Object

Representation ID: 1326

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

These three policies in the emerging Plan set out various policy measures relating to sustainable design and construction in order to achieve the Council’s aspiration of mitigating and adapting to climate change. As identified through previous representations, it is considered that the policies should be reviewed and amalgamated, in order to streamline policy requirements and reduce duplication, consistent with the requirements of Paragraph 16 of the Framework. It should be considered whether policy requirements could be identified in more simple terms, with more detailed policy suggestions identified through Supplementary Planning Documents, whilst also recognising the increased requirements for renewable energy and other sustainable technologies advanced through changes to Building Regulations.

Object

Representation ID: 1329

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy is deemed unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not aligned with national policy.

Redundancy: HBF questions the necessity of this policy, suggesting it may duplicate existing policies within the Plan. They are concerned that this redundancy could create confusion.

Ministerial Statement on Energy Efficiency: HBF draws attention to a recent Ministerial Statement which clearly states that the Government does not expect local authorities to set energy efficiency standards beyond current or planned building regulations. The proliferation of local standards adds costs and complexity, undermining economies of scale in building homes. The statement is available here: Ministerial Statement.

Future Homes Standard Consultation: HBF notes that the consultation on the Future Homes Standard was held from December 13, 2023, to March 6, 2024, and encourages the Council to consider its findings. The consultation documents can be found here: Future Homes and Buildings Standards 2023 Consultation.

In summary, HBF argues that the policy is unnecessary, could cause confusion, and is not in line with national expectations regarding energy efficiency standards.

Object

Representation ID: 1390

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

These three policies in the emerging Plan set out various policy measures relating to sustainable design and construction in order to achieve the Council’s aspiration of mitigating and adapting to climate change. As identified through previous representations, it is considered that the policies should be reviewed and amalgamated, in order to streamline policy requirements and reduce duplication, consistent with the requirements of Paragraph 16 of the Framework. It should be considered whether policy requirements could be identified in more simple terms, with more detailed policy suggestions identified through Supplementary Planning Documents, whilst also recognising the increased requirements for renewable energy and other sustainable technologies advanced through changes to Building Regulations.

Comment

Representation ID: 1451

Received: 29/11/2024

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

The three policies on sustainable design and construction in the emerging Plan aim to mitigate and adapt to climate change. However, it is suggested that these policies be reviewed and merged to streamline requirements and reduce duplication, in line with Paragraph 16 of the Framework. The policies should be simplified, with detailed requirements outlined in Supplementary Planning Documents, while also considering the increased standards for renewable energy and sustainable technologies introduced by changes to Building Regulations.

Comment

Representation ID: 1491

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterate comments made to Regulation 18.

Request cross-reference to Policy DLP36 Canals within this policy and justification text.

Retrofitting is also briefly mentioned in para 12.10 of the justification text. Request paragraph is augmented to reflect reality that heritage property stock as well as modern (up to the early 21st century) stock will require retrofitting to be energy efficient and sustainable. Development proposals should be required to ensure that the chosen approach considers any impacts on the canals. Reference Historic England Advice Notes.

Comment

Representation ID: 1508

Received: 29/11/2024

Respondent: NHS Property Services Ltd

'Draft Policy DLP41 Increasing Efficiency and Resilience'

Draft Policy DLP41 sets out that development should be designed to mitigate climate change impacts and provide adaptations that will help communities and individuals to continue to avoid or mitigate adverse effects on human health. The NHS requires all new development projects to be net zero carbon, and NHSPS fully support policies that promote carbon neutral development. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from carbon offset funds collected if one were to be introduced. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.

Comment

Representation ID: 1555

Received: 29/11/2024

Respondent: Historic England

Policy DLP41 Clause h

Re-write to state ‘not cause harm to the significance, historic fabric…’

Support

Representation ID: 1601

Received: 29/11/2024

Respondent: National Highways

Acknowledge the Local Plan has focused on policies DLP41 - DLP48 to tackle climate change by reduction in carbon emissions, improving sustainable modes of transport and the development of energy efficient infrastructure which is welcomed.