the best use of previously developed land in accordance with national planning policy guidance.

Object

Representation ID: 4977

Received: 02/01/2024

Respondent: Mr Richard Creasey

Net Zero by 2050 cannot be met because of the mineral extraction policies mandated in RLP chapter 10 . These permit an annual extraction of 1.4Mt cement and 0.3Mt, recently increased to 0.5Mt, of aggregate leading, using IEA figures to around 600kt/a of CO2 equivalent emissions . Offsetting these by tree planting at the Forestry commission ‘s 10t/ha/a implies > 50,000 ha/a of trees , for net zero. The present RLP Net Zero aspiration is unrealistic and incoherent, for example CC 12 doesn’t even require a carbon budget for significant industrial developments such as quarries,.

The target to become net zero by 2050 is UK wide as required by the Climate Change Act 2008 (as amended). Strategic Objective 1: Climate change and policies on Climate Change in Chapter 4 all seek to achieve net zero and to reduce the county’s carbon footprint. As a Minerals Planning Authority, RCC is required by Government to plan for a steady and adequate supply of aggregates and industrial minerals. The plan supports the use of recycled and secondary aggregates (in place of primary aggregates) and their use will reduce the waste sent for final disposal and is in line with the Circular Economy (Policy CC1). Until/if there is a change in national regulations/guidance in relation to cement production and decarbonization, or for carbon budgeting for mineral extraction, then the plan preparation will continue in line with the current national planning guidance.

Support

Representation ID: 5852

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

The vision and eleven strategic objectives provide a sound and forward-looking basis for the policies that will help Rutland mitigate and adapt to climate change, especially as the first leading set of policies are entitled climate change.

The next 20 years, as covered by the Local Plan, are the most critical for tackling the climate crisis by achieving the required mitigation of climate change. So, a clear, unambiguous lead needs to be taken by Rutland County Council, if its vision to “become a leading example of a modern rural county” is to become a reality.

Support noted.

Support

Representation ID: 5853

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Several other local examples of recently published Local Plans, such as Central Lincs and Cambridgeshire, have already taken a positive approach and lead. It should be noted in this regard that subsequent direction by the Secretary of State (DLUHC) concerning the Future Homes Standard will still be bound by ‘the rule of law’ which must embrace “freedom, certainty, and fairness” and will be subject to judicial review if deemed an “unreasonable exercise of discretionary power vested in the Minister” (Appendix 5. Paper by Professor Paul Craig: The Rule of Law, Select Committee on Constitution Sixth Report, www.parliament.uk.)

Support noted. The Future Homes and Buildings Standards (which aims to improve the energy efficiency and carbon emissions of new homes and non-residential buildings through the Building Regulations system) should take effect in 2025. With such regulations still being debated and no legal guarantee that they will come into effect in 2025, Policy CC2 seeks to ensure that development proposals for existing and new buildings meet high energy efficiency standards, as a contribution towards achieving net zero, and as set out in the Government’s National Design Guide (2021).

Support

Representation ID: 6547

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Comments made on behalf of the Defence Infrastructure Organisation (DIO) as part of a full written response to Rutland Council. Representations should be read in context and not in isolation.

The DIO are supportive of the Council’s objective to tackle the climate crisis and ensure that development takes a proactive approach to carbon reduction, in line with national policy.

There are points of detail within the policies of this section, that need to be reviewed to ensure there is no duplication with other legislation (including Building Regulations and Future Homes Standards) or other policies within the emerging plan.

Support noted in relation to overall strategy on climate change. Responses on specific policies set out under individual policies.

Support

Representation ID: 6976

Received: 06/01/2024

Respondent: Greetham Parish Council

The aspiration for houses to be energy efficient and Carbon neutral is good, but the current base line has not been determined and the aspiration is tempered by the need to provide affordable houses.

Support noted. The evidence base for Climate Change policies include the document: Zero Carbon Policy Options for Net Zero Carbon Developments B(i) Carbon Reduction (July 2023) which gives historic, baseline and projected figures for greenhouse gas emissions in Rutland broken down into different sectors. For affordable housing, the Plan acknowledges that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments (that would include affordable housing). It is intended that further work to update the cost evidence will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023).

Object

Representation ID: 6987

Received: 06/01/2024

Respondent: Greetham Parish Council

Net Zero Carbon Footprint
Chapter 4, Climate change has a very clear objective. Namely:
"making Rutland a truly green county that is net zero carbon, with the challenge of reducing high levels of waste and our carbon footprint."
We think that the plan does not give a clear enough path as to how this will be achieved. It does not give a baseline of where we are at the moment, or measurable parameters of how the goal will be monitored and achieved.

This objective is set out in the council’s Corporate Strategy and there is a robust evidence base against which the Local Plan policies are drawn up. For the Climate Change policies these include the document: Zero Carbon Policy Options for Net Zero Carbon Developments B(i) Carbon Reduction (July 2023) which gives historic, baseline and projected figures for greenhouse gas emissions in Rutland broken down into different sectors. Greenhouse gas emissions are monitored for each local authority area by the Department for Energy Security and Net Zero and are published by the ONS.

Object

Representation ID: 7000

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

It is important that the policies included in the final draft Local Plan do not duplicate or overlap with matters that are more appropriately dealt with by the national building regulations. Building standards should not be dealt with through local plan policies.
The Plan proposes a large number of new climate change policies and from a practical perspective it would be helpful if these climate change policies could be combined into a smaller number of more focused policies to reduce the complexity of the emerging policy framework for officers and applicants. It is suggested that at most three policies are needed on the requirements for new development, changes to existing buildings and renewable energy.
Once all the matters covered by building regulations, the National Planning Policy Framework and the General Permitted Development Order are removed, many of the individual policies could be distilled into one or two bullet points within an over arching climate change policy. This is the approach taken by many authorities in local plans to avoid conflict between policies and unnecessary duplication.

A number of development plan documents have passed examination which have successfully included energy efficiency and/or other emissions reduction requirements beyond those of the Building Regulations. Such policies allow LPAs to meet the obligation on them to ensure development plan documents include policies designed to secure that development of land in the local authority’s area ‘contribute to the mitigation of, and adaption to, climate change’. The Future Homes and Buildings Standards (which aims to improve the energy efficiency and carbon emissions of new homes and non-residential buildings through the Building Regulations system) should take effect in 2025. With such regulations still being debated and no legal guarantee that they will come into effect in 2025, and recognising that buildings are the UK’s second-highest emitting sector, the Local Plan sets out a positive strategy through the Climate Change policies for carbon reduction and to mitigate against the impact of climate change. The Plan acknowledges that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is intended that further work to update the cost evidence for a number of options for the wording of CC2 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023).

In recognising the need for urgent action to address climate change, the Local Plan seeks to achieve this by a range of policies that reduce carbon dioxide emissions and encourage renewable energy generation. They consider all areas where greenhouse gas emissions can be reduced, including wider resource efficiency and its link to carbon emissions. Climate change mitigation is addressed including sustainable travel, net zero buildings, design, energy and water efficiency, renewable energy, supporting the circular economy and green infrastructure (for example through the protection of carbon sinks and carbon sequestration).

Object

Representation ID: 7201

Received: 08/01/2024

Respondent: Mr David Lawson

Why doesn't Public transport feature more highly in the plan especially related to climate change.

Response: Strategic Objective 10 seeks to ensure that development is supported by essential infrastructure and services, including public transport and this is covered by Policies INF1 and INF2. Agree that reference to the importance of increasing the proportion of trips made through sustainable transport and its role in reducing carbon emissions should be made in the Climate Change chapter with reference to Policies INF1 and INF2.

Object

Representation ID: 7204

Received: 07/01/2024

Respondent: Nicki Hooper

The plans are very generic and do not have a look ahead approach with global warming solely looking at electric cars and bikes.

Whilst these issues are covered in Policy CC13, in recognising the need for urgent action to address climate change, the Local Plan has a range of policies that reduce carbon dioxide emissions and encourage renewable energy generation. They consider all areas where greenhouse gas emissions can be reduced, including wider resource efficiency and its link to carbon emissions. Climate change mitigation is addressed including sustainable travel, net zero buildings, design, energy and water efficiency, renewable energy, supporting the circular economy and green infrastructure (for example through the protection of carbon sinks and carbon sequestration). Reference to be made to importance of supporting and enhancing sustainable forms of transport in introduction to Chapter 4.

Object

Representation ID: 7210

Received: 07/01/2024

Respondent: Nigel Blackburn

Climate change seems too restrained and doesn’t marry up to better public transportation in the area. It seem too generic and not specific enough.

In recognising the need for urgent action to address climate change, the Local Plan has a range of policies that reduce carbon dioxide emissions and encourage renewable energy generation. They consider all areas where greenhouse gas emissions can be reduced, including wider resource efficiency and its link to carbon emissions. Climate change mitigation is addressed including sustainable travel, net zero buildings, design, energy and water efficiency, renewable energy, supporting the circular economy and green infrastructure (for example through the protection of carbon sinks and carbon sequestration). Reference to be made to importance of supporting and enhancing sustainable forms of transport in introduction to Chapter 4.

Object

Representation ID: 7244

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Taylor Wimpey have a concern with the policies on climate change in the draft plan as they go beyond what national guidance suggests should be included in local policies.

Whilst the updated NPPF is less clear on this point, the Government is consulting on the Future Homes Standard (FHS) and Future Buildings Standard, which will set new requirements for energy efficiency and heating for new homes and non-domestic buildings.

Draft policies CC2 and CC4 set out Rutland County Council’s own local policy requirements in relation to the energy efficiency of new development and net zero carbon. Whilst TW are fully supportive of the Council’s strategic climate objectives, on the basis it is the Government’s intention to publish the FHS in 2024, TW would urge the Council to review their strategy in relation to Draft Policies CC2 and CC4 and consider whether it is necessary to include criteria that may duplicate the requirements of FHS.

LPAs have the power under the Planning and Energy Act 2008 to adopt planning policies that set higher targets for energy performance standards for development in their area than the national baseline providing that they are reasonable, comply with the usual plan-making requirements and do not affect the viability of new development to an unreasonable extent. A number of development plan documents have passed examination which have successfully included energy efficiency and/or other emissions reduction requirements beyond those of the Building Regulations. Such policies allow LPAs to meet the obligation on them to ensure development plan documents include policies designed to secure that development of land in the local authority’s area ‘contribute to the mitigation of, and adaption to, climate change’. The Future Homes and Buildings Standards (which aims to improve the energy efficiency and carbon emissions of new homes and non-residential buildings through the Building Regulations system) should take effect in 2025. With such regulations still being debated and no legal guarantee that they will come into effect in 2025, and recognising that buildings are the UK’s second-highest emitting sector, the Local Plan sets out a positive strategy through the Climate Change policies for carbon reduction and to mitigate against the impact of climate change. The Plan acknowledges that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is intended that further work to update the cost evidence for a number of options for the wording of CC2 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023).

Object

Representation ID: 7351

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

It is noted that despite the emerging local plan’s commitment to addressing climate change and the need for Rutland to become net carbon zero as set out within the local plan’s vision, there is no consideration in the individual assessment of sites in respect of their contribution towards these important objectives.
These matters should be considered in the selection of sites if the LPA is to meet its ambitions in these areas and it is apparent from a review of the Site Allocations Assessment that they have not been. This represents a missed opportunity to achieve the emerging local plan’s vision.

Support for inclusion of Climate Change policies in the Local Plan noted.

The Sustainability Appraisal (November 2023), that is one of the pieces of supporting evidence for the Local Plan, includes Climate Change, assessing sites with regard to both climate change mitigation and climate change adaptation. The SA concludes that: ‘the most sustainable sites are Oakham, Uppingham and the edge of Stamford, in South Kesteven District. The preferred sites deliver 86.6% of homes in these three main towns. In this respect, the preferred sites perform well by supporting the use of sustainable transport modes, given residents have good access to existing services, facilities and amenities in these towns. Due to the main towns forming key nodes to local transport networks, directing growth to these settlements would help to encourage a modal shift and reduce reliance on the private vehicle, helping to minimise an increase in emissions.’ Overall the SA concludes that, in the context of wider regional, national and global contributions to and impacts on climate change, both the preferred sites and the reserved sites are unlikely to represent a significant change in the baseline. As a result, no significant effects are anticipated.

Object

Representation ID: 7431

Received: 07/01/2024

Respondent: Cottesmore Parish Council

We welcome the increased priority given to Climate Change in this Reg18.Local Plan and introducing a suite of policies to ensure development has to meet many more up to date environment, design and energy efficient policies.
we are concerned that climate aspirations set out in this chapter have not consistently been reflected in the other chapters of the Plan, despite this being, promoted as a clear, almost overriding aspiration.
We understand that additional work is being undertaken on climate change policies - what will the status of this be – will they, for example, be subject to a separate consultation sometime later in 2024? They really cannot be introduced by RCC in this way, as they are either part of the Local Plan in which case they need to have been part of the Reg.18 consultation or they are not.

Response: Support for the increased priority given to Climate Change in the Local Plan noted. Climate Change policies are the first ones set out in the Local Plan and climate change was one of the assessment criteria used in the Sustainability Appraisal, a key piece of supporting evidence for the drawing up of the whole plan. Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Object

Representation ID: 7500

Received: 08/01/2024

Respondent: Wing Parish Council

We are pleased to see the prominence given to this critical issue, but feel strongly that the Council could and should be more ambitious. Several policies have been considerably watered down from the carbon reduction targets we had hoped RCC would follow. Central Lincs and Cambridge have set the necessary targets and their plans are adopted, while RCC appear to have backed down because of their flawed Viability Assessment. The situation has been made more difficult with the Minister putting out a directive that all LP’s must follow Building Regulations while the Future Homes Standard (FHS) intended to upgrade these is currently out for consultation. Astonishingly, the FHS does not even list solar panels as a developer requirement

Support for prominence given to climate change in the Local Plan noted. The evidence base on climate change includes consideration of the impact of policies on the viability of new developments. Further work to update this cost evidence is intended and this will inform the policies at the next stage of the local plan.
LPAs have the power under the Planning and Energy Act 2008 to adopt planning policies that set higher targets for energy performance standards for development in their area than the national baseline providing that they are reasonable, comply with the usual plan-making requirements and do not affect the viability of new development to an unreasonable extent. A number of development plan documents have passed examination which have successfully included energy efficiency and/or other emissions reduction requirements beyond those of the Building Regulations. Such policies allow LPAs to meet the obligation on them to ensure development plan documents include policies designed to secure that development of land in the local authority’s area ‘contribute to the mitigation of, and adaption to, climate change’. The Future Homes and Buildings Standards (which aims to improve the energy efficiency and carbon emissions of new homes and non-residential buildings through the Building Regulations system) should take effect in 2025. With such regulations still being debated and no legal guarantee that they will come into effect in 2025, and recognising that buildings are the UK’s second-highest emitting sector, the Local Plan sets out a positive strategy through the Climate Change policies for carbon reduction and to mitigate against the impact of climate change. The Plan acknowledges that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is intended that further work to update the cost evidence for a number of options for the wording of CC2 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023).

Object

Representation ID: 7576

Received: 08/01/2024

Respondent: Historic England

The Renewable Energy study does include reference to heritage, Grade II listed buildings and setting of heritage assets are not referenced nor are archaeology and non-designated heritage assets. Setting is of particular importance when assessing the impact of wind turbines.There is
strong concern regarding the methodology and
assessment of setting. Individual turbine locations are
shown on Figure 13, will a settings assessment be
undertaken? How was the 500 metre buffer considered for
RPAG’s? In particular, proximity should not be used as a
gauge of harm or impact when considering setting. The use of proximity does not comply with the NPPF; impact upon the setting of assets can occur from a great distance and not simply from sites ‘in close proximity’ to an asset,
dependant on the type of development.

The Renewable Energy Study Parts 1 and 2 (November 2023) forms part of the supporting evidence for Policy CC8. Historic constraints (Scheduled Monuments, Conservation Areas and Listed Buildings) are shown on the constraints figure. Impact on heritage assets and their setting is included in the criteria based policy CC8 on Renewable Energy. A similar criteria-based policy for renewable energy is in the adopted Central Lincolnshire Local Plan. In addition to Policy CC8, other Local Plan policies would be used to assess renewable energy schemes such as EN12 and EN13 which consider the historic environment and heritage assets, and their settings. Other guidance such as the NPPF/NPPG would also be used in the assessment of applications for renewable energy schemes. The NPPG recognises that the significance of a heritage asset derives not only from its physical presence but also from its setting, so careful consideration should be given to the impact of wind turbines on such assets.

Object

Representation ID: 7714

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

It is essential that the all the climate change requirements in the emerging local plan are considered in the final viability assessment of the plan, to avoid policies which impact on the deliverability of the homes and jobs needed.
The viability assessment highlights that this is an area of policy that the Council is currently developing and notes that the evidence being prepared to inform the local plan policy is at a relatively early stage. The viability assessment will need to be updated as the emerging local plan is refined.
It is unclear from the conclusions of the viability report whether the emerging climate changes policies are considered viable by the viability consultants. This needs to be clarified to inform the final draft of the Local Plan.

Comments regarding updating of viability assessment noted. The Plan acknowledges that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is intended that further work to update the cost evidence for a number of options for the wording of CC2 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Support

Representation ID: 7726

Received: 08/01/2024

Respondent: Anglian Water

Our Thriving East report indicates that Rutland ranks well on rainfall, temperature, and flood risk in the region. However, GHG emissions are high per resident and renewable energy capacity is also low.
Looking at other assessments of Rutland’s position on climate change, the Climate Scorecard assesses the Council at being at 14% versus the average for single tier councils of 36%. The Planning and Land Use score of 6% against an average of 35%. The absence of an up-to-date Plan means that the Council has not, for example, a net zero strategic objective or which requires whole life carbon assessment of new development.

Comments noted. Strategic Objective 1: Climate Change states that the council will take positive action to achieve net-zero through (in part) reducing a development’s embodied carbon as set out in Policy CC5.

Object

Representation ID: 7869

Received: 08/01/2024

Respondent: Ryhall Parish Council

More detail required, not a strong enough statement (no mention of RCC stated confirmation that we are in a Climate Crisis.

This is of critical importance, particular to our young generation who have no voice.

Consideration should be given to incorporate further re NPPF Chapter 13 Protecting Green Belt Land, i.e., further define our Greenbelt Areas, particularly in relation to para 143, 149, 150 and 152.

No mention of renewable energy, heat pumps - Appreciate that this may come under the Climate Resilient, however feel that our LP should be more prescriptive, than general.
We need developers to be under no doubt as per the standards required. It is understood that heat pumps are installed under the planning system with a noise assessment. It seems unacceptable to Ryhall Parish Council that they can be installed only 1m away from their neighbours and have a maximum decibel of approx. 42 (about the noise of a washing machine. However, one does not have a washing machine on all the time and we tend to have washing machines indoor! These guidelines must be revised as they are unacceptable.

There is not enough emphasis on improving existing energy efficiency in buildings or utilities (e.g., street lighting). We have to improve performance to achieve Net Zero across the county.

The opening paragraph of Chapter 4 states that the Council has declared a Climate Crisis. RCC has no Green Belt designations (and new Green Belts should only be established in exceptional circumstances) so Chapter 13 of the NPPF is not relevant to the local plan. Policy CC2 sets out design principles for energy efficiency including heating with a net zero carbon content. Issues of noise from ASHPs are dealt with through planning application legislation rather than the local plan process. The opening text in Chapter 4 acknowledges that the Local Plan has very limited influence over existing buildings but Policy CC7 does aim to improve the energy efficiency of existing buildings and CC8 seeks to maximise use of renewable energy including ASHPs. Any planning application for an ASHP would be assessed against Policy CC8 which takes into account noise impact. Energy efficient street-lighting would be a matter of wider council policy rather than through the local plan (except where part of a new development covered by Policy CC2.)