Support
Regulation 18 Draft Local Plan
Representation ID: 134
Received: 09/03/2024
Respondent: Mrs Marie Jackson
No further comment
Support
Regulation 18 Draft Local Plan
Representation ID: 496
Received: 15/04/2024
Respondent: Miss Carys Vaughan
I support in principal but too many ‘shoulds’ here e.g ‘should strive for low carbon emissions’. SKDC have declared a climate emergence so by the nature of the word ‘emergency’ we should be a lot stricter on carbon emissions. Developers MUST show a low carbon approach e.g why allow the bund at Stamford North to be unnecessarily demolished? This is the opposite of a low carbon design.
Object
Regulation 18 Draft Local Plan
Representation ID: 687
Received: 19/04/2024
Respondent: Jelson Homes Ltd
The Government has made clear through its written ministerial statement of 13 December 2023 that it does not expect Local Plans to impose energy efficiency standards in excess of current or proposed building regulations. This policy and the requirements that it sets out should therefore be deleted as compliance with building regulations will address its objectives in full.
Support
Regulation 18 Draft Local Plan
Representation ID: 782
Received: 21/04/2024
Respondent: Jane Bateman
I support this policy, BUT SKDC must ensure it is enforced and not watered down. If anything it should be strengthened to include new developments having solar panels on their roofs and heat pumps. New distribution units and warehouses should also have solar panels as they tend to have flat roofs which is ideal and located near transportation links rather than open countryside
Low-carbon transport is vital to encourage residents to get out of their cars. Transport in Stamford is already bad and with all the developments in the pipeline it will only get worse.
Object
Regulation 18 Draft Local Plan
Representation ID: 1060
Received: 23/04/2024
Respondent: Dr Ray Butler
The best way to mitigate against climate change is to leave countryside as just that!
Support
Regulation 18 Draft Local Plan
Representation ID: 1120
Received: 24/04/2024
Respondent: Persimmon Homes East Midlands
As set out in the plan, this policy alongside all other policies, including affordable housing provision, need to be factored into the Whole Plan Viability Assessment.
Object
Regulation 18 Draft Local Plan
Representation ID: 1177
Received: 24/04/2024
Respondent: Barberry Grantham Limited
New housing development will shortly be required to be built in accordance with the Future Homes Standard that would include measures in relation to energy consumption and water resource use. As such, would the policy be better worded to refer to compliance with the Future Homes Standard or the relevant standard in place at the time of construction.
Support
Regulation 18 Draft Local Plan
Representation ID: 1286
Received: 25/04/2024
Respondent: Knightwood Developments Ltd
Agent: Boyer Planning
Over the plan period the requirements, standards and targets are likely to change as best practice and modern technologies change and evolve and bring about greater efficiencies and outcomes for both the residents of new residential dwellings, the local community and the development industry. As such we are concerned that Policy SB1 as currently written will not be effective over the plan period and greater focus should be given to development proposals needing to meet the mandatory building regulations and where possible exceeding these standards.
As the Council is aware, the building regulations are constantly being updated and revised to reflect more standards and legislation covering all aspects such as energy consumption, water use and requirements such as EV charging. Therefore Policy SB1 is at risk of becoming redundant in the short term as building regulations will require greater standards than those outlined in the emerging policy
Support
Regulation 18 Draft Local Plan
Representation ID: 1363
Received: 25/04/2024
Respondent: Wates Developments
Agent: Boyer Planning
Over the plan period the requirements, standards and targets are likely to change as best practice and modern technologies change and evolve and bring about greater efficiencies and outcomes for both the residents of new residential dwellings, the local community and the development industry. As such we are concerned that policy SB1 as currently written will not be flexible and effective over the plan period and greater focus should be given to development proposals needing to meet the mandatory building regulations and where possible exceeding
these standards.
As the Council is aware, the building regulations are constantly being updated and revised to reflect more standards and legislation covering all aspects such as energy consumption, water use and requirements such as EV charging. Therefore policy SB1 is at risk of becoming redundant in the short term as building regulations will require greater standards than those outlined in the emerging policy.
Support
Regulation 18 Draft Local Plan
Representation ID: 1398
Received: 25/04/2024
Respondent: The Woodland Trust
We have no objection to this policy but propose it be strengthened by adding a new section
4 Nature Based Solutions
New development should maximise the use of nature-based solutions, such as rain gardens and SuDS for drainage, green walls and roofs for natural cooling, and planted barriers for pollution control.
Object
Regulation 18 Draft Local Plan
Representation ID: 1613
Received: 18/04/2024
Respondent: Pegasus Planning Group
Agent: Pegasus Planning Group
This policy requires further clarification. The policy should only encourage the inclusion of energy efficiency measures and use of renewable energy sources which go beyond Building Regulation requirements. Regard needs to be had of the Housing Minister’s Written Ministerial Statement of January 2024 which clearly set out that the Government does ‘not expect plan makers to set local energy efficiency standards that go beyond current or planned building regulations’. In accordance with the Planning Practice Guidance, the Council will also be expected to provide evidence supporting the inclusion of optional water efficiency target of 110 litres per house per day.
Object
Regulation 18 Draft Local Plan
Representation ID: 1666
Received: 24/04/2024
Respondent: The Deepings Neighbourhood Plan Group
Reword to offer clarity on where these are Building reg issues. Not consistent with Climate Change chapter.
Object
Regulation 18 Draft Local Plan
Representation ID: 1692
Received: 25/04/2024
Respondent: Deeping St James Parish Council
Reword to offer clarity on where these are Building reg issues. Not consistent with Climate Change chapter.
Support
Regulation 18 Draft Local Plan
Representation ID: 1793
Received: 25/04/2024
Respondent: NHS Property Services
NHSPS fully support policies that promote carbon neutral development, and the securing of financial contributions where on-site carbon mitigation requirements cannot be met. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from carbon offset funds. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.
Support
Regulation 18 Draft Local Plan
Representation ID: 1915
Received: 25/04/2024
Respondent: Environment Agency
We support the adoption of the Buildings Regulations optional higher water efficiency standard of 110 litres per person per day to ensure water efficiency.
Object
Regulation 18 Draft Local Plan
Representation ID: 1926
Received: 24/04/2024
Respondent: Bettinson Trust
Agent: Savills
We object to Policy SB1 Sustainable Building, the Council should provide a suitable evidence base to ensure it is justified in line with paragraph 35 of the NPPF, and include suitably detailed guidance of how it expects such requirements to be complied with by applicants.
Any requirements related to local energy efficiency standards for residential uses, should consider the recent (13 December 2023) statement by the minster for Minister of State for Housing which states that: “…the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations.” Significantly, the Statement goes on to state “The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale”.
Object
Regulation 18 Draft Local Plan
Representation ID: 1946
Received: 24/04/2024
Respondent: Hallam Land Management & Barratt Developments PLC
Agent: Pegasus Planning Group
In relation to Part 1 it is suggested that the policy should reflect the national position and include the terminology ‘proactive approach’ rather than to ‘strive to be zero carbon’. In relation to Part 2 Building Regulations require all new dwellings to achieve 125 litres per day per person (Part G) and it is considered that water efficiency is a matter most appropriately dealt with through Building Regulations.
Object
Regulation 18 Draft Local Plan
Representation ID: 2053
Received: 22/04/2024
Respondent: Defence Infrastructure Organisation
Agent: Fisher German
The Policy makes it clear that where the requirements of Policy SB1 cannot be met, it is incumbent on the applicant to demonstrate exceptional circumstances that compliance with the policy is not viable or feasible. This approach is not supported.
If this element of the policy is to be retained, then updated evidence should be provided demonstrating that there remains a localised issue which requires such a significant policy intervention above and beyond the requirements already set out in Building Regulations.
Object
Regulation 18 Draft Local Plan
Representation ID: 2071
Received: 22/04/2024
Respondent: South Lincolnshire Green Party
Given the various restrictions imposed by government edicts and viability, how will new developments be 1. zero carbon. 2. water neutral? 3. Low carbon travel?
NB Net Zero by 2050 is too late.
Support
Regulation 18 Draft Local Plan
Representation ID: 2084
Received: 23/04/2024
Respondent: The Crown Estate
Agent: Savills
Policy SB1 states that ‘all development proposals will be expected to mitigate against and adapt to climate change, to comply with national and contribute to local targets on reducing carbon emissions and energy uses…’. TCE supports the principle of Policy SB1.
Support
Regulation 18 Draft Local Plan
Representation ID: 2107
Received: 25/04/2024
Respondent: Buckminster
It is noted and welcomed that under Summary of Proposed Changes (page 128) it is set out that: The final policy, will be informed by a Whole Plan Viability Assessment which will accompany the plan.
Object
Regulation 18 Draft Local Plan
Representation ID: 2227
Received: 24/04/2024
Respondent: Lindum Group Ltd
These representations should be read in conjunction with separate representations submitted on behalf of the Lindum Group by Carter Jonas which focus specifically on the proposed allocation of Land off Ermine Street in Ancaster in Policy H1.
We have concerns that this policy is broadly similar to the conditions proposed within Chapter 5 which deals with climate change. We suggest this policy should be incorporated within that chapter and reiterate our view that any such policy should bear in mind the ministerial statement of December 2023. We do however welcome the acknowledgement that any sustainable building policy takes into account the planned Whole Plan Viability Assessment. We frequently work in the Central Lincolnshire Plan Area in which extensive Climate Change and Sustainable Building policies were introduced. The result of which is viability of development in the area is under extreme pressure, with application numbers falling. Any viability assessment needs to be robust and include consultation with developers and construction companies who have experience of this issue. Lindum would be happy to participate in such discussions.
Object
Regulation 18 Draft Local Plan
Representation ID: 2416
Received: 25/04/2024
Respondent: Vistry Group
Agent: Boyer Planning
We are concerned that policy SB1 as currently written will not be effective over the plan period and greater focus should be given to development proposals needing to meet the mandatory building regulations and where possible exceeding these standards.
As the Council is aware, the building regulations are constantly being updated and revised to reflect more standards and legislation covering all aspects such as energy consumption, water use and requirements such as EV charging. Therefore policy SB1 is at risk of becoming redundant in the short term as building regulations will require greater standards than those outlined in the emerging policy.
Whilst Vistry is supportive of the principle of a policy which seeks to reduce carbon, there are
some practical considerations, as noted above, which should be taken into account as part
of future draft policy SB1.
Object
Regulation 18 Draft Local Plan
Representation ID: 2498
Received: 24/04/2024
Respondent: The Dean and Chapter of the Cathedral Church of Christ in Oxford of the Foundation of King Henry the Eighth
Agent: Savills
As drafted, this Policy requires, “New development should strive to be zero carbon ready through minimising energy use and choice of low carbon energy sources. New development should demonstrate how carbon dioxide emissions have been minimised…” Our Client supports this aim and as discussed, our Client’s own ROPP confirms a commitment to low carbon developments.
Nonetheless, the requirements of this Policy should be tested by the whole Plan viability assessment given the implications for development of achieving net zero. The policy needs to be drafted in such a way that its requirements fall away as they are superseded by national planning guidance and Building Regulations.
In the longer term our Client considers national legislation is the appropriate mechanism to deliver net zero, so again Policy SB1 should be drafted in a manner that means its requirements fall away once national guidance/regulations catch up and overtake the Policy.
Object
Regulation 18 Draft Local Plan
Representation ID: 2539
Received: 24/04/2024
Respondent: David Wilson Homes East Midlands
Agent: Savills
The policy as stated in the Ministerial Statement that was issued in December 20233 should not go beyond national standards. The Ministerial Statement states ‘a further change to energy efficiency building regulations is planned for 2025 meaning that homes built to that standard will be net zero ready and should need no significant work to ensure that they have zero carbon emissions as the grid continue to decarbonise. Compared to varied local standards, these nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes’. It goes on to state that ‘the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations’ [Savills Emphasis]. Therefore, it is considered that the plan should only require development to comply with current or planned building regulations and not ask developers to meet local needs which go beyond these.