Regulation 18 draft Local Plan

Object

Representation ID: 7170

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes welcome a policy on Energy Efficiency and the need for Design and Access Statements to demonstrate how energy efficiency has been considered in the development of the scheme. Criteria a) to d) of the policy are fully supported.

With regards to criteria e) ‘net zero carbon content of heat supply’, Persimmon Homes are of the view that this criteria should be removed from the policy. The vehicle for delivering the net zero content of heat supply is through Building Regulations and this is already happening with Part L requiring a 31% carbon reduction upon previous Building Regulations and a move to a decentralised network in 2025.

Point f), also suggest this be removed for the same reasons as per criteria e) above with Building Regulations being the most effective vehicle for introducing these standards.

In respect to criteria e) and f) in the Housing Ministers Written Statement of the 13th December 2023 on Energy Efficiency which sets out the Government does not expect Local Planning Authorities to set enhanced energy efficiency standards via local plans and instead these should come through Building Regulations. Neither the wording of the policy or the evidence base meet these two criteria further supporting the removal of criteria e) and f) from this policy.

Object

Representation ID: 7171

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

In response to wind exposure (criteria c) this is covered in detail under Building Regulations where different building standards apply depending on whether an area falls within an area of low, medium or high areas of wind exposure.

This criterial point is therefore not justified and merely a duplication of building regulations and as such should be removed from the policy.

Object

Representation ID: 7172

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

This policy is a duplication of Building Regulations and as such is not required and should be removed from the plan.

Climate change matters need to be led centrally thorough Building Regulations.

The incorporation of renewable energy on site needs to be realistic, for example, there are only so many roof spaces that photovoltaic panels can be installed and issues associated with wind turbines are well documented.
Furthermore, the preference for renewable energy to be provided on plot goes against heat networks which are being pushed forward as part of Building Regulations.

If this policy requires any additional requirements above Building Regulations, these additional costs need to be set out in the ‘Whole Plan Viability Report’ undertaken by HDH Planning and Development Limited.

Ministerial Statement dated 13th December 2023 on energy efficiency makes it clear that local plan policy should not go beyond Building Regulations which further supports the removal of this policy from the Local Plan.

Object

Representation ID: 7173

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Whilst the re-consultation on the Future Homes Standard does not include embodied carbon the government has set out in this consultation that it intends to consult in due course on its approach to measuring and reducing embodied carbon in new buildings.

Persimmon Homes are of the view that policies should come through national standards set through Building Regulations and as such Persimmon Homes are of the view that this policy is not justified and should be removed from the plan.

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.

Object

Representation ID: 7175

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes support the protection of Carbon Sinks. It was unclear from this policy and the evidence base which underpins how much of the land within the County (and its location), is classified as a ‘carbon sink’. It would be expected that a plan identifying the location of existing carbon sinks be incorporated within this Plan.

It was also unclear what the impacts of this policy would have on the viability of schemes as this has not been referred to or considered in the ‘Whole Plan Viability Report’ undertaken by HDH Planning and development Limited.

Object

Representation ID: 7176

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

The Rutland Housing Market Assessment (HMA) trend-based projections conclude that household growth will be expected to deliver between 124 and 167 units per annum. The key message concluded in the overall housing need section of the HMA that the Standard Method housing need should be considered by the (Rutland) Council as very much a minimum figure, with the majority of the rigorously assessed projections pointing to a higher figure. This has not been sufficiently demonstrated in both the overall housing need (and affordable housing need) assessment, and consequently, in the finalised requirement figure in Policy SS1.

As stated above, it is our view that the affordable housing requirement that has been taken into account to formulate the overall annual need figure in Policy SS1, is too low.

Encourage RCC to reconsider the rationale behind the statement regarding those already in housing, not adding to a net need of affordable housing.

The annual average completions figure for Rutland over the period of 2011-2022 was 184 units per annum, with the past five year average only just falling slightly below this, at 172 units per annum. The supply has almost consistently exceeded the standard method figure given in Policy SS1. One option for this is to increase the provision of affordable housing, as per the identified need.

Object

Representation ID: 7178

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

It is the view that Langham is one of the most sustainable Large Villages in the region. Langham has the capabilities to accommodate some of this identified affordable housing need.

Langham has one of the highest sustainability credentials out of the Large Villages, which, in line with our comments to both increase the minimum requirement figure to 3,340 (167 per annum), and to fill the identified affordable need in the region, proves to be a logical location to direct growth. PHEM wish to take the opportunity as part of this Regulation 18 consultation response, to initially present a site in Langham to assist in our comments regarding this policy, and Policy SS1, regarding increasing delivery in both the minimum figure in the local plan.

The site in Langham is located on the northern side of Cold Overton Road and could form an extension to the already approved outline consent for up to 50 dwellings (2021/1423/MAO). It was concluded as part of the consideration of 2021/1423/MAO that the site is located in a sustainable location within the village and the same vehicular access could be shared with the site put forward. Furthermore, with existing vegetation in place, the proposed site would be well screened from Cold Overton Road.

Object

Representation ID: 7179

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

The number of dwellings per hectare (dph) should be increased to generally no less than 30 dph. The 30 dph figure is used in this Draft Local Plan to calculate likely numbers of dwellings for housing allocations in this draft plan.

Wording within the policy still allows for flexibility in its application, however the 30 dwellings per hectare provides a useful starting point in ensuring land is developed in an effective manner as possible whilst ensuring the character of settlements is maintained.

Conversely if this figure is not increased to 30 dwellings per hectare, allocations would need to be calculated on the basis of 25 dph and this would have a knock on impact for the number of sites which need to be allocated.

Object

Representation ID: 7180

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

The affordable mix of dwellings should be informed by the Housing Market Assessment. Persimmon Homes are of the view that the mix of market housing should be dictated by the market where choice is a more fundamental factor as is documented in the Housing Market Assessment at page 172 of the report. Allowing for this flexibility will also allow for residential developments to respond to local circumstances as it is clearly evident in the Housing Market Assessment that there are vast differences between the different sub areas, also it is more likely that smaller units of accommodation, such as apartments, will come forward in the main towns within the county.

Criteria A Queston whether this policy is required. Persimmon Homes are of the view that enabling older people to sustain their independence in their own homes is interlinked with policy H5 which sets out enhanced accessibility standards.

Given the above and the Older People’s Accommodation Market Position Statement 2021 sets out there is sufficient provision for care homes until 2043, Persimmon Homes are of the view that criteria a) should be replaced by a policy which encourages specialist housing.