Support

Representation ID: 4753

Received: 13/12/2023

Respondent: Mr Andrew Lunn

Solar panels should be a must and not an option. Design of buildings can make sure these are standard fitment and not design estates for maximum financial gain by the developer.

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. This approach is reflected in the wording of Policy CC4. 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 also in Local Plan Policy CC2 that seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 4954

Received: 31/12/2023

Respondent: Mrs Jayne Williams

This is the most sensible way to roll out solar energy. Rooftops, both commercial and domestic should be utilised before farmland.

Support noted.

Object

Representation ID: 5026

Received: 02/01/2024

Respondent: Pigeon Investment Management

The requirements of this draft policy go beyond that of the draft consultation stage requirements of the Future Homes Standards (FHS). This sets out that systems should be an appropriate size for the site, available infrastructure and on-site energy demand. The Council may wish to reconsider this policy in the context of the consultation version of the FHS.

The FHS has now been renamed the Future Homes and Buildings Standards – FHBS. It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the FHBS 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. 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) 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 CC4 seeks to ensure that new development does not add to the challenge of reducing Rutland’s emissions. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 renewable energy generation, 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 energy demand targets such as that used in other adopted local plans.

Support

Representation ID: 5065

Received: 02/01/2024

Respondent: Mary Cade

This policy should apply to all new buildings - individual, estate, commercial - with roof mounted solar panels mandatory . The phrase 'practically and viably' is too vague and provides an easy way for a developer to argue their way out of fulfilling the policy. What expertise will be available to aid developers and planners to produce and assess Energy Statements?

Agree that policy should not just apply to major development but should exclude householder and applications for listed building consent. 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. This approach, which must have some flexibility built in, is reflected in the wording of Policy CC4. 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 also in Local Plan Policy CC2 that seeks to maximise energy generation from on-site renewable sources. RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy.

Support

Representation ID: 5470

Received: 05/01/2024

Respondent: Ms Janet Taylor

All properties, residential and commercial, should have solar generation and storage. Combined with proper insulation and heat recovery systems it is possible to make houses pretty much energy self-sufficient

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. This approach, which must have some flexibility built in, is reflected in the wording of Policy CC4. 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 also in Local Plan Policy CC2 that seeks to maximise energy generation from on-site renewable sources.

Object

Representation ID: 5505

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

This policy as drafted places a huge burden on applicants for housing. Does this mean every planning application from a single plot to 1,000 houses (say) will have to provide a viability report to set out the level of renewable energy generation is the "maximum" viably possible on site? How else would the Council assess this. Criterion 2. is especially challenging as this level of post-development testing is not a function of national policy, where such matters are generally caught anyway by Building Regs and EPC's. What is the evidence to support the need for this?

Comments noted. Disagree. The NPPF states that, in order to increase the use and supply of renewable and low carbon energy, plans should provide a positive strategy for energy from these sources. As a local plan has a limited influence on retrofitting existing buildings, in order to reach targets for carbon reductions, significant reductions in the energy requirements of new buildings are urgently needed and Policy CC4 seeks this aim. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum generation’, 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 energy demand targets for renewables such as that used in other adopted local plans.

Support

Representation ID: 5562

Received: 05/01/2024

Respondent: Mrs laura alcock

agree

Support noted.

Support

Representation ID: 5802

Received: 06/01/2024

Respondent: Mrs Sue Scarrott

Every new house should have solar panels on the roof - this needs to be added to the Plan.

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. This approach, which must have some flexibility built in, is reflected in the wording of Policy CC4. 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 also in Local Plan Policy CC2 that seeks to maximise energy generation from on-site renewable sources.

Object

Representation ID: 5841

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

The requirement for an Energy Statement is welcomed. However the phrase “practically and viably possible” is vague, non-specific and immeasurable. It should be backed up by cross-reference to policy CC2.

Add “Where on-site renewable energy is not practical or viable, equivalent off-site renewable energy should be provided or an offset price of £5-15K per dwelling should be paid to RCC”, as recommended in the Bioregional Report and in the Central Lincs Local Plan (2023).

It is important to emphasise the Local Plan Vision by stating “The Vision implies that no energy systems will be based on fossil fuels.”

There is no need to state here (as it is in no other policy!) that “cost evidence is needed that this will not impact the viability of new developments.” Surely policy evidence should be more important in a Local Plan than cost evidence.

Comments noted. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 renewable energy generation or further clarifying ‘practically and viably possible’, 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 specified energy demand targets, or contributions towards off-site provision for renewables such as that used in other adopted local plans.
Disagree regarding the vision. One of the visions for the Local Plan is the need to become net zero. In moving towards net zero, there is, however, a transmission period during which fossil fuels must continue to play a role. Not certain where ‘cost evidence…..’ quotation is set out in the local plan.

Support

Representation ID: 6049

Received: 07/01/2024

Respondent: Mr David Lewis

I support the policy aim but would like to see stronger wording. The current wording of "as practically and viably possible" is not strong enough. Solar panels should be a requirement for all new homes and commercial buildings, providing more affordable heating and hot water for Rutland's residents and businesses.

Support noted. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 renewable energy generation or further clarifying ‘practically and viably possible’, 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 specified energy demand targets.
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. This approach, which must have some flexibility built in, is reflected in the wording of Policy CC4. 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 also in Local Plan Policy CC2 that seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 6285

Received: 07/01/2024

Respondent: Mr Chris Read

support

Support noted.

Object

Representation ID: 6591

Received: 08/01/2024

Respondent: Distinctive Developments Group Ltd

This policy, as drafted, is placing an extra burden and cost on housebuilders and developers to prove the energy efficiency of new homes, which is unnecessary when this is already covered by BRegs.

Comments noted. Disagree. The NPPF states that, in order to increase the use and supply of renewable and low carbon energy, plans should provide a positive strategy for energy from these sources. As a Local Plan has a limited influence on retrofitting existing buildings, in order to reach targets for carbon reductions, significant reductions in the energy requirements of new buildings are urgently needed and Policy CC4 seeks this aim. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum generation’, 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 energy demand targets for renewables such as that used in other adopted local plans.

Support

Representation ID: 6780

Received: 08/01/2024

Respondent: Wendy Dalton

New Housing - all new housing to meet Passiv accreditation and all new housing to be fitted with solar panels and storage batteries. This will reduce to reliance on overseas companies for energy security in Rutland. No carbon offsetting as an alternative.

Comments noted. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum generation’, 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 energy demand targets for renewables such as that used in other adopted local plans. 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. This approach, which must have some flexibility built in, is reflected in the wording of Policy CC4. 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 also in Local Plan Policy CC2 that seeks to maximise energy generation from on-site renewable sources.

Object

Representation ID: 7172

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

This policy is a duplication of Building Regulations and as such is not required and should be removed from the plan.

Climate change matters need to be led centrally thorough Building Regulations.

The incorporation of renewable energy on site needs to be realistic, for example, there are only so many roof spaces that photovoltaic panels can be installed and issues associated with wind turbines are well documented.
Furthermore, the preference for renewable energy to be provided on plot goes against heat networks which are being pushed forward as part of Building Regulations.

If this policy requires any additional requirements above Building Regulations, these additional costs need to be set out in the ‘Whole Plan Viability Report’ undertaken by HDH Planning and Development Limited.

Ministerial Statement dated 13th December 2023 on energy efficiency makes it clear that local plan policy should not go beyond Building Regulations which further supports the removal of this policy from the Local Plan.

Disagree that climate change should be led through the Building Regulations. The NPPF makes it very clear that plans should take a proactive approach to mitigating climate change and in order to increase the use and supply of renewable and low carbon energy, plans should provide a positive strategy for energy from these sources.
Disagree regarding wording of Policy CC4 not being realistic. It is a flexibly worded policy with ‘should’ and ‘practically and viably possible on-site’. The wording would also not preclude the use of heat networks.
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. As a Local Plan has a limited influence on retrofitting existing buildings, in order to reach targets for carbon reductions, significant reductions in the energy requirements of new buildings are urgently needed and Policy CC4 seeks this aim. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 renewable energy generation, 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 specify renewable energy use levels such as that used in other adopted local plans.
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 can exceed building regulations standards.

Object

Representation ID: 7224

Received: 07/01/2024

Respondent: Mr Harold Dermott

Excellent, but there is also no indication of what size of solar array would be “practically and viably possible on-site (and preferably on-plot)”.

Whilst I appreciate that this will depend on the
design efficiency of the dwelling, developers in Rutland have a long history of just installing a token number of PV panels, fewer that there is space for, and producing less energy than the building uses. Leaving size of solar PV unspecified in this plan would mean this is likely to continue.

There can be no downside to fitting the largest solar array possible on every roof, other that capital cost. If the objective is for Rutland to generate as much renewable energy as possible,
RCC cannot ignore the significant area of domestic and commercial roofing it will be authorising
to be built during the life of this plan.

With regard to the extra capital costs, there should be no automatic assumption that solar PV system will belong to the owner of the building.

Energy costs will only reduce either when the lower cost of renewables is allowed to be passed on to the consumer or by generating your own electricity, the technology to do this is available NOW and is already being used in Rutland.

Thus a high level of ‘standard’ array for each class of building is critically important for meeting Rutland’s Climate Change targets.

Comments noted. The size of a solar array would be justified and costed in the Energy Statement. It is suggested that RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy.

Object

Representation ID: 7250

Received: 08/01/2024

Respondent: Manton Parish Council

Residential development to incorporate renewable energy but must maintain character of the location. How do you address actual performance which falls short of design performance?

Comments noted. Agree that weight must be given, in terms of design, to the character of the location of the development and to other Local Plan policies such as EN12 and EN13, and other guidance such as the National Design Guide (2021) and Design Guidelines for Rutland SPD (2021). It is suggested that RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy.

Object

Representation ID: 7278

Received: 08/01/2024

Respondent: Manor Oak Homes

Agent: Mr Andy Moffat

The proposed approach which does not set out prescriptive standards is supported, but the requirement for maximum generation of renewable electricity as practically and viably possible on-site (and preferably on-plot) needs to be clarified. Will this require practicality and viability assessments for all major developments? Such a requirement would not be proportionate or justified.

Comments noted. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum generation’, 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 energy demand targets for renewables such as that used in other adopted local plans.

Object

Representation ID: 7315

Received: 08/01/2024

Respondent: Avant Homes

This policy is ambiguous and does not provide enough detail as to how it can be proven that that all residential proposals provide the maximum generation of renewable energy that is viable on site. This implies that developers will need to submit a scheme viability with every application, which is not considered achievable or realistic and will cause unnecessary delays during the application process. This policy should be deleted and simply dealt with via Building Regulations.

Comments noted. The NPPF makes it very clear that plans should take a proactive approach to mitigating climate change and in order to increase the use and supply of renewable and low carbon energy, plans should provide a positive strategy for energy from these sources. 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. As a Local Plan has a limited influence on retrofitting existing buildings, in order to reach targets for carbon reductions, significant reductions in the energy requirements of new buildings are urgently needed and Policy CC4 seeks this aim. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 renewable energy generation, 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 a renewable energy level such as that used in other adopted local plans.

Object

Representation ID: 7344

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Whilst the principle of on-site generation is broadly accepted, the policy must incorporate flexibility to
address site specific circumstances where there are opportunities for renewable generation adjacent/ very
close to a site. The Council must ensure there are full resources to enable site specific circumstances around energy provision to be properly assessed to pragmatically enable the most appropriate option to be considered and progressed.

The policy also sets out what ‘proposals supported by an Energy Statement should cover: Whilst the overall aspirations of the policy are understood and broadly accepted, the detail within the policy is not clear. There is currently no industry accepted definition of ‘net zero carbon’. This should therefore be explicitly set out within the policy or elsewhere within the emerging Local Plan, with details on methodology and expectations also clearly set out to ensure there is certainty around implementation.
Additionally, further clarification is needed on what is meant by ‘independently verified calculations’.

Furthermore the policy must ensure it is aligned with the Written Ministerial Statement made on 13
December 2023 entitled, ‘Planning – Local Energy Efficiency Standards Update’.

Disagree. It is a flexibly worded policy with ‘should’, ‘practically and viably possible on-site’ and ‘preferably on-plot. It is suggested that RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy.
Disagree regarding the alignment with 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 can exceed building regulations standards.

Object

Representation ID: 7503

Received: 08/01/2024

Respondent: Wing Parish Council

This should be worded more strongly to require that all new
developments must provide all their own energy needs and achieve the net zero carbon targets. The policy is simply not ambitious enough to address the objectives outlined at the start of the Plan.

Comments noted. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum generation’, 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 energy demand targets for renewables such as that used in other adopted local plans. In the absence of such feasibility evidence the policy cannot state that new development ‘must’ provide all their own energy needs.

Object

Representation ID: 7538

Received: 08/01/2024

Respondent: House Builders Federation

HBF would question what this policy is seeking to achieve and what it adds to Building Regulations. What will the Council do with the information of the ‘as built’ calculations when they receive it? What action could or would be taken once the homes have been completed? HBF note that Plan explains that consideration is being given to the viability of this approach and agree that energy efficiency requirements (and other policies) need to be subject to robust viability testing. However, this policy seems unnecessary and should be deleted.

Comments noted. Disagree. Comments noted. The NPPF makes it very clear that plans should take a proactive approach to mitigating climate change and in order to increase the use and supply of renewable and low carbon energy, plans should provide a positive strategy for energy from these sources. 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. As a Local Plan has a limited influence on retrofitting existing buildings, in order to reach targets for carbon reductions, significant reductions in the energy requirements of new buildings are urgently needed and Policy CC4 seeks this aim. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 renewable energy generation, 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 a renewable energy level such as that used in other adopted local plans. It is suggested that RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy.

Object

Representation ID: 7549

Received: 08/01/2024

Respondent: Mr Roderick Morgan

CC4
The presumption in favour of repair and reuse of a building is not strongly stated enough - currently it is 'easier' to demolish and rebuild than it should be, because this is how it has been for decades - even GDP is biased towards greater consumption and waste in development. There needs to be a very a very high bar based on serious feasibility challenges, not just a financial justification, however slight.

Comments noted. The importance of repair and re-use of buildings in reducing carbon emissions is more appropriately set out in Policies CC1 (Circular Economy), CC5 (Embodied carbon) and CC7 (Reducing energy consumption in existing buildings).

Object

Representation ID: 7668

Received: 08/01/2024

Respondent: South Luffenham Parish Council

Roof mounted PV is mentioned for any new development, what consideration or derogation was considered where development falls within conservation areas. Building Control/management can this be undertaken with existing resources?

Comments noted. Agree that weight must be given, in terms of design, to the character of the location of the development and to other Local Plan policies such as EN12 and EN13, and other guidance such as the National Design Guide (2021) and Design Guidelines for Rutland SPD (2021). It is suggested that RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy by developers and planning staff.

Support

Representation ID: 7730

Received: 08/01/2024

Respondent: Anglian Water

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 CC4 requirement on renewable energy generation and instead that we submit a summary of the renewable energy projects delivered across the Anglian Water estate in Rutland and the wider Anglian Water estate.

Comment noted. The policy is worded (‘should provide for’) flexibly so would take into account the scale and function of such small developments when the policy is applied.

Object

Representation ID: 7874

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC4 Net Zero Carbon (operational) – only Support subject to a change so that new proposals must [not should] provide Net Zero.

Surely this “Should” must be changed to “Must”?

Comment noted. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum generation’, 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 energy demand targets for renewables such as that used in other adopted local plans. In the absence of such feasibility evidence the policy cannot state that new development ‘must’ provide all their own energy needs.

Support

Representation ID: 8015

Received: 08/01/2024

Respondent: Mr PJRS Hill and Pikerace Limited

Agent: Silver Fox Developments

We support the objectives if this policy.

Support noted.