Regulation 18 draft Local Plan

Support

Representation ID: 7014

Received: 08/01/2024

Respondent: House Builders Federation

HBF agree that the Vision for Rutland should include reference to the need to meet the current and future housing needs of the whole community, including for market and affordable housing. We agree that new housing is needed in towns, larger villages and smaller settlements. HBF also agree that it is important for the Local Plan Objectives to recognise the connection between housing and the future aspirations for the local economy.

Support noted.

Support

Representation ID: 7526

Received: 08/01/2024

Respondent: House Builders Federation

HBF support the intention of Strategic Objective 3 to meeting Rutland’s identified current and future diverse housing needs.

Support noted.

Object

Representation ID: 7535

Received: 08/01/2024

Respondent: House Builders Federation

HBF are pleased that the Council have recognised the need for the Plan to cover a period of 15 years from adoption. We would highlight that plan-making can take time and would encourage the Council to consider whether the Plan period should be extended to 2042 or 2043 to ensure that this will still be the case even if there is an unexpected delay during the plan-making and Examination process. It will be
essential that the evidence base covers the full plan period and as such HBF suggest there is merit in considering this issue now.

Comments noted. The Local Plan evidence base has been prepared and updated to cover a base period of 2021-2041 - a 20 year period to ensure that the Plan would then cover at least the required 15 year period after adoption.

Object

Representation ID: 7537

Received: 08/01/2024

Respondent: House Builders Federation

HBF supports the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to success is standardisation and the
avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers,
suppliers and developers. The Councils do not need to set local energy efficiency standards, or a requirement for zero carbon homes, in a Local Plan policy.

HBF would caution against policies that seek to go further and faster than national policy changes as this would lead to a patchwork of local policies which could undermine the delivery of these wider environmental objectives and create unnecessary delays to much needed new housing.

If a policy were to remain, HBF would question if the requirement for all new development to be net zero carbon in terms of heat supply is realistic in all cases,
and suggest some flexibility is needed within the policy.

It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. 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.
Disagree regarding part e). The policy already has flexibility built in with the use of words ‘should demonstrate’ and ‘have influenced’ in the second sentence.

Object

Representation ID: 7538

Received: 08/01/2024

Respondent: House Builders Federation

HBF would question what this policy is seeking to achieve and what it adds to Building Regulations. What will the Council do with the information of the ‘as built’ calculations when they receive it? What action could or would be taken once the homes have been completed? HBF note that Plan explains that consideration is being given to the viability of this approach and agree that energy efficiency requirements (and other policies) need to be subject to robust viability testing. However, this policy seems unnecessary and should be deleted.

Comments noted. Disagree. Comments noted. The NPPF makes it very clear that plans should take a proactive approach to mitigating climate change and in order to increase the use and supply of renewable and low carbon energy, plans should provide a positive strategy for energy from these sources. It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. As a Local Plan has a limited influence on retrofitting existing buildings, in order to reach targets for carbon reductions, significant reductions in the energy requirements of new buildings are urgently needed and Policy CC4 seeks this aim. 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, 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 a renewable energy level such as that used in other adopted local plans. It is suggested that RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy.

Object

Representation ID: 7539

Received: 08/01/2024

Respondent: House Builders Federation

HBF are unclear how a developer would show compliance with this policy, and whether the Council has the skills and expertise to undertake or critique embodied carbon assessments, especially as be qualified to make judgements on accepting or rejecting carbon assessments as the baseline and measures therein have not been established. HBF therefore view this policy as unnecessary, and it should be deleted.

Comments 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. Disagree to the policy’s deletion. There is a statutory requirement for development plans to include policies designed to ensure that the development and use of land contributes to climate change mitigation and adaption. Whilst the NPPF does not contain a similar policy on embodied carbon, para 124 does states that planning policies should…promote and support the development of under-utilised land and buildings. The policy is needed in the Local Plan because of embodied carbon making up between 67% and 76% of the building’s total carbon emissions and that this must be addressed in order to respond to the Climate Emergency. Currently, no part of the Building Regulations addresses embodied carbon and so there is no regulatory incentive for new development to reduce its embodied carbon. There is also no guarantee that this will be legislated for in the future. A similar policy approach has been taken in the adopted Central Lincolnshire Local Plan (2023).

Object

Representation ID: 7540

Received: 08/01/2024

Respondent: House Builders Federation

HBF note that the current Part G Building Regulations requires developments to compliance with a limit of 125 litres per day. House builders are frequently delivering
115-110 litres per day which means the house building industry is already improving upon the regulations. HBF would caution against policies that seek to go further and
faster than national policy changes that result in patchwork of differing local standards. Because. There is therefore no need for a policy on this matter in a Local Plan.

Disagree. Para 158 of the NPPF states that ‘Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk,…..water supply…. The Optional Technical Standards for housing allows local authorities to apply a more stringent standard of 110 litres per person per day where there is a clear local need. Rutland is identified as being within a serious water stressed area and so this optional standard is required in the Local Plan.

Object

Representation ID: 7541

Received: 08/01/2024

Respondent: House Builders Federation

Although HBF does not comment on individual sites or allocations, we believe that the Plan should provide for a wide range of deliverable and developable sites across
the Borough in order to provide competition and choice to ensure that housing needs are met in full. HBF would wish to see the Plan set out a logical settlement hierarchy
which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation.

The NPPF requires Local Plans to identify land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless there are strong
reasons why this cannot be achieved.

HBF would therefore wish to see the 10% small sites allowance delivered through allocations (and not windfall). Such sites are important for encouraging the growth in
SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan.

Although a policy that sets criteria to enable housing is smaller settlements is welcomed, HBF would support a Local Plan that included sites allocated sites in rural areas. HBF supports this being done through plan-making process in the Local Plan
which provides certainty in meeting rural housing needs.

The Plan needs to set out how and when monitoring will be undertaken, and more is needed on what action(s) will be taken when if monitoring shows under delivery of
housing.

The housing requirement is 123 per annum x 20 years plus 10% buffer = 2706. Of this total 193 have already been built leaving a requirement of 2513 dwellings.

The plan is to include a section on monitoring and what actions would be triggered if a lack of housing delivery was reported. Although Policy SS1 does provide this in the last paragraph of SS1b)

Object

Representation ID: 7544

Received: 08/01/2024

Respondent: House Builders Federation

The standard method LHN should be the minimum starting point for establishing the housing requirement and the Council should then considers if there are issues that result in the need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing.

HBF suggests that Council should consider if these factors, individually and/or cumulatively result in the need for a higher housing requirement for Rutland, and a subsequent need for additional allocations.

HBF note that the consultation acknowledges that
“some or all of the reserve sites may still need to be allocated in the final version of the plan if the minimum housing need increases or if any of the preferred sites
become unavailable or undeliverable. HBF suggest reserve sites should be allocated so they that can be easily and quickly brought forward to address any under-delivery of housing supply.

HBF believe that the Plan should provide for a wide range of deliverable and developable sites, including a buffer and small site allocations across Rutland in
order to provide competition and choice to ensure that housing needs are met in full.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 7545

Received: 08/01/2024

Respondent: House Builders Federation

HBF have no comments on this policy other than to note that cross-boundary strategic sites can be complex to deliver, which further underlines the need for
flexibility in the plan through additional allocations, and robust monitoring to ensure effective housing delivery is achieved over the Plan period.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.