Policy SRM1: Towards a low carbon future

Shepway District Council supports measures that will offset the impacts of climate change.

Trinity College supports the policy requirement to maximise energy efficiency and renewable energy generation, subject to viability considerations. However, Trinity College are concerned that the Policy requirement in criterion (iv) for developments to North East Bexhill, to include Combined Heat and Power (CHP) and/or wind energy, pre-judges the outcome of the comprehensive energy strategy required by criterion (i) of the Policy to support any planning application for the area.

There needs to be clear evidence available to demonstrate that a CHP system and/or wind energy generation is both technically feasible and financially viable if it is to remain as a Policy requirement. Trinity College has not yet commissioned any such work.

CPRE Sussex welcomes and supports Policy SRM1 Towards a Low Carbon Future, particularly criterion (iii):

(iii) Support stand-alone renewable and low carbon energy generation schemes that:
a) do not have a significant adverse impact on local amenities or landscape character, particularly those utilising solar, biomass and wind energy technologies, and
b) in respect of locations in or adjacent to the High Weald AONB and other sensitive landscapes, are generally small in scale;

Paragraph 13.13 refers to the Rother's biomass resource (woodland). Paragraph 17.15 advises that Rother has the highest percentage of ancient woodland cover in the South East (15.5%).
However, there is nothing within the policy to encourage the use of this natural resource that is not only sustainable but zero carbon. This would also support policy EN1 that seeks to enhance the district's landscape and landscape features ((vi) refers to ancient woodland); and policy EN5 that seeks to support opportunities to manage and restore habitats. There would also be benefits for rural employment.

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.

Natural England welcomes the policies in SRM1 Towards a Low Carbon Future, TR2 Integrated Transport and TR3 Access and New Development in the Rother Core Strategy.