Regulation 18 draft Local Plan

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.

Object

Representation ID: 5027

Received: 02/01/2024

Respondent: Pigeon Investment Management

It is noted that the Planned Limits of Development (PLD) associated with Oakham has been extended so that the majority of the site which benefits from planning permission reference 2022/0336/MAO is now included within the PLD. However, a portion of the north westernmost part of the site is excluded. It is considered that the PLD should be amended to ensure it accurately reflects the application site associated with the above-mentioned permission.

The PLD will be amended to reflect the full extent of the site with planning permission in this location.

Object

Representation ID: 5029

Received: 02/01/2024

Respondent: Pigeon Investment Management

Any increase in the requirement over and above 10% will inevitably have an impact on the amount of developable land available to meet the County’s development needs. With regard to housing development, it is noted that a key element of national planning policy remains the Government’s objective of significantly boosting the supply of homes (National Planning Policy Framework (NPPF), December 2023, paragraph 60). Any requirement for in excess of 10% BNG will reduce the County’s ability respond to this requirement of national policy.

Comment noted. Change from 15% to 10% as a higher percentage than the statutory objective of biodiversity net gain needs to be evidenced. In order for the Local Plan to be deemed sound this uplift above the mandatory level must be robustly evidenced.