Regulation 18 draft Local Plan

Object

Representation ID: 5406

Received: 04/01/2024

Respondent: North Luffenham Parish Council

Whilst supportive of the aims of the policy, we cannot see how this will be interpreted, e,g if the approach to Site Waste is listed as not complying with the 5R's will this lead to the application being refused?

Support for the aims of the policy noted. Policy CC1 is supportive of proposals that demonstrate the meeting of circular economy principles. In assessing applications for planning permission, these must be determined in accordance with the development plan, unless material considerations indicate otherwise.

Object

Representation ID: 5408

Received: 04/01/2024

Respondent: North Luffenham Parish Council

"Highest Possible Standards" would mean that all development has to be to to Passivhaus standards : https://bregroup.com/a-z/the-passivhaus-standard/
If an application complies with latest Building Regulations with regard to materials used, insulation values etc, this is not the "Highest Possible Standard" and so would fail this Policy? Policy will therefore be ineffective in application

LPAs must 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 adaption to, climate change’ and Policy CC2 contributes towards this. The Future Homes and Buildings Standards (which aims to improve the energy efficiency and carbon emissions of new homes and non-residential buildings through the Building Regulations system) should take effect in 2025. With such regulations still being debated and no legal guarantee that they will come into effect in 2025, and recognising that buildings are the UK’s second-highest emitting sector, the Local Plan sets out a positive strategy through the Climate Change policies for carbon reduction and to mitigate against the impact of climate change. The Plan does, however, acknowledge that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is intended that further work to update the cost evidence for a number of options for the wording of CC2 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 viability in relation to the climate change policies will be consulted on through the Reg 19 consultation.

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: 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.

Object

Representation ID: 5412

Received: 04/01/2024

Respondent: North Luffenham Parish Council

The requirement to improve the energy efficiency of the "original building" for development applications for extensions seems unworkable - how will it be assessed, and what minimum level of improvement to the "original building" will be required. This is likely to deter improvements to the housing stock of Rutland, potentially reducing improvements in energy efficiency delivered via extensions, as people will be deterred from building them by this policy.

Comment noted. Disagree. A policy seeking to reduce energy consumption in existing buildings is justified and consistent with the aims and objectives of the Plan to reduce carbon emissions. The supporting text to the policy outlines how the Council intends to bring forward supplementary guidance on best practice for energy retrofitting measures which will help in drawing up and assessing the Energy Statement. There is no evidence to suggest that the policy would deter home improvements, and there are already a number of industry standards/targets relating to energy efficiency measures in place that have been and are currently applicable.

Object

Representation ID: 5413

Received: 04/01/2024

Respondent: North Luffenham Parish Council

Can you advise who will pay for the "Independent Assessment of the Proposals" commissioned by the County Council

Policy CC8 states that the County Council may commission its own independent assessment. This would be paid for by RCC.

Object

Representation ID: 5414

Received: 04/01/2024

Respondent: North Luffenham Parish Council

Does the preservation of farmland as a "Carbon Sink" overule Renewables development ?

Comment noted. The Local Plan recognises the importance of renewable energy generation in tackling the Climate Crisis and policies are supportive of such renewable schemes in accordance with national guidance. This means that the inclusion of farmland in Policy CC11 as a carbon sink would not prevent renewable energy development but, in accordance with the policy, developers would need to demonstrate that harm to the carbon sink as been reduced to the minimum possible, and that there was not a less harmful viable option for the development of that site. Other policies such as EN3 on Biodiversity Net Gain would also apply to such proposals.

Object

Representation ID: 5416

Received: 04/01/2024

Respondent: North Luffenham Parish Council

"Proposals that include electric vehicle parking provision that exceeds or improves on the requirements set by Building Regulations will be supported"
This phraseology could be interpreted as any development that meets this policy will be supported, regardless of other attributes of the development

Comments noted. Disagree as there then follow the series of bullet points giving examples of how proposals can exceed the requirements of the Building Regulations in terms of EV charging point provision.

Object

Representation ID: 5417

Received: 04/01/2024

Respondent: North Luffenham Parish Council

CC13 Sustainable Travel, only seems to deal with charging of electric cars rather than covering any other forms of sustainable travel - Buses, Walking, Bicycles etc - the policy should be renamed to reflect this.

Comments noted. Agree. Title of policy changed to: ‘Electric Vehicle Charging and Electric Bike parking’.

Object

Representation ID: 5418

Received: 04/01/2024

Respondent: North Luffenham Parish Council

Will SS6 and SS7 also apply to St Georges barracks, or does SS5 overide these.

No, as the text accompanying Policies SS6 (Now SS5) and SS7 (Now SS6) makes clear, these policies will not apply to SGB.