Support

Representation ID: 4636

Received: 05/12/2023

Respondent: Whissendine Parish Council

Whissendine subject to fluvial flooding. Discharge to watercourses should be last resort and in any event at a rate of no more than 1.7 L per second.

Comment noted. This is a matter for inclusion in a Flood Risk Assessment under Policy CC14 (which is cross referenced to in Policy CC6).

Object

Representation ID: 4735

Received: 12/12/2023

Respondent: Miss Serena Solanki

Rutland county is within a water stressed area as per the Sustainability Appraisal report conducted by Aecom. The level of development proposed will add further stress to the local water supply. Anglian Water which services the area has no plans to increase the capacity of the infrastructure in Wing or Tinwell. Wing is deemed outside the statutory service are by Anglian Water. Milton Keynes, Bedfordshire and Northamptonshire are the fastest growing areas within the Ruthamford Water Resource Zone, therefore leaving Rutland to become further water stressed. I don't think that RCC has considered this in their plan

Comment noted. Disagree. Policy CC6 seeks to reduce carbon emissions through reducing the supply and disposal of water for new dwellings and other buildings. It notes that, as Rutland is a water stressed area, then the Local Plan should include policies requiring higher water efficiency target of 110 litres per person per day to reduce water consumption. The Spatial Strategy policies, amongst other things, seek to deliver sustainable development and meeting housing and employment needs on the basis of supporting evidence, including the Draft Water Cycle Strategy (2023). This considers the impact of the plan on water usage and looks at future investment by the water supply companies.

Support

Representation ID: 4755

Received: 13/12/2023

Respondent: Mr Andrew Lunn

Fully support, we need to manage our water needs going forward. Why not consider underground grey water tanks on all new estates that households can use for water the garden, cleaning vehicles etc.. This would be cheaper to do during a build rather than retrofit.

Support noted. The Adopted Central Lincs Local Plan (2023) considers storing rainwater for wider household uses but concludes that this may not be the most sustainable option due to the on-site treatment (for toilet flushing) and storage requirements, and may actually have a higher carbon footprint than the use of mains water. This adopted Plan remains neutral on this point and does not, therefore, promote or require such measures. This also seems an appropriate position for the Rutland Reg 18 plan at this stage.

Object

Representation ID: 4984

Received: 02/01/2024

Respondent: Define (on behalf of William Davis Homes)

The requirements of Policy CC6 are particularly specific in some regards, for example in requiring outside hard surfacing to be permeable unless there are technical and unavoidable reasons for not doing so in certain areas, and in requiring all flat roofs to be green roofs unless they are being used for photovoltaic or thermal solar panels.

It is suggested that the wording within this policy is softened somewhat to encourage the use of such measures where technically feasible, appropriate to the local context, and viable.

Comments noted. Para 158 of the NPPF 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,…..water supply….' The Water Management criteria in CC6 are justified as they meet these requirements set out in the NPPF with flexibility built into the wording of first bullet point ‘(unless there are technical or unavoidable reasons for not doing so in certain areas)’ and is in the interests of sustainable water management. Agree the second bullet point on drought resistant planting schemes is perhaps too prescriptive and may conflict with policies in the Local Plan that seek to ensure enhancements for biodiversity through landscaping (eg Policies EN3, EN4 and EN7). Agree third bullet point is too prescriptive and should be more flexible. Disagree fourth bullet point too prescriptive as even such small measures can reduce demands on water supply, and thereby carbon emissions, in new residential development.

Support

Representation ID: 5039

Received: 02/01/2024

Respondent: Julie Gray

I support this policy

Support noted.

Support

Representation ID: 5068

Received: 02/01/2024

Respondent: Mary Cade

With respect to 'soft landscaping' - drought tolerant planting schemes should be of locally sourced (ref CC1), native plants (ref EN3) and a maintenance schedule should be included.
With reference to 'green roofs' - they have minimum biodiversity value, and rain gardens and swales are seen to be more effective in terms of the water network, also they require regular maintenance (watering, weeding, gutter clearing etc) to be effective. PV panels or solar thermal would be better on flat roofs.

Agree adding ‘native’ before ‘drought resistant’ in second bullet point and reference to Policy EN3 and EN7.
Partly agree on third bullet point. The incorporation of rain gardens and/or swales may not be appropriate or feasible in small schemes. Reworded to ‘should consider the potential to incorporate a green roof and/or walls’. Agree emphasis should be given to solar panels by adding in reference to Policy CC2 (that seeks to maximise on-site renewable energy).

Object

Representation ID: 5091

Received: 03/01/2024

Respondent: Natural England

Natural England advises that this policy should also reference protecting water quality and suggest that the CIRIA SuDS Manual could be referenced.

Comment noted. The CIRIA SuDS Manual is referenced under Policy CC14 (Flood Risk).

Object

Representation ID: 5410

Received: 04/01/2024

Respondent: North Luffenham Parish Council

The Flat Roof element of this policy seems very draconian. How will this be implemented in Conservation Areas?

Agree could be better worded. Also as green roofs require a slight pitch to ensure proper drainage and green walls can be incorporated delete ‘with any flat-roofed area’ from third bullet point and include and/or green walls.

Support

Representation ID: 5471

Received: 05/01/2024

Respondent: Ms Janet Taylor

With exception for green flat roof requirement where any advantages are outweighed by maintenance issues.
Slow release water butts should be encouraged; much easier to install than soakaway systems and pilot schemes have demonstrated their efficacy.

Support noted. The green roof bullet point is worded flexibly with reference to utilising the roof for solar panels in accordance with Policy CC2.

Object

Representation ID: 5511

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

Reference to "outside hard surfacing" is too vague. Public Highway cannot, from experience, be adopted if it is not impermeable. Does this cover driveways - these can be permeable if the drainage and ground conditions allow, but what about patio areas? Also, drought tolerant plants might not be best for bio-diversity or suitable. Planting in private gardens is not controlled by planning (and can be readily changed by residents) so this wording is not justified or enforceable.

Agree ‘outside hard surfacing’ requires further definition to exclude public highway.
Partly disagree on second bullet point as planting in private gardens, such as hedging or tree planting. is sometimes part of a landscaping scheme that would be controlled through condition for implementation and maintenance. Agree drought resistant plants may not be best for biodiversity. so reword to: ‘with outside soft landscaping, should consider the incorporation of native drought resistant plants in private gardens, communal areas, and any proposed public green spaces whilst recognising the importance of enhancing biodiversity in accordance with Policies EN3 and EN7;’

Support

Representation ID: 5564

Received: 05/01/2024

Respondent: Mrs laura alcock

Agree with policy. Also should consider grey water solutions for new builds.

Support noted. The Adopted Central Lincs Local Plan considers storing rainwater for wider household uses but concludes that this may not be the most sustainable option due to the on-site treatment (for toilet flushing) and storage requirements, and may actually have a higher carbon footprint than the use of mains water. This adopted Plan remains neutral on this point and does not, therefore, promote or require such measures. This also seems an appropriate position for the Reg 18 plan at this stage.

Support

Representation ID: 5843

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Remove “private gardens” as planning cannot determine what people do in their private gardens.

Green roofs should not be encouraged. They are of little value for biodiversity, as well as a maintenance and H&S liability. Alternatives include swales, rain gardens or ponds, all of which offer excellent biodiversity opportunities and slow down storm water.

Drought tolerant planting schemes should use native plants where possible, and plant in late autumn to give maximum time for roots to develop.

Add “Where possible, water storage could be alternatively installed under a hard standing drive or garden for garden watering and car washing.”

Comments noted. Disagree regarding private gardens in second bullet point as planting in private gardens, such as hedging or tree planting, is sometimes part of a landscaping scheme that would be controlled through condition for implementation and maintenance. Partly agree on third bullet point. The incorporation of rain gardens and/or swales may not be appropriate or feasible in small schemes. Reworded to ‘should consider the potential to incorporate a green roof and/or walls’ and emphasis should be given to solar panels by adding in reference to Policy CC2 (that seeks to maximise on-site renewable energy).
Agree drought resistant plants may not be best for biodiversity so reword to: ‘with outside soft landscaping, should consider the incorporation of native drought resistant plants in private gardens, communal areas, and any proposed public green spaces whilst recognising the importance of enhancing biodiversity in accordance with Policies EN3 and EN7;’
Disagree regarding use of water storage. The Adopted Central Lincs Local Plan considers storing rainwater for wider household uses but concludes that this may not be the most sustainable option due to the on-site treatment (for toilet flushing) and storage requirements, and may actually have a higher carbon footprint than the use of mains water. This adopted Plan remains neutral on this point and does not, therefore, promote or require such measures. This also seems an appropriate position for the Reg 18 plan at this stage.

Support

Representation ID: 6291

Received: 07/01/2024

Respondent: Mr Chris Read

Again, there is no "don't know".
The first point seems sound.
The last three seem pointless - focus on something more important - how would they be monitored in the long-term? What if I want to replant my garden? What if the roof won't support moss or grass?

Comments noted. The last three bullet points are worded flexibly and each can contribute, albeit often in a small way individually, towards reducing carbon emissions and in adapting to climate change. Landscaping conditions would set out the implementation and maintenance of planting schemes, and the policy acknowledges that green roofs and/or walls are only appropriate (reworded to ‘should consider the potential’) in certain developments.

Support

Representation ID: 6482

Received: 08/01/2024

Respondent: Ms Jo Carr

It may make sense to remove the reference to drought tolerant plants “in private gardens”. How would this even be policed?

Comment noted. Planting in private gardens, such as hedging or tree planting. is sometimes part of a landscaping scheme that would be controlled through condition for implementation and maintenance. The requirements of a planning condition would be enforceable.

Object

Representation ID: 6537

Received: 08/01/2024

Respondent: Mrs Susan Shepherd

To optimise water efficiency the policy should include reference to the management and prevention of water leaks.

Comment noted but this would be the responsibility of the Water Companies rather than through a policy in the Local Plan.

Support

Representation ID: 7003

Received: 08/01/2024

Respondent: Environment Agency

Rutland County council is in a serious water stressed area as outlined in the 2021 classification https://www.gov.uk/government/publications/water-stressed-areas-2021- classification.
This could be made worse by growth and climate change effects. To mitigate this, water resources need to be more efficiently used in new homes and businesses.
We therefore support this policy. We support the requirement for the higher water efficiency standard of 110 litres per day per person in residential development.
We particularly welcome the encouragement to go further to 85 litres per day per person.

Support noted.

Object

Representation ID: 7174

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes support the requirement for Optional Technical Housing Standard of 110 litres per day per person for water efficiency with the encouragement to reduce this to 85 litres per day.

With regards to Water Management, and bullet point 1 relating to permeable paving, Persimmon Homes make the following comments:

- Further clarity is required on what areas are included within the definition of ‘outside hard surfacing areas’, for example, does it include adoptable roads, private drives, as well as all on plot hard surfaced areas. It is important to note that many Highway Authorities do not adopt permeable paving.

- There is also an extra cost in providing permeable paving of approximately £50 extra a square metres and this has not been factored into the ‘Whole Plan Viability Report’ undertaken by HDH Planning and Development Limited.

Support noted. Agree regarding further clarification required regarding definition of ‘outside hard surfacing’ given that many Highway Authorities doe not adopt permeable paving.
Comment noted additional regarding cost of providing permeable paving. Agree this should be the subject of further viability work which 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.

Object

Representation ID: 7193

Received: 08/01/2024

Respondent: Allison Homes

AH suggests more flexibility is added to the water management requirements to have regard to site specific technical constraints, viability and local context.

Comment noted. Partly agree. Para 158 of the NPPF 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,…..water supply….' The Water Management criteria in CC6 are largely justified as they meet these requirements set out in the NPPF with flexibility built into the wording of first bullet point ‘(unless there are technical or unavoidable reasons for not doing so in certain areas)’ and is in the interests of sustainable water management. Agree the second bullet point on drought resistant planting schemes is perhaps too prescriptive and may conflict with policies in the Local Plan that seek to ensure enhancements for biodiversity through landscaping (eg Policies EN3 and EN7). Agree third bullet point is too prescriptive and should be more flexible. Disagree fourth bullet point too prescriptive as even such small measures can reduce demands on water supply, and thereby carbon emissions, in new residential development.

Object

Representation ID: 7251

Received: 08/01/2024

Respondent: Manton Parish Council

Residential and commercial development should address efficient water management. A policy on identifying and addressing water leaks should be included.

Comments noted. Agree regarding commercial development. There is currently no standard in water efficiency in non-residential development and, without such a standard, this would not help to mitigate the problem of Rutland being classified as being in a serious water stressed area. Agree there should be a limit for non-residential development by encouraging new developments to achieve full credits for category Wat 01 of BREEAM unless demonstrated impracticable. (similar to approach in Greater Cambridge Local Plan). This is also highlighted in the Rutland Draft Water Cycle Study (2023) that states that: ‘Non-domestic consumption can also be reduced by encouraging new developments to be built to ‘Very Good’ or ‘Excellent’ BREEAM standards.’

Addressing water leaks is the responsibility of the Water Companies rather than through a policy in the Local Plan.

Support

Representation ID: 7282

Received: 08/01/2024

Respondent: Manor Oak Homes

Agent: Mr Andy Moffat

The expectation that all new dwellings should achieve the Optional Technical Housing Standard of 110 litres per day per person for water efficiency as described by Building Regulation G2 is supported.

Support noted.

Object

Representation ID: 7316

Received: 08/01/2024

Respondent: Avant Homes

The Council should not be seeking to establish policies which go above and beyond the national policy position. This can cause unnecessary delays when this matter is already dealt with via Building Regulations. This policy should be deleted.

Comment noted. Disagree. Para 158 of the NPPF 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,…..water supply…. The Water Management criteria are justified as they meet these requirements set out in the NPPF, particularly given that Rutland is in a serious water stressed area (as defined in the 2021 classification by the Government), with flexibility (subject to a number of proposed changes) built into the policy.

Support

Representation ID: 7346

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The approach to reducing water consumption is broadly supported and the policy appears to align with
Building Regulations.

Support noted.

Object

Representation ID: 7540

Received: 08/01/2024

Respondent: House Builders Federation

HBF note that the current Part G Building Regulations requires developments to compliance with a limit of 125 litres per day. House builders are frequently delivering
115-110 litres per day which means the house building industry is already improving upon the regulations. HBF would caution against policies that seek to go further and
faster than national policy changes that result in patchwork of differing local standards. Because. There is therefore no need for a policy on this matter in a Local Plan.

Disagree. Para 158 of the NPPF 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,…..water supply…. The Optional Technical Standards for housing allows local authorities to apply a more stringent standard of 110 litres per person per day where there is a clear local need. Rutland is identified as being within a serious water stressed area and so this optional standard is required in the Local Plan.

Support

Representation ID: 7640

Received: 08/01/2024

Respondent: Severn Trent

Severn Trent is supportive of Policy CC6 in particular the reference to managing surface water flood risk.
We are supportive of the use of water efficient design of new developments fittings and appliances and encourage the optional higher water efficiency target of 110 litres per person per day within part G of building regulations. Delivering against the optional higher target or better provides wider benefits to the water cycle and environment as a whole. This approach is not only the most sustainable but the most appropriate direction to deliver water efficiency. We would therefore recommend that the following wording is included for the optional higher water efficiency standard:

New developments should demonstrate that they are water efficient, incorporating water efficiency and re-use measures and that the estimated consumption of wholesome water per dwelling is calculated in accordance with the methodology in the water efficiency calculator, not exceeding 110 litres/person/day.
We recommend that all new developments consider:
• Single flush siphon toilet cistern and those with a flush volume of 4 litres.
• Showers designed to operate efficiently and with a maximum flow rate of 8 litres per minute.
• Hand wash basin taps with low flow rates of 4 litres per minute or less.
• Water butts for external use in properties with gardens.

Comments noted. Agree to strengthen the policy to require developers to show what measures they have taken to improve water efficiency.

Object

Representation ID: 7670

Received: 08/01/2024

Respondent: South Luffenham Parish Council

Plan concentrates on efficiencies and management but does not address the failings of a Victorian water infrastructure that gives rise to leaks and wastage and reduced water pressure. South Luffenham has only recently (summer 2023) been upgraded to MDPE to replace the life expired asbestos pipework. As the water authority is a private body there appears little joined up approach to overhauling the water infrastructure.

Comments noted. Policy CC6 establishes a series of principles for sustainable water management. Requirements for infrastructure relating to waste water disposal and treatment is considered under Policy INF1 and addressing leaks is the responsibility of the Water Companies rather than through a policy in the Local Plan.

Object

Representation ID: 7732

Received: 08/01/2024

Respondent: Anglian Water

20 Anglian Water with the Environment Agency, Natural England and Cambridge Water are now moving from 110 litres to 100 litres as the water efficiency standard for new homes. We therefore ask that policy CC6 is updated to reflect this and the government position in the 2023 Environmental Improvement Plan. Anglian Water supports the Water Management bullet points in CC6. One question is whether the carbon, water and climate benefits of green roofs is always positive. Work with other Councils suggests that the engineering and design of roof structures means that some buildings and especially those with small roofs provide minimal benefits which could be more sustainably provided through ground level solutions including BNG. Anglian Water would want to work with the Council to support the Evidence Base which shows the thresholds when green roofs do and do not deliver the most environmental gains and so avoid costs in our and others capital schemes which could have been utilised to deliver more effective carbon outcomes and biodiversity gains.

Comments noted. The request to move from 110 litres per day to 100 litres is noted. The Optional Technical Standard for housing allows councils to set a more stringent standard of 110 litres per day, as compared to the Building Regulations requirement of 125 litres per day, where there is a clear local need (as is the case in Rutland which is classified as being in a serious water stressed area). The 110 litres per day set out in CC6 is considered justified on this basis, recommended in the Rutland Water Cycle Study (2023) (part of the evidence base for the Local Plan). The policy also seeks to go further in terms of water usage by supporting ambitious proposals for down to 85 litres per day.
Comments regarding the efficiency of green roofs is noted. It is acknowledged that green roofs and/or walls are often not feasible in developments and this is reflected in the wording of the policy. Further evidence work on the carbon and biodiversity benefits of such structures, and viability testing may be appropriate in the future to inform the next stages of the Local Plan.

Object

Representation ID: 7742

Received: 08/01/2024

Respondent: Anglian Water

With reference to water use standards, as the Local Plan will inform future development to 2041, we would support a more ambitious approach similar to that proposed by the emerging Greater Cambridge Local Plan which has proposed 80 l/p/d in recognition of future water supply issues as a result of abstraction reductions to protect the environment. The policy tests would need to be robust to require monitoring of the proposed efficiency standard and remediation where the level of usage is exceeded. Policies should also require integrated water management solutions including rainwater/storm water harvesting and greywater recycling for non-potable uses – such schemes should be mandatory in larger developments that can provide economies of scale to achieve robust water efficiency standards. Anglian Water is working to prepare a Joint Protocol and supporting evidence with Natural England and the Environment Agency to underpin more ambitious water efficiency standards. See attachment

Comments noted.
There is not sufficient evidence to support this approach at this time, although it is recognised that AWS and NE are preparing evidence and a protocol at the moment.
Higher standards will impinge on viability and deliverability of the plans policies and proposals.

Object

Representation ID: 7773

Received: 08/01/2024

Respondent: McCarthy Stone

Agent: The Planning Bureau Limited

We note that point 3 of policy CC6 seeks ‘with any flat-roofed area, should be a green roof (for biodiversity, flood risk and water network benefits), unless such roof space is being utilised for photovoltaic or thermal solar panels’.

As such 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 requirement for a flat roof to include a green roof 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 flat roofs to be built as a green roof and this should be reconsidered, and a cost should be accounted for within any Viability Assessment.

Comments noted regarding cost of providing green roofs. Agree this should be the subject of further viability work which 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. It is proposed to reword the third bullet point to make it less prescriptive.

Object

Representation ID: 7785

Received: 08/01/2024

Respondent: Edith Weston Parish Council

We support policies that reduce carbon use, water efficiency and micro energy generation. However, We note that the policy refers to specific building regulations. We would suggest removing these references, as change to the building regulations in question will date the policies. Reference to the relevant building regulations could instead be made in supporting text.

Comments noted. The Optional Technical Standard for housing allows councils to set a more stringent standard of 110 litres per day, as compared to the Building Regulations requirement of 125 litres per day, where there is a clear local need (as is the case in Rutland which is classified as being in a serious water stressed area). The 110 litres per day set out in CC6 is considered justified on this basis and the policy also seeks to go further in terms of water usage by supporting proposals for down to 85 litres per day. The policy already aims, therefore, to go lower than the current Building Regulations requirements. A similarly worded policy is included in the adopted Central Lincs Local Plan (2023).

Object

Representation ID: 7823

Received: 07/01/2024

Respondent: CPRE Rutland

Is this just for new residential buildings or should it apply equally to commercial developments? It should
also address waste water disposal.

Comments noted. Agree. There is currently no standard in water efficiency in non-residential development and, without such a standard, this would not help to mitigate the problem of Rutland being classified as being in a serious water stressed area. Agree there should be a limit for non-residential development by encouraging new developments to achieve full credits for category Wat 01 of BREEAM unless demonstrated impracticable. (similar to approach in Greater Cambridge Local Plan). This is also highlighted in the Rutland Draft Water Cycle Study (2023) that states that: ‘Non-domestic consumption can also be reduced by encouraging new developments to be built to ‘Very Good’ or ‘Excellent’ BREEAM standards.’
Infrastructure relating to waste water disposal and treatment is considered under Policy INF1.