Support

Representation ID: 4752

Received: 13/12/2023

Respondent: Mr Andrew Lunn

This should include location of any new estates that will mean travel to and from places of employment and shops etc.. We need to reduce the use of cars etc to help meet our climate goals.

Comments noted. Tackling climate change and achieving sustainable development are two of the Strategic Objectives of the Local Plan. The Sustainability Appraisal (November 2023) 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.’

Object

Representation ID: 5037

Received: 02/01/2024

Respondent: Julie Gray

I believe this policy needs to be updated to be in line with the revised NPP

Comment noted. In line with the Climate Change Act 2008, the latest version of the NPPF (December 2023) para 158 states that: ‘Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures.’ CC3 sets out a number of design considerations for being more climate-resilient. Suggested changes to include green infrastructure for contributing towards mitigating the effects of climate change are set out under the response to Natural England's (5090) representation.

Support

Representation ID: 5060

Received: 02/01/2024

Respondent: Mary Cade

Point d) needs to be separated into 2 , with a proposed point e) 'to minimise future resource consumption in the adaptation and redevelopment of buildings in response to future needs, in line with Policy CC1'

Agree.

Object

Representation ID: 5090

Received: 03/01/2024

Respondent: Natural England

Natural England consider that this policy should include how development (and associated provision for onsite nature enhancement /landscaping etc.) will be climate resilient with the use of nature based measures. For example green roofs and walls, and street trees can modify microclimates, most notably by reducing ambient temperatures in summer and reducing urban heat islands. Detailed guidance on how green infrastructure can contribute to tackling climate change appears in the Green Infrastructure Design guide. (Natural England Green Infrastructure Planning and Design Guide 2023)

Comments noted. Partly agree. Green roofs and walls can assist in reducing overheating but are not always feasible or appropriate. Other nature-based climate change mitigation measures such as tree planting and landscaping is covered in Policy EN7: Green and Blue Infrastructure Network. The text accompanying that policy acknowledges the contribution that nature-based solutions can make to mitigating and reducing the risks of climate change.

Object

Representation ID: 5149

Received: 03/01/2024

Respondent: Mr Frank Brett

The policy should explicitly support use of sustainable materials e.g. Timber Frame and/or Hemp blocks / hempcrete. The Design Guidelines SPD may need to change as well to reflect this. Rutland should create an expectation that goes further than national regulations.

Comments noted. Disagree. The use of sustainable materials is covered under Policy CC5: Embodied Carbon that seeks to reduce the carbon emitted from the sourcing and construction of building materials. The Design Guidelines for Rutland SPD includes reference to the Climate Emergency and addresses embodied carbon. The SPD also refers to the LETI Climate Emergency Design Guide (2020) that offers guidance on reducing carbon emissions in new development.

Object

Representation ID: 5503

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

Draft Policy CC3 and CC2 do not relate well together and should be re-drafted, perhaps as one more coherent policy. Policy CC2 seeks to maximise solar gain - Policy CC3 seeks to minimise overheating. Again, orientation alone cannot be the answer, and there needs to be flexibility here to ensure development produces decent places and houses that people want to live in. Is wind exposure a material planning consideration - where has this criterion come from and what evidence is there to support it?

Comments noted. Disagree. Subject to change to Policy CC2 part a) to read: orientation of buildings such as to manage opportunities for solar gain and to minimize winter cold wind heat loss’, 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 PPG on climate change advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. Examples include maximising summer cooling and avoiding solar gain. Requiring applicants to consider how buildings can minimise overheating is therefore justified in seeking to secure high quality design and higher levels of efficiency in new construction. 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.’ With the increase in extreme weather events, such as storms with higher wind speeds, as a consequence of climate change, then inclusion of mitigation of risks related to wind exposure is justified.

Support

Representation ID: 5560

Received: 05/01/2024

Respondent: Mrs laura alcock

Mitigation of flooding should also be included.

Comment noted. Mitigation measures against flood risk is included in part b) with reference to Policy CC14: Flood Risk.

Support

Representation ID: 5840

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

These are also excellent points b) to d) to include in the Design and Access Statement. But please add a) to the required Energy Statement.

Also split section d) into two points as they are both separate and important points:
d) How the proposal is flexible to future social, economic, technological, and environmental requirements in order to make buildings fit for purpose in the long term.
e) How to minimise future resource consumption in the adaptation and redevelopment of buildings in response to future needs with reference to the circular economy in CC1.

Support noted. Agree to include considerations set out in CC3 into an Energy Statement (rather than a DAS) and to split part d) into two parts.

Support

Representation ID: 6043

Received: 07/01/2024

Respondent: Mr Roderick Morgan

Sites for development of housing or commercial buildings should be selected based on how appropriate they are in line with this policy, rather than whether they are offered in response to a "call for sites". This is leading to sites being potentially developed which are very hard to design to be resilient to flood and other risks, and also trigger additional risks for surrounding areas, by affecting the landscape. Flood plain development should be banned and reversed rather than 'mitigated'.

Comments noted. Disagree. The PPG on Climate Change sets out how the challenges of climate change can be addressed through the local plan, including considering future climate risks when allocating development sites to ensure risks are understood over the development’s lifetime. A call for sites is a way to suggest sites that might be available for development in the future and is a normal part of plan making. The Sustainability Appraisal (November 2023) includes climate change, assessing sites with regard to both climate change mitigation and climate change adaptation, including flood risk.

Support

Representation ID: 6284

Received: 07/01/2024

Respondent: Mr Chris Read

Clearly this is sensible. I hope that planning/building control and Committee will abide by these principles in future.

Support noted.

Object

Representation ID: 6478

Received: 08/01/2024

Respondent: Ms Jo Carr

I’ve we have learned something of late, it is that new estates contribute to flooding through compacting the ground and speeding up water run-off. Before any new plots of land are identified, existing buildings need to be reviewed as this is an important flood risk mitigation.

Comments noted. The Strategic Flood Risk Assessment (2023) examines flood risk across Rutland including maps showing all identified sources of flood risk and an assessment of the implications of climate change on flood risk. This forms an evidence base for further decision-making on the water environment and water infrastructure provision and is a supporting document for the drawing up of the Local Plan.

Object

Representation ID: 6589

Received: 08/01/2024

Respondent: Distinctive Developments Group Ltd

This policy seems to be at odds with policy CC2 which encourages solar gain. The measures suggested should again be addressed via the BRegs process and do not need to be repeated or enlarged upon within planning policy. It is not stated how some of the criteria can be met/measured, which leaves it open to interpretation. The planning system needs less ambiguity and more certainty in order to support successful and timely housing delivery.

Disagree. Subject to change to Policy CC2 part a) to read: orientation of buildings such as to manage opportunities for solar gain and to minimize winter cold wind heat loss’, 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 PPG on climate change advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. Examples include maximising summer cooling and avoiding solar gain. Requiring applicants to consider how buildings can minimise overheating is therefore justified in seeking to secure high quality design and higher levels of efficiency in new construction. 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.’

Object

Representation ID: 6753

Received: 05/01/2024

Respondent: Barrowden Parish Council

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.

Disagree. Subject to change to Policy CC2 part a) to read: orientation of buildings such as to manage opportunities for solar gain and to minimize winter cold wind heat loss’, 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 PPG on climate change advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. Examples include maximising summer cooling and avoiding solar gain. Requiring applicants to consider how buildings can minimise overheating is therefore justified in seeking to secure high quality design and higher levels of efficiency in new construction. 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.’

Object

Representation ID: 7129

Received: 08/01/2024

Respondent: National Grid

Agent: Avison Young

The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by NGET.

NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.

Therefore, to ensure that Design Policy CC3 is consistent with national policy we would request the inclusion of a policy strand such as:

“x. taking a comprehensive and co-ordinated approach to development including respecting existing
site constraints including utilities situated within sites.”

Comments noted but disagree with proposed inclusion in this policy. Such a policy strand, that seeks to protect utilities’ assets, would be best placed in a general design policy rather than in Policy CC3 that deals specifically with the design of buildings to be resilient to climate change. RCC DM will already be aware of guidance put out by National Grid: ‘Guidelines for Development near pylons and high voltage overhead power lines’.

Object

Representation ID: 7134

Received: 08/01/2024

Respondent: National Gas Transmission

Agent: Avison Young

National Gas Transmission advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around underground gas transmission pipelines and other National Gas Transmission assets.

Therefore, to ensure that Design Policy CC3 is consistent with national policy we would request the inclusion of a policy strand such as:

“x. taking a comprehensive and co-ordinated approach to development including respecting existing
site constraints including utilities situated within sites.”

Comments noted but disagree with proposed inclusion in this policy. Such a policy strand, that seeks to protect utilities’ assets, would be best placed in a general design policy rather than in Policy CC3 that deals specifically with the design of buildings to be resilient to climate change. RCC DM will already be aware of the requirements for consulting with National Gas Transmission where a development may affect their assets.

Object

Representation ID: 7171

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

In response to wind exposure (criteria c) this is covered in detail under Building Regulations where different building standards apply depending on whether an area falls within an area of low, medium or high areas of wind exposure.

This criterial point is therefore not justified and merely a duplication of building regulations and as such should be removed from the policy.

The PPG on Climate Change advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. With the increase in extreme weather events, such as storms with higher wind speeds, as a consequence of climate change, then inclusion of mitigation of risks related to wind exposure is justified. Similar wording is used in the Adopted Central Lincs Local Plan (2023).

Support

Representation ID: 7223

Received: 07/01/2024

Respondent: Mr Harold Dermott

Good to see the new Part O of Building Regulations that sets certain minimum requirements for overheating risk mitigation, in new-build homes included. Together with the other requirements in this section, hopefully we can finally move away from construction techniques that have changed very little for several hundred years.

Support noted.

Support

Representation ID: 7276

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 noted.

Support

Representation ID: 7343

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The broad principles of this policy are all supported and align with the NPPF. However, any duplication with other policies should be avoided. For example, there appears some crossover with the requirements in policy CC14 and CC1 within policy CC3, particularly points b) and d), which could be incorporated within policy CC1. This should be addressed to ensure the policies are compliant with the NPPF.

Support noted. Disagree. The PPG on Climate Change advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. Policy CC3 deals with the future proofing of new development against the impact of climate change in accordance with the PPG. It is appropriate to cross reference to both CC1 and CC14 in the policy so as to guide developers on the wider requirements of the circular economy and flood risk.

Object

Representation ID: 7401

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Hereward Homes consider that as with Policy CC2, this policy would appear to go beyond matters that should be considered under the planning system. Criterion 1 is surely a Building Regulations matter. Would planning development management staff have the technical ability to assess matters included under criterion 3 and criterion 4? These matters should be considered through a comprehensive Design Code approach that is subject to extensive stakeholder engagement. Without this there is 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.

Disagree. The PPG advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. Examples include maximising summer cooling and avoiding solar gain. Requiring applicants to consider how buildings can minimise overheating is therefore justified in seeking to secure high quality design and higher levels of efficiency in new construction. The policy is considered to be justified, effective and consistent with national planning policy. A similar policy approach has been taken with the recently adopted Central Lincs Local Plan (2023).

Object

Representation ID: 7502

Received: 08/01/2024

Respondent: Wing Parish Council

Again the policy is weak, in requiring only that developers should “consider” various elements in their designs.

Agree in part. The PPG advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. As worded, there is no requirement for developers to document their considerations as set out in the policy but some flexibility as to the relevance of the policy to the scale/type of proposals must be retained.

Object

Representation ID: 7667

Received: 08/01/2024

Respondent: South Luffenham Parish Council

The plan looks at designs to reduce overheating and negate the use of air conditioning. The use of ASHP’s to reduce carbonisation by 2030 within new developments would by its nature provide cooling via underfloor heating or buildings will have to be designed to reduce heat gains via orientation or use thermal mass, which might be at variance with the plan for affordability housing. Where large sites are proposed consideration should be given to ground source heat pumps system serving multiple dwellings.

Comments noted. Maximising the generation of energy from ASHPs and ground source heat pumps would be encompassed in part f) of CC2 and both are included in the list of renewable energy technologies in the introductory text to Policy CC8.

Support

Representation ID: 7873

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC3 Resilient and Flexible Design - Support

Support noted.