Regulation 18 draft Local Plan

Support

Representation ID: 5838

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

The three principles of the circular economy would be reinforced if the following was added:
• “Waste and pollution should be viewed as design flaws rather than the inevitable products of the buildings and infrastructure as constructed.”

Disagree. The Waste Hierarchy in Policy CC1 recognises that the prevention of waste is the most effective environmental solution to reduce the generation of waste but it is acknowledged that waste can be unavoidable as a result of some industrial processes. In that case, waste should not be conceived as a design flaw but instead ways be found to treat it further down the waste hierarchy scale.

Object

Representation ID: 5839

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

The phrase “highest possible” is too imprecise. An energy use limit should be included, as in the Central Lincs Local Plan (2023).

The specific, quantitative targets from the earlier draft Local Plan should apply:
Achieve a target average space heating demand for the development site of between 15-20kWh/m2/yr and a site average total energy demand (Energy Use Intensity EUI) of 35 kWh/m2/yr for housing and 55kWh/m2/yr for commercial buildings, through a ‘fabric first’ approach to construction. No single building should have a total energy demand (EUI) in excess of 60 kWh/m2/yr, irrespective of the amount of on-site renewable energy production.

Policy CC2 should set out the specific “high standards for space heating demands and, Energy Use Intensity”, or reference space heating demands or EUI, as in the second sentence of the section Net zero carbon (operational) - What will the policy do?

Equally “residential development” should be replaced by “all building development” as is implied in policy CC2.

Comments noted. The Plan acknowledges that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is not currently able to set such targets. 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, such as setting standards for energy efficiency, 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 an energy use limit such as that used in other adopted local plans.
Disagree on taking out (where appropriate) in criteria d) as heat recovery from outgoing air and/or wastewater would only be achievable on larger scale commercial or residential developments.

Support

Representation ID: 5840

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

These are also excellent points b) to d) to include in the Design and Access Statement. But please add a) to the required Energy Statement.

Also split section d) into two points as they are both separate and important points:
d) How the proposal is flexible to future social, economic, technological, and environmental requirements in order to make buildings fit for purpose in the long term.
e) How to minimise future resource consumption in the adaptation and redevelopment of buildings in response to future needs with reference to the circular economy in CC1.

Support noted. Agree to include considerations set out in CC3 into an Energy Statement (rather than a DAS) and to split part d) into two parts.

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: 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: 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: 5844

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

This is a welcomed policy as there are many historic and listed buildings in Rutland. However, the phrase “where possible” should be omitted in that sentence as it could be added to a new sentence “Any extension to an existing building should where possible have a minimum EPC rating of B” or a similar standard.

Solar panels (both PV and thermal) and the external units air source heat pumps should be more actively encouraged on or around listed buildings. Chelsea and Kensington Council have actively encouraged solar panels on listed buildings.

Support noted. Regarding setting of efficiency targets, it is intended that further work to update the cost evidence for a number of options for the wording of CC7 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. The part of the policy on retrofitting is positively worded to ‘will be expected’ and is intended to encompass all micro-renewables, including ASHPs, whilst still consistent with protecting heritage assets as required under national planning policy and other policies of the Local Plan.

Support

Representation ID: 5846

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Replace “Weight in favour will be afforded..” with “Proposals will be actively supported for renewable energy systems…..”
Also add “This may include partnerships with local companies or landowners, especially in terms of heat recovery or the siting of renewable energy systems.”

This is a welcomed policy, especially in terms of wind energy. Relatively more emphasis should be placed on solar energy. The interactive map identifies nearly as much area for solar as wind energy.

Support noted. The wording under the heading ‘Community renewable energy proposals’ accords with Government guidance in the PPG which states at para 004 that: ‘Local planning authorities may wish to establish policies which give positive weight to renewable and low carbon energy initiatives which have clear evidence of local community involvement and leadership.’ Agree to add in: ‘This may include partnerships with local companies or landowners, especially in terms of heat recovery or the siting of renewable energy systems.’
Agree more emphasis should be given to solar energy. Add to 5th para on page 42: Ground-mounted solar pv farms are one of the most established renewable electricity technologies in the UK and the cheapest form of electricity generation. Solar pv offers the potential for the greatest generation of renewable energy in Rutland. Solar is a key part of the government’s strategy for low-cost decarbonisation of the energy sector. Solar also has an important role in delivering the government’s goals for greater energy independence and the British Energy Security Strategy states that government expects a five-fold increase in solar deployment by 2035 (up to 70GW). The Government is supportive of solar that is co-located with other functions (for example, agriculture, onshore wind generation, or storage) to maximise the efficiency of land use. Solar farms can be built quickly and the generation of renewable electricity and associated reduction in greenhouse gas emissions would make a positive contribution towards achieving the UK Government's legally binding emissions reduction targets as well as contribute to achieving Rutland County Council’s objectives related to the declared Climate Crisis.

Support

Representation ID: 5847

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Add sentence “There should be a presumption in favour of preserving carbon sinks in situ, especially for wetlands and woodland habitats. On land wetlands store the largest amount of carbon per unit area, followed by woodlands.”

There are very few, if any, peat soils in Rutland - only in garden centres! Replace with “Grassland, scrub, arable land and especially wetlands and woodlands, sequester and store carbon. Development on these habitats is a major source of global greenhouse gas emissions.”

Add examples of methodologies for evaluation such as life cycle assessment or material flow analysis.

Support noted. Agree but more appropriate in accompanying text. Add in extra sentence in first para after sentence ending in …’under water.’ ‘On land wetlands store the largest amount of carbon per unit areas, followed by wetlands.’
Add in to 2nd para after 2nd sentence: ‘Grassland, scrub, arable land and especially wetlands and woodlands, sequester and store carbon. Development on these habitats is a major source of global greenhouse gas emissions.’
Further details of methodologies for evaluation of the carbon sink would be included in a future SPD.

Support

Representation ID: 5849

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

It should also be recognised here that buildings can be carbon sinks in their bio-based construction materials such as wood and agricultural crop residues. Carbon can also be stored in materials such as lime mortar.

Support noted. Policy CC12 considers land-based carbon sequestration. The importance of embodied carbon in buildings in reducing greenhouse gas emissions is covered by Policy CC5 and the recycling of materials is covered by CC1.