Regulation 18 draft Local Plan

Object

Representation ID: 7861

Received: 08/01/2024

Respondent: Ryhall Parish Council

10 Ensure Development is Supported by Essential Infrastructure

The background information re population size, age demographics etc. are noted.
How is this to be achieved?

We see lots of detail with regard to Housing Allocation, but nothing on further infrastructure provision?

Comments noted. The Spatial Strategy takes into account the supporting demographic data and provides the overall framework for the quantity and location of new development. The requirements for infrastructure provision is set out in Chapter 11: Infrastructure and delivery and in the accompanying IDP.

Object

Representation ID: 7869

Received: 08/01/2024

Respondent: Ryhall Parish Council

More detail required, not a strong enough statement (no mention of RCC stated confirmation that we are in a Climate Crisis.

This is of critical importance, particular to our young generation who have no voice.

Consideration should be given to incorporate further re NPPF Chapter 13 Protecting Green Belt Land, i.e., further define our Greenbelt Areas, particularly in relation to para 143, 149, 150 and 152.

No mention of renewable energy, heat pumps - Appreciate that this may come under the Climate Resilient, however feel that our LP should be more prescriptive, than general.
We need developers to be under no doubt as per the standards required. It is understood that heat pumps are installed under the planning system with a noise assessment. It seems unacceptable to Ryhall Parish Council that they can be installed only 1m away from their neighbours and have a maximum decibel of approx. 42 (about the noise of a washing machine. However, one does not have a washing machine on all the time and we tend to have washing machines indoor! These guidelines must be revised as they are unacceptable.

There is not enough emphasis on improving existing energy efficiency in buildings or utilities (e.g., street lighting). We have to improve performance to achieve Net Zero across the county.

The opening paragraph of Chapter 4 states that the Council has declared a Climate Crisis. RCC has no Green Belt designations (and new Green Belts should only be established in exceptional circumstances) so Chapter 13 of the NPPF is not relevant to the local plan. Policy CC2 sets out design principles for energy efficiency including heating with a net zero carbon content. Issues of noise from ASHPs are dealt with through planning application legislation rather than the local plan process. The opening text in Chapter 4 acknowledges that the Local Plan has very limited influence over existing buildings but Policy CC7 does aim to improve the energy efficiency of existing buildings and CC8 seeks to maximise use of renewable energy including ASHPs. Any planning application for an ASHP would be assessed against Policy CC8 which takes into account noise impact. Energy efficient street-lighting would be a matter of wider council policy rather than through the local plan (except where part of a new development covered by Policy CC2.)

Support

Representation ID: 7870

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC1 Supporting a Circular Economy - Support

Support noted.

Object

Representation ID: 7872

Received: 08/01/2024

Respondent: Ryhall Parish Council

Only Support if there’s clarity as to what standard is being used to measure the “highest possible energy efficiency standards?

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 CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges that a key consideration for Policy CC2 is its impact on the viability of new developments (that would include affordable housing). 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 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.

Support

Representation ID: 7873

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC3 Resilient and Flexible Design - Support

Support noted.

Object

Representation ID: 7874

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC4 Net Zero Carbon (operational) – only Support subject to a change so that new proposals must [not should] provide Net Zero.

Surely this “Should” must be changed to “Must”?

Comment 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum 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 for renewables such as that used in other adopted local plans. In the absence of such feasibility evidence the policy cannot state that new development ‘must’ provide all their own energy needs.

Support

Representation ID: 7875

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC5 Embodied Carbon - Support

Support noted.

Support

Representation ID: 7876

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC6 Water Efficiency and Sustainable Water Management - Support

Support noted.

Support

Representation ID: 7878

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC7 Reducing Energy Consumption in Existing Buildings – Support

Support noted.

Support

Representation ID: 7879

Received: 08/01/2024

Respondent: Ryhall Parish Council

- Support in General, with exception as below.

We are awaiting a decision re Mallard Pass Solar Farm, which has gone through a lengthy process.

We support Solar Panels on Roofs and on Industrial Building but cannot support on Greenbelt Land. The Carbon Footprint over the lifetime of the project is huge and cannot be offset. Would rather have wind turbines.

Support noted. As there is no greenbelt in Rutland it is assumed that the comments refer to greenfield land. Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. If solar pv developments were restricted only to greenfield land this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. Solar pv offers the potential for the greatest generation of renewable energy in Rutland and it would not be appropriate to set a preference for wind energy over solar energy in the local plan.