Support

Representation ID: 4624

Received: 04/12/2023

Respondent: Forestry Commision

We do note your Policy CC5 regarding embodied carbon and the choice, use and sourcing of materials and consider that you may wish to consider mentioning the benefits of using locally grown timber in construction.

The 25 Year Environment Plan aims to support ‘Grown in Britain’ to increase the amount of home grown timber used in England in construction, creating a conveyor belt of locked-in carbon in homes and buildings”.

The use of timber in construction to replace concrete, steel and brick can be a major contributor to creating a truly green economy, currently the UK imports around 80% of the wood it consumes annually, we are the second biggest timber importer in the world. Using home grown timber would be of benefit in reducing the carbon cost of buildings in terms of materials, construction and transport etc.

Increasing levels of woodland management by increasing demand for locally grown timber can help improve the habitat condition of neglected woodlands, and also allow owners to address tree disease problems and increase resilience to climate change.

Agree. To make reductions in embodied carbon fewer materials need to be used more efficiently and the carbon content of the construction materials that are used needs to be reduced. Increasing the use of low-carbon materials, such as home grown timber, is important and the 25 year Environment Plan aims to support ‘Grown in Britain’ by increasing the amount of home grown timber used in England in construction, creating a ‘conveyor belt of locked-in carbon in homes and buildings.’

Support

Representation ID: 4754

Received: 13/12/2023

Respondent: Mr Andrew Lunn

Support, cost should not be the justification of demolition, they need to show that this is the best and greenest way forward. Even if cost is higher keeping present structures must be the way forward where at all possible.

Support noted. It is important that the policy does not completely prohibit demolition as there may be circumstances where it is unviable to reuse the building, or where a new building would offer a lower carbon solution or there would be public benefits that would outweigh any carbon savings. This argument would be set out in justification for the building’s demolition.

Support

Representation ID: 5038

Received: 02/01/2024

Respondent: Julie Gray

I fully support this policy and look forward to seeing it in action as there have been NO attempts to reuse the buildings on the officers mess and No justification given as reasons not to.

Support noted. The Officers’ Mess application at Edith Weston was assessed against the policies of Adopted Local Plan which has no policies to equivalent to CC5 with its presumption in favour of repurposing existing buildings over their demolition.

Support

Representation ID: 5067

Received: 02/01/2024

Respondent: Mary Cade

The 'practical and viable' wording should be removed from this policy.
Locally grown timber and locally quarried stone will both have lower embodied Carbon, and stone has the advantage that it can be reused again and again (ref CC1). www.leti.uk (a Community Interest Company) provides expert advice on embodied Carbon.
Proposals for demolition should be in line with policy CC1.

Support noted. Disagree to remove ‘practical and viable’ as it is important that the policy is flexible and does not completely prohibit demolition as there may be circumstances where it is unviable to reuse the building, or where a new building would offer a lower carbon solution or there would be public benefits that would outweigh any carbon savings. This argument would be set out in justification for the building’s demolition. The Design Guidelines for Rutland SPD 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. Agree reference to the SPD, LETI and Policy CC1 in the text accompanying Policy CC5 would be appropriate.

Object

Representation ID: 5409

Received: 04/01/2024

Respondent: North Luffenham Parish Council

Para 1. How will Planning Officers Assess, Interpret and enforce this?

Comment noted. RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Justification Statements to help with the interpretation of the policy, similar to that available to support the policies in the adopted Central Lincolnshire Local Plan.

Object

Representation ID: 5525

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

The policy could go further in proving specific and positive guidance in respect of the way that under-utilised, or unused heritage assets could be re-purposed. This is especially important, as these buildings have both a heritage importance, but also themselves embody significant carbon in their structures.

Comments noted. National guidance/Local Plan policy covers this. Para 124 of the NPPF states that planning policies should…promote and support the development of under-utilised land and buildings. Strategic Objective 9 and Policy EN12 of the Local Plan seek to encourage the re-use and refurbishment of existing buildings (including heritage assets) in accordance with the national planning policy guidance.

Support

Representation ID: 5842

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

As it is a new concept for many developers and homeowners it would be best to include some examples of how the wastage of embodied carbon can be reduced. The phrase “where practical and viable” is unnecessary as the phrase “take opportunities to reduce” is also included.
Examples could include:
• Preference for lime mortar or cement-lime mortars, rather than cement mortars to conserve bricks and stone and enable reuse for construction.
• Preference for hedges as green infrastructure rather than wooden fences or stone walls.
• Timber framing of the whole building structure rather than steel or concrete blockwork
The justification for demolition should be required in the Energy Statement.

Targets should aim for a 40% reduction in embodied carbon or to 500kgCO2/m2 for housing; 600kgCO2/m2 for commercial buildings and schools.

Disagree to remove ‘practical and viable’ as it is important that the policy is flexible and does not completely prohibit demolition as there may be circumstances where it is unviable to reuse the building, or where a new building would offer a lower carbon solution or there would be public benefits that would outweigh any carbon savings. This argument would be set out in justification for the building’s demolition. The Design Guidelines for Rutland SPD 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.
Agree reference to the SPD, LETI in the text accompanying Policy CC5 would be appropriate.
Disagree about setting carbon reduction targets because, in order to specify such figures, there must be a robust evidence base in terms of viability. It is intended that further work to update the cost evidence for a number of options for the wording of CC5 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.
Action: Add in “the Design Guidelines for Rutland SPD (2021) and the LETI Climate Emergency Design Guide (2020) both provide further guidance, including examples, on reducing embodied carbon. “ after first sentence on page 33 ending in ‘carbon impact of new development.’

Support

Representation ID: 6047

Received: 07/01/2024

Respondent: Mr Roderick Morgan

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.

Support noted. It is important that the policy does not completely prohibit demolition as there may be circumstances where it is unviable to reuse the building, or where a new building would offer a lower carbon solution or there would be public benefits that would outweigh any carbon savings. This argument would be set out in justification for the building’s demolition.

Support

Representation ID: 6286

Received: 07/01/2024

Respondent: Mr Chris Read

I think I support this - but I don't really know enough about it - there's no "don't know" button.

Support noted. Reference to the Design Guidelines for Rutland SPD and the LETI Climate Emergency Design Guide (as recommended as an Action) in the supporting text to the policy should help in the interpretation of the policy.

Object

Representation ID: 6557

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

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

Emerging Policy CC5 currently requires proposals to provide a “full justification for the demolition” of a building but does not provide guidance on what the Council expects applicants to submit. It would be useful for the Council to outline the minimum level of information expected in this Policy and/or indicate whether an SPD would be prepared on this issue and adopted in line with the Plan to support this matter.

Comments noted. RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Justification Statements to help with the interpretation of the policy, similar to that available to support the policies in the adopted Central Lincolnshire Local Plan.

Object

Representation ID: 7173

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Whilst the re-consultation on the Future Homes Standard does not include embodied carbon the government has set out in this consultation that it intends to consult in due course on its approach to measuring and reducing embodied carbon in new buildings.

Persimmon Homes are of the view that policies should come through national standards set through Building Regulations and as such Persimmon Homes are of the view that this policy is not justified and should be removed from the plan.

Comments noted. There is a statutory requirement for development plans to include policies designed to ensure that the development and use of land contributes to climate change mitigation and adaption.
Whilst the NPPF does not contain a similar policy on embodied carbon, para 124 does states that planning policies should…promote and support the development of under-utilised land and buildings. The policy is needed in the Local Plan because of embodied carbon making up between 67% and 76% of the building’s total carbon emissions and that this must be addressed in order to respond to the Climate Emergency. Disagree that embodied carbon should be addressed through future changes to the Building Regulations. Currently, no part of the Building Regulations addresses embodied carbon and so there is also no regulatory incentive for new development to reduce its embodied carbon. There is no guarantee that this will be legislated for in the future. A similar policy approach has been taken in the adopted Central Lincolnshire Local Plan (2023).

Support

Representation ID: 7225

Received: 07/01/2024

Respondent: Mr Harold Dermott

Whilst the carbon costs of operating the building are addressed elsewhere in this Chapter, ignoring the embedded carbon is to ignore the major part of the problem.

It will, however, require major changes to the way buildings are constructed in the UK, with more precision control of construction, quite possibly by large sections of buildings being factory built where processes to control quality and specification are easy to achieve, rather than using
historic materials with high embodied carbon content built on site in highly variable weather conditions and using construction techniques which do not always result in consistently high quality products.

Support and comments noted.

Support

Representation ID: 7281

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.

Object

Representation ID: 7345

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

This policy is not clear how ‘favouring’ a building would be assessed or what this might mean in practice. Additionally, the policy does not acknowledge that repairing, refurbishing, re-using and re-purposing a building will not always result in less carbon use. It would be helpful if the policy could explain a methodology to assess the total embodied carbon consumption to consider whether this approach would actually use less carbon.

Comments noted. The policy does not completely prohibit demolition as there may be circumstances where it is unviable to reuse the building, or where a new building would offer a lower carbon solution or there would be public benefits that would outweigh any carbon savings. This argument would be set out in justification for the building’s demolition. The Design Guidelines for Rutland SPD 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. RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Justification Statements to help with the interpretation of the policy, similar to that available to support the policies in the adopted Central Lincolnshire Local Plan.

Object

Representation ID: 7539

Received: 08/01/2024

Respondent: House Builders Federation

HBF are unclear how a developer would show compliance with this policy, and whether the Council has the skills and expertise to undertake or critique embodied carbon assessments, especially as be qualified to make judgements on accepting or rejecting carbon assessments as the baseline and measures therein have not been established. HBF therefore view this policy as unnecessary, and it should be deleted.

Comments noted. RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Justification Statements to help with the interpretation of the policy, similar to that available to support the policies in the adopted Central Lincolnshire Local Plan. Disagree to the policy’s deletion. There is a statutory requirement for development plans to include policies designed to ensure that the development and use of land contributes to climate change mitigation and adaption. Whilst the NPPF does not contain a similar policy on embodied carbon, para 124 does states that planning policies should…promote and support the development of under-utilised land and buildings. The policy is needed in the Local Plan because of embodied carbon making up between 67% and 76% of the building’s total carbon emissions and that this must be addressed in order to respond to the Climate Emergency. Currently, no part of the Building Regulations addresses embodied carbon and so there is no regulatory incentive for new development to reduce its embodied carbon. There is also no guarantee that this will be legislated for in the future. A similar policy approach has been taken in the adopted Central Lincolnshire Local Plan (2023).

Object

Representation ID: 7669

Received: 08/01/2024

Respondent: South Luffenham Parish Council

More prevalent to a barn conversion, where the existing structure is retained.

Comment noted. The policy, as well as seeking to reduce wastage of embodied carbon as a result of demolition, also seeks to decarbonise the construction of new buildings by reducing the carbon content of the construction materials that are used.

Support

Representation ID: 7731

Received: 08/01/2024

Respondent: Anglian Water

Anglian Water welcomes the policy CC5 on Embodied Carbon. We suggest that the first part of the policy should be in utilising embodied (capital) carbon in existing infrastructure to select the most sustainable locations for and quantum of growth. This may be best placed in the Spatial Strategy policies and should be referenced in the supporting text for CC5. As operational carbon is reduced through decarbonisation of the grid and transport electrification the embodied carbon in new construction and that saved by using existing infrastructure will be increasingly important on the path to net zero. Anglian Water is able to provide tCO2e figures for each of the spatial options which the Council wants to consider.

Support noted. Agree inherent in contributing towards reducing a development’s embodied carbon is its location in terms of utilising existing infrastructure and thereby the delivery of sustainable development, one of the key Strategic Objectives in the Local Plan. The Spatial Strategy policies in the Local Plan seek to meet this Strategic Objective.

Object

Representation ID: 7772

Received: 08/01/2024

Respondent: McCarthy Stone

Agent: The Planning Bureau Limited

We would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). The introduction of an embodied carbon policy must not be so inflexible that it deems sites unviable and any future policy needs to ensure this to make sure it is consistent with NPPF/PPG and can be justified by the Council.
We note that the Rutland County Council Whole Plan Viability Assessment, August 2023, HDH (Viability Assessment) does not appear to include a cost for the embodied carbon policy. This is concerning as embodied carbon will have a cost that should be accounted for within any Viability Assessment.

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

Recommendation:
Ensure the policy is properly assessed within the Viability Assessment and that the requirement is realistic with data and evidence readily available to the development industry.

Comments noted. The policy does not completely prohibit demolition as there may be circumstances where it is unviable to reuse the building, or where a new building would offer a lower carbon solution or there would be public benefits that would outweigh any carbon savings. This argument would be set out in justification for the building’s demolition. It is intended that further work to update the cost evidence for a number of options for the wording of CC5 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Support

Representation ID: 7786

Received: 08/01/2024

Respondent: Edith Weston Parish Council

We support policies that reduce carbon use, water efficiency and micro energy generation.

Support noted.

Support

Representation ID: 7822

Received: 07/01/2024

Respondent: CPRE Rutland

This is an important and welcome inclusion.

Support noted.

Support

Representation ID: 7875

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC5 Embodied Carbon - Support

Support noted.

Support

Representation ID: 8016

Received: 08/01/2024

Respondent: Mr PJRS Hill and Pikerace Limited

Agent: Silver Fox Developments

We support the objectives if this policy.

Support noted.