Object
Proposed Submission Development and Site Allocations (DaSA) Local Plan
Representation ID: 24438
Received: 07/12/2018
Respondent: Persimmon Homes Ltd
Agent: Savills
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy DRM3 is considered to be an onerous and unnecessary obligation. The commitment to seeing a low carbon and renewable energy contribution is acknowledged as being well-intended, but in practice can lead to the dismissing of best practice energy efficiency techniques. Elements such as robust details, triple glazing, or efficient heating and ventilation systems are all more in keeping with the principles of sustainability as set out in the NPPF and are proven to be readily effective, but are often dismissed as not being not renewable or low carbon.
Therefore, policy DRM3 would benefit from additional wording along the lines of "The extent to which a proposal incorporates renewable and low carbon energy technologies alongside best practice efficiency techniques will be a factor weighing in the favour of a proposed development."
The supporting text also identifies that Core Strategy Policy SRM 1 already promotes renewable energy through its requirements for an energy strategy on residential developments of 10 or more units, and that these thresholds should be reviewed as the requirements for an energy strategy can be onerous. These requirements are onerous, and would greatly benefit from a prompt review.
Please see attached full representation for further information.
Policy DRM3: Energy Requirements (Objection, requires technical amendment)
Policy DRM3 states that the extent to which a proposal incorporates renewable and low carbon energy technologies will be a factor weighing in the favour of a proposed development", and that "Proposed developments of more than 100 dwellings or 10,000sqm of non-residential floorspace should demonstrate that due regard has been had to energy efficiency, including through the use of renewable and low carbon energy technologies, as part of their Design and Access Statement."
This policy is considered to be an onerous and unnecessary obligation. The commitment to seeing a low carbon and renewable energy contribution is acknowledged as being well-intended, but in practice can lead to the dismissing of best practice energy efficiency techniques. Elements such as robust details, triple glazing, or efficient heating and ventilation systems are all more in keeping with the principles of sustainability as set out in the NPPF and are proven to be readily effective, but are often dismissed as not being not renewable or low carbon.
Therefore, policy DRM3 would benefit from additional wording along the lines of "The extent to which a proposal incorporates renewable and low carbon energy technologies alongside best practice efficiency techniques will be a factor weighing in the favour of a proposed development."
The supporting text for Policy DRM3 also identifies that Core Strategy Policy SRM 1 already promotes renewable energy through its requirements for an energy strategy on residential developments of 10 or more units, and that these thresholds should be reviewed as the requirements for an energy strategy can be onerous. These requirements as set out in SRM1 are onerous, and would greatly benefit from a prompt review.
Please see attached full representation for further information.
Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171
Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172