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.”

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.

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.

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.

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.

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.”

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

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

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

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.