Support

Representation ID: 6730

Received: 07/01/2024

Respondent: Lucy & Tom Pengilley Gibb

Number of people: 2

Solar should be a mandatory requirement on all new homes and industrial buildings

It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 6734

Received: 07/01/2024

Respondent: Aileen Coupe

Number of people: 2

Solar panels should be a mandatory requirement for all new dwellings and industrial buildings.

It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Object

Representation ID: 6752

Received: 05/01/2024

Respondent: Barrowden Parish Council

CC2
There appears to be a contradiction between these two policies in that CC2 seeks “.. to optimise opportunities for solar gain..”, whereas Page 81 CC3 should “.. prevent overheating..”

We would ask that these policies are clarified and examples of how developer can optimise solar gain while preventing overheating.

Agree some contradiction. The two policies are seeking to achieve design solutions that manage solar gain whilst preventing overheating – a balance between the two is required. There are significant benefits in solar gain in terms of heating and solar panel efficiency particularly in the winter months but these must be balanced against the harmful risks of overheating. The National Design Guide (2021) has useful advice: ‘Well-designed buildings make the most of passive design strategies to minimise overheating and achieve internal comfort. These include: the layout and aspect of internal spaces; insulation of the external envelope and thermal mass; management of solar gain; and good ventilation to reduce overheating.’

Support

Representation ID: 6783

Received: 08/01/2024

Respondent: Wendy Dalton

Industrial building - All new industrial building to be fitted with solar panels and batteries- no carbon offsetting as an alternative.

Disagree. It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 6799

Received: 02/01/2024

Respondent: Gary Firkins

Solar panels should be a mandatory requirement for all new dwellings and industrial buildings.

It would not be appropriate to mandatorily require all new dwellings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources. The Local Plan has little, if any, influence over domestic or commercial retrofitting of solar panels where such alterations do not require planning permission.

Support

Representation ID: 6802

Received: 02/01/2024

Respondent: Mrs Jayne Williams

The council should encourage the installation of solar panels on all new builds, domestic and commercial.

It would not be appropriate to require all new dwellings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 6805

Received: 04/01/2024

Respondent: Mrs Carol Dry

We should encourage solar panels on all new-builds and industrial buildings, and existing buildings. This is of the utmost importance .

It would not be appropriate to require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources. The Local Plan has little, if any, influence over domestic or commercial retrofitting of solar panels where such alterations do not require planning permission.

Support

Representation ID: 6871

Received: 07/01/2024

Respondent: Peter Shaw

Large scale solar farms of this type should not be allowed on farmland of any description. Instead solar panels should be a mandatory requirement for all new dwellings and industrial buildings and encouraged on existing domestic and commercial buildings.

Sites that are potentially suitable for ground mounted solar energy schemes are identified on the Local Plan proposals map. These are on the basis of evidence set out in the supporting renewable energy documents. The issue of their siting on BMV agricultural land is set out in Policy CC8. It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources. The Local Plan has little, if any, influence over domestic or commercial retrofitting of solar panels where such alterations do not require planning permission.

Object

Representation ID: 6890

Received: 08/01/2024

Respondent: Ian Mcalpine

In section CC 2, condition 6 should be strengthened to say that planning permission for new build commercial and residential developments will only be granted, other than in exceptional circumstances, where the design incorporates photovoltaic panels.

Disagree. It would not be appropriate to mandatorily require all new buildings to have solar pv panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Object

Representation ID: 6898

Received: 06/01/2024

Respondent: Richard Camp

It is of concern to see so few older and new domestic and commercial buildings with solar panels. The Local Plan should include clearly expressed policies on the requirement for new builds to have relevant solar panels and heat exchangers, if necessary with the requirement that developers should install these.

Disagree. It would not be appropriate to mandatorily require all new buildings to have solar panels and ASHPs through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 6911

Received: 05/01/2024

Respondent: Ms Erica Downs

Instead, solar panels should be a mandatory requirement for all new dwellings and industrial buildings

Disagree. Sites that are potentially suitable for ground mounted solar energy schemes are identified on the Local Plan policies map. These are on the basis of evidence set out in the supporting renewable energy documents. The issue of their siting on BMV agricultural land is set out in Policy CC8. It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources. The Local Plan has little, if any, influence over domestic or commercial retrofitting of solar panels where such alterations do not require planning permission. Policies in the Local Plan would not necessarily prevent solar panels on protected buildings where listed building consent is required.

Object

Representation ID: 6939

Received: 08/01/2024

Respondent: Morcott Parish Council

1. policy needs to be both strengthened and adapted so that emerging technologies are included - eg hydrogen and small nuclear. Paragraphs d. e. and f. should be subject to these revisions.
2. inserting provisions that ensure that there is an obligation to install the latest climate change friendly technology as this becomes available.
3. including provisions within d. e. and f. which recognises that technology will change over the life of the Plan.
4. Para d. should include heat recovery from ground sources including ground water.
5. Para e. should include a reference to hydrogen or other forms of climate friendly gases being permitted in future to be supplied by a gas distribution main. Hydrogen forms a key part of the UK Government long term energy infrastructure plans.
6. Para f. should specifically mention solar pv, wind, air source and ground source technology.

Disagree. Part d) already references the ‘most efficient available technologies’ which would take into account new technologies. Parts e) and f) would also apply to new technologies. Part f) encompasses all on-site renewables: solar pv, wind, air source and ground source technology.

Object

Representation ID: 7079

Received: 08/01/2024

Respondent: Mr Tony Godwin

Policy CC2 is admirable but how it to be judged and enforced. ‘Expected’ is not’ required’. Applicants have been playing the low energy card to beautify applications for some years now. But these are often vague and do not deliver. Can this be related to a standard – percentage better then building regs for example. Passivhaus is known to deliver and deals with retrofit also. the AECB has useful standards.

It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which is due to take effect in 2025. Thiss still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for new energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.

Support

Representation ID: 7086

Received: 07/01/2024

Respondent: Bob Chidgey

Solar panels should be a mandatory requirement for all new dwellings and industrial buildings.

It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 7130

Received: 08/01/2024

Respondent: Mr Douglas Reid

Solar panels should be a mandatory requirement for all new dwellings and industrial buildings.

Sites that are potentially suitable for ground mounted solar energy schemes are identified on the Local Plan proposals map. These are on the basis of evidence set out in the supporting renewable energy documents. The issue of their siting on BMV agricultural land is set out in Policy CC8. It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources. The Local Plan has little, if any, influence over domestic or commercial retrofitting of solar panels where such alterations do not require planning permission.

Object

Representation ID: 7170

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes welcome a policy on Energy Efficiency and the need for Design and Access Statements to demonstrate how energy efficiency has been considered in the development of the scheme. Criteria a) to d) of the policy are fully supported.

With regards to criteria e) ‘net zero carbon content of heat supply’, Persimmon Homes are of the view that this criteria should be removed from the policy. The vehicle for delivering the net zero content of heat supply is through Building Regulations and this is already happening with Part L requiring a 31% carbon reduction upon previous Building Regulations and a move to a decentralised network in 2025.

Point f), also suggest this be removed for the same reasons as per criteria e) above with Building Regulations being the most effective vehicle for introducing these standards.

In respect to criteria e) and f) in the Housing Ministers Written Statement of the 13th December 2023 on Energy Efficiency which sets out the Government does not expect Local Planning Authorities to set enhanced energy efficiency standards via local plans and instead these should come through Building Regulations. Neither the wording of the policy or the evidence base meet these two criteria further supporting the removal of criteria e) and f) from this policy.

Support for parts a) to d) noted. Part e) Disagree. It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.
Part f) Disagree. It is appropriate for the Local Plan to seek to maximise the generation of renewable energy on site but it is also acknowledged that there are a number of factors that would need to be taken into account as to whether renewable energy can be installed on site such as location, efficiency and viability. The wording of the policy allows for such an justified argument to be made.
Disagree regarding the weight that must be given to the WMS 2023. Legal advice obtained by Essex County Council in February 2024 (https://www.essexdesignguide.co.uk/media/2966/updated-open-advice-re-energy-policy-building-regs-26-2-24-final.pdf) concludes that: ‘Local Authorities have a clear power, in sections 1-5 of 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, provided such standards comply with the usual plan-making requirements of section 19 of the Planning and Compulsory Purchase Act 2004 and are reasonable, in that they do not affect the viability of new development to an unreasonable extent. This position has not been changed by the 2023 WMS. The WMS must be interpreted in a way that allows for the effective operation of the PEA 2008 powers; and allows LPAs effectively 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 adaptation to, climate change’. This means that the 2023 WMS cannot be interpreted to prevent LPAs from putting forward, and planning inspectors from finding sound, policies which are justified and evidenced and which use metrics other than the Target Emissions Rate metric and/or do not require calculation by Standards Assessment Procedure.

Object

Representation ID: 7192

Received: 08/01/2024

Respondent: Allison Homes

AH suggests that Policies CC2 and CC4 are removed, and that the Plan takes a more flexible approach to requiring developments to meet national sustainability standards being developed and enforced through the Building Regulations which in turn would future proof the policy.

The Council may wish to reconsider this policy in the context of the consultation version of the FHS

Disagree regarding CC2. It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges, however, that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.

Support

Representation ID: 7215

Received: 08/01/2024

Respondent: Catherine Morgan

The priority should be on all new houses and commercial buildings to have roof mounted PV and solar heating, plus other renewable energy systems like heat pumps and batteries,

It would not be appropriate to mandatorily require all new buildings to have solar panels and/or heat pumps through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 7222

Received: 07/01/2024

Respondent: Mr Harold Dermott

Brilliant! At last a policy that recognises that, to retrofit a home to the required standards, costs three to five times as much as it would cost to simply build to these
standards in the first place”. Retrofit would also be highly disruptive to the occupants, which disincentivises these improvements ever occurring.

As long as this is “in addition to the requirements of policy SC3 of the Sustainable Communities chapter” and cannot be rejected or watered-down by any policy within SC3 or any other policy in the Local Plan, this is a huge step forward.

“orientation of buildings to optimise opportunities for solar gain and to minimise winter cold wind heat loss” is extremely important: not only does is maximise natural solar gain but ensures that solar panels are at their most effective. Another way of saying this is that ANY building on ANY development with their major roof(s) aligned in the northern quadrant between south west and south east will NOT receive planning permission.

“net zero carbon content of heat supply” About time! Thank you.

Those households without solar panels simply cannot understand the huge effect that they have in reducing fuel bills. As we move to all-electric dwellings, the significance of energy storage, most easily done in this context by storage batteries, becomes more important.

Home battery storage is highly practical and available NOW. I would therefore suggest adding “and energy storage” after “generation of energy” in the policy line above, thus: “maximising the generation of energy and energy storage from renewable sources on-site”.

The energy storage could be a single unit for the whole development, allowing communities to create an income from a community battery storage. Alternatively,
individual storage batteries in each house which can be combined to form a virtual power plant, both have their benefits.

Support for Policy CC2 noted. Agree to adding in ‘and energy storage’ after ‘generation of energy’ in part f).

Support

Representation ID: 7275

Received: 08/01/2024

Respondent: Manor Oak Homes

Agent: Mr Andy Moffat

The proposed approach which does not set out prescriptive standards is supported.

Support for CC2 noted.

Object

Representation ID: 7314

Received: 08/01/2024

Respondent: Avant Homes

Whilst Avant supports the national intentions to set standards for energy efficiency through the Building Regulations, it is important that the Council do not seek to deviate from the Government policy position - either in terms of bringing additional enhancements in earlier than National Policy, or to a level that exceeds the National requirements. To do so, could lead to unnecessary delays to delivery of housing, and undermine the delivery of wider environmental objectives. As a principle, therefore, Avant would object to any policy which seeks to set higher benchmarks and standards when considered against National requirements.

Support for CC2 noted. Local Authorities do have a clear power, in sections 1-5 of 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, provided such standards comply with the usual plan-making requirements of section 19 of the Planning and Compulsory Purchase Act 2004 and are reasonable, in that they do not affect the viability of new development to an unreasonable extent. ((https://www.essexdesignguide.co.uk/media/2966/updated-open-advice-re-energy-policy-building-regs-26-2-24-final.pdf) It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.

Object

Representation ID: 7342

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The policy must ensure it is aligned with the Written Ministerial Statement entitled, ‘Planning – Local
Energy Efficiency Standards Update’. This sets out that, ‘The Government does not expect plan-makers
to set local energy efficiency standards for buildings that go beyond current or planned buildings
regulations…. Any planning policies that propose local energy efficiency standards for buildings that go
beyond current or planned buildings regulation should be rejected at examination if they do not have a well reasoned and robustly costed rationale that ensures:
• That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework.
• The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions
Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).

This relates in particular to criteria e) around heat supply and connect to the gas network.

Point f) should clearly ensure that energy consumption is reduced initially and only any remaining energy
requirements are from renewable energy sources. Energy generation on ‘or near’ the site should also be prioritised to ensure there is flexibility to accommodate site specific circumstances.

It is also considered that these measures could be better addressed through a dedicated Energy/Sustainability Statement, rather than the Design & Access Statement, with clear examples and supporting text clearly explaining the requirements to ensure there is certainty over the implementation requirements associated with this policy

Broad support for Policy CC2 noted. Disagree regarding the weight that must be given to the WMS 2023. Legal advice obtained by Essex County Council in February 2024 (https://www.essexdesignguide.co.uk/media/2966/updated-open-advice-re-energy-policy-building-regs-26-2-24-final.pdf) concludes that:
Local Authorities have a clear power, in sections 1-5 of 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, provided such standards comply with the usual plan-making requirements of section 19 of the Planning and Compulsory Purchase Act 2004 and are reasonable, in that they do not affect the viability of new development to an unreasonable extent. This position has not been changed by the 2023 WMS. The WMS must be interpreted in a way that allows for the effective operation of the PEA 2008 powers; and allows LPAs effectively 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 adaptation to, climate change’. This means that the 2023 WMS cannot be interpreted to prevent LPAs from putting forward, and planning inspectors from finding sound, policies which are justified and evidenced and which use metrics other than the Target Emissions Rate metric and/or do not require calculation by Standards Assessment Procedure. Having said this, it is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.
Disagree part f). Maximising the generation of energy from renewable sources on-site would play a vital role in reducing carbon emissions in accordance with national planning policy. On-site generation is most appropriate and achievable and it is very unlikely that developers would be able to secure renewable energy generation nearby off-site.
Agree that the measures required in Policy CC2 would be best addressed in an Energy Statement rather than in the Design and Access Statement. Such a requirement should form part of the local list for RCC’s validation requirements.

Object

Representation ID: 7399

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

This Policy in part to duplicates building regulation requirements, particularly criteria 3, 4 and 5. If this is the case Hereward Homes considers that it should it be removed. Would planning development management staff have the technical skills to be able to assess this level of detail or would they involve Building Control at the 2
planning Stage? Have Building Control got the additional resources to do this evaluation at the planning stage? We note criteria 1 and 2 need to be balanced against the need for the design and layout of new development to be informed by an analysis of the site context, particularly in a heritage setting. These matters should be considered through a comprehensive Design Code approach that is subject to extensive stakeholder engagement. Without this there is potentially a significant risk that decision making will be ad-hoc and that the delivery of growth will be significantly delayed. This policy seems to seek to impose an unnecessary and unwarranted burden on new development and applicants for planning permission.

It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.

Object

Representation ID: 7501

Received: 08/01/2024

Respondent: Wing Parish Council

This is very much “motherhood and apple pie”, lacking specifics and with no indication of how it will be enforced. What does “highest possible energy efficiency standards” mean? Where is an ambitious target? There are local concerns about how to improve energy efficiency of homes in Wing especially older/listed houses but the planning constraints imposed by RCC on altering existing housing are significant. The adoption of Future Homes Standard will provide little energy efficiency gain so not offsetting Rutland’s older housing stock.

Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.
The Local Plan has little, if any, influence over domestic retrofitting, or the financing, of solar panels/insulation where such alterations do not require planning permission. Policies in the Local Plan would not necessarily prevent solar panels on protected buildings where listed building consent is required.

Object

Representation ID: 7537

Received: 08/01/2024

Respondent: House Builders Federation

HBF supports the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to success is standardisation and the
avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers,
suppliers and developers. The Councils do not need to set local energy efficiency standards, or a requirement for zero carbon homes, in a Local Plan policy.

HBF would caution against policies that seek to go further and faster than national policy changes as this would lead to a patchwork of local policies which could undermine the delivery of these wider environmental objectives and create unnecessary delays to much needed new housing.

If a policy were to remain, HBF would question if the requirement for all new development to be net zero carbon in terms of heat supply is realistic in all cases,
and suggest some flexibility is needed within the policy.

It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 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) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.
Disagree regarding part e). The policy already has flexibility built in with the use of words ‘should demonstrate’ and ‘have influenced’ in the second sentence.

Object

Representation ID: 7574

Received: 08/01/2024

Respondent: Historic England

There is no reference to listed buildings and other
heritage assets.

Historic England would be very happy to assist with wording. Examples might include reference to a whole building approach in the retrofitting of traditional buildings, whereby applications will need to demonstrate how principles such as the following have been embedded in the design rationale – methodical assessment of the buildings heritage significance, harm to heritage significance, advice from heritage professionals.

Noted but Policy CC2 should not be read in isolation as set out in ‘How to use the Plan’ in the opening chapter. The accompanying text to CC2 makes reference to Policy SC3 and the Design Guidelines for Rutland SPD (2021) (which recognises the importance of the rich heritage that Rutland has when designing schemes). Local Plan policies EN12 and EN13 consider the protection of the historic environment.

Support

Representation ID: 7643

Received: 08/01/2024

Respondent: Mr Robert Bolton

Solar should be a mandatory requirement for all new dwellings and industrial buildings, and further encouraged on domestic, industrial and commercial buildings to facilitate green energy and protect our food security and maintain the Rutland countryside for future generations.

This would encourage a huge uptake and rollout of solar, benefitting local businesses with no detrimental implications or negative impacts.

It would not be appropriate to mandatorily require all new buildings to have solar panels through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Object

Representation ID: 7666

Received: 08/01/2024

Respondent: South Luffenham Parish Council

Plan concentrates on new build developments and building to almost “Passivhaus” standards. Consideration should be given to existing building stock in reducing heat losses and energy usage of primary fuels i.e. gas/oil/electric

Noted. One of the objectives in the Council’s Corporate Strategy is to reduce carbon emissions but the Local Plan has no influence over domestic retrofitting, or the financing, of insulation/changes from primary fuels where such alterations do not require planning permission.

Support

Representation ID: 7728

Received: 08/01/2024

Respondent: Anglian Water

Anglian Water supports policies CC2, CC3 and CC4 including the cost benefits and carbon efficiencies from designing and building energy (water?) efficient buildings as opposed to retrofitting. Given the construction of new homes and building stock is approximately 1% per year and we have just over 25 years until net zero being legally required in 2050, the benefits of making a step change in construction and building performance is clear. Our sector leading approach on climate change means that we are able to provide information to show how we comply with these policies in our developments.
On CC2 d) we support the potential for heat recovery from wastewater.
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 the CC2 f)

Support for CC2 welcomed. Comment regarding part f) noted. The policy is worded (‘should demonstrate’) flexibly so would take into account the scale and function of such small developments when the policy is applied.

Object

Representation ID: 7787

Received: 08/01/2024

Respondent: Edith Weston Parish Council

Policy CC2 (a) needs to make mention of overheating.

Disagree. Policy CC3 – Resilient and flexible design – considers overheating. The two policies in tandem are seeking to achieve design solutions that manage solar gain whilst preventing overheating – a balance between the two is required. There are significant benefits in solar gain in terms of heating and solar panel efficiency particularly in the winter months but these must be balanced against the harmful risks of overheating. The National Design Guide (2021) has useful advice: ‘Well-designed buildings make the most of passive design strategies to minimise overheating and achieve internal comfort. These include: the layout and aspect of internal spaces; insulation of the external envelope and thermal mass; management of solar gain; and good ventilation to reduce overheating.’