Object

Proposed Submission Core Strategy

Representation ID: 21158

Received: 11/11/2011

Respondent: Rother Environmental Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Objection is made to Rother's carbon reduction strategy. As a minimum residential development should be level 3 (Code for Sustainable Homes) with incentives to encourage developers to build to level 4/5 with strong aspirations to reach level 6 (zero carbon).

Objection is also made to the policy requirement on development of 100 dwellings or 1,000 sq m should have an energy strategy as it is considered this type of development is rare in Rother and would only be implemented once or twice. Consideration should be given over to a reduction of the theshold to capture smaller scale of development and a change to policy wording to strengthen Rother's commitment to a low carbon future.

Full text:

The guidance has decided not to given any advice or set any target or even encouragement to build to higher standards than those set out in current building regulations. Some guidance is needed as part of the Council's carbon reduction strategy. The policy could be that new homes will be built to a minimum standard of Sustainable Homes Code 3 and that there should be encouragement and even incentives for developers who build to Code 4. There should be provision in the strategy for the codes to be raised during the course of the life of the strategy so that by the end of the period the minimum will be Code 5 but the aim should be Code 6 - the so called zero carbon home.

(1) This policy states that developments of over 100 dwellings or 1,000 sq m should have an energy strategy.
Our first objection to this policy is that developments of this size are so rare in Rother as to make the policy unlikely to be needed more than once or twice. The scale at which developments need to consider very seriously their energy use is much smaller. We would suggest 25 dwellings or 400 square meters of non-residential.
Requiring a strategy is not strong enough. There must be a requirement to implement low carbon design in to the energy and water use of the developments.
(v) We welcome the intent of this policy but "encourage" is not enough. We suggest that for larger extensions of existing buildings there should be a requirement that the existing building meets current standards or as an alternative- for the resulting building to meet a minimum rating on an Energy Performance Certificate - possibly level C.