QUESTION 5: What thresholds should apply to the requirement on developers to submit an 'energy statement'?

Agree

It is considered that the requirements for Energy Statements are set too low and would not encourage smaller builders or development. An Energy Statement could be required for 50 dwellings or more, with a more complex assessment for developments of 250 dwellings or more.

Comments by Rye Town Council on the Rother DC Development and Site Allocations (DaSA) (Local Plan)


1.The 2014 Core Strategy recognised that it needed a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies. It would need to tackle two specific issues affecting dwellings: to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

2. It is noted that the DaSA Plan records the preferred sites across Rother District in two categories:

- sites where no Neighbourhood Plan (NP) is being made
- sites identified in Neighbourhood Plans; Rye is in this category.

4. Rye Town Council has considered the DaSA Plan in its three parts.

- It has NOTED Part A - the Context: (the Core Strategy), with its development requirements (not for review), and related policies. Where NPs are being prepared these are listed (Rye is listed).
- It COMMENTS on Part B - Development Policies as below. Many of these draft policies affect the RNP. Some have argued that it would have been useful to have had these as Rye was drafting its RNP, but we are where we are. We have been specifically encouraged to consider the definitive housing requirements for the Rye Neighbourhood Plan area (Rye targets have already been reconciled by Rother officers) and the policies for Development Boundaries and "Gaps".

- It has NOTED Part C - There are the Site Allocations for those parishes where no NP is being made. The only site allocations in this section relating to Rye are in Rye Harbour which we have considered in the RNP. Also there is discussion of traveller sites including one in Rye.

5. Whereas we had, at first sight, presumed that Part B might conflict with the emerging Rye NP, this is not the case. As agreed, here is the Rye TC comments in consolidated form on the three parts of DaSA.

The Rother District Development and Site Allocations Local Plan

Part A - Neighbourhood Plans (NP) - Rye NP is listed as being drafted. Version 8 emerging plan is on the website. www.ryeneighbourhoodplan.org.uk
Rother Officers have reconciled numbers in the RNP with the DaSA.

Part B Q1 - Water Efficiency -Support approach: adopt standard through Bldg Regs

Part B Q2-4 - Suggest Rye Harbour for turbines and biomass. Solar panels are not mentioned and could be fitted to large industrial and educational buildings in Rye. Support approach - should adopt national guidance standards.

Q5 - Retention of sites of social or economic value - Support approach and proposed criteria for retentions.

Q6 - Equestrian development - Support approach - as drafted

Q7 - Affordable Housing - Support Option B, in line with PPG (None under 10; 30% over 10 dwellings)

Q8 - Access to housing and space standards (Older people) - Support Option E

Q9 - 10 - Custom and self-build housing - 1% of target of 160 houses= 2 for Rye Rye could support 5 homes which is around 3%. Support Option D; a site is identified in Rye NP

Q11 - External residential areas - Support proposed policy

Q12 - Extensions to residential gardens - Support proposed policy

Q13 - Extensions and alterations, including annexes - Support proposed policy

Q14 - Boundary treatments and accesses -Support proposed policy

Q15 - Shopfronts and advertising - Strongly support proposed (more prescriptive) policy

Holiday Sites - Support proposed policy

Q16 - Existing Businesses and Sites - Support proposed policy

Q17 - Landscape and AONB - Support proposed policy

Q18 - Strategic Gaps - Rye-Rye Harbour to be extended Support the proposed definition of strategic gap, but given the unique nature and profile of Rye could be extended to gaps on the Eastern and Western approaches: New Road, Military Road and New Winchelsea Rd

Q19 - Bio diversity and Green Space - Support the policy approach

Q20 - Drainage - Support the policy approach

Q21 - Land Stability - There is a risk of (sandstone) rockfall around Rye. The rock structure is of similar composition to cliff structure of Fairlight / Pett . The risk locations include East, South and West Citadel; land above Military Rd and at Cadborough. Rye should be specifically identified and a similar policy applied to land at risk above and below where historical falls have occurred. Propose inclusion of Rye as for Fairlight and Pett Level

Q22 - Environmental Pollution - Support policy approach

Q23 - Comprehensive Development -Support policy approach

Q24 - Development Boundaries - The RNP proposes two changes to the development boundary of Rye. Policy approach should cater for this.

Part C - Targets
Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour), 10-20,000 sqm employment. Dwellings Number Breakdown has been agreed with Rother DC Officers:

Total Completions Large Site Small Site Windfall
355 198 22 6 22
Balance: 107

Rye Harbour - Allocation to Rye Harbour - 40 dwellings - Support policy approach; as directed by Rother DC, and for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish)
The 40 are included in the Rye target of 400 as above.

Traveller sites - Traveller Site - Rye Gritting Depot is listed but not a preferred option - Support policy approach

community heating is always inefficient, so combined heat and power on a large scale is wasteful, but individual homes should all be required to have solar thermal or solar power generation and rain water storage or a zero carbon foot print as a starting point not an add on

Ticehurst Parish Council recommends making it a requirement for developments of six dwellings + be required to produce an energy statement so that architectural designs will automatically take the requirement into account, providing well-designed schemes hidden into the roofs etc. TPC feel that any application to ESCC for fracking licenses should be subject to consultation at RDC and PC levels and that notice of receipt of an application to RDC and PC should be immediate.

Energy Statement should be required for all developments over 50 houses.

The requirement should not be lowered from what it currently is, most forms of energy (solar being the exception) are finite resources and must be treated accordingly.

Energy statements should be required for all developments over 50 homes

All developers should be required to submit an energy statement (even for one new house). This should encourage energy-efficient buildings.

In the SRNP we have proposed a policy in Policy HO7 that all forms of development, whether residential or commercial, should demonstrate 'regard to issues of renewable energy technologies' otherwise they will be refused. Please note the threshold for Salehurst and Robertsbridge is any development.We urge you to adopt the same principle.

Rather than trying to require an energy statement from developers, why not set criteria for all buildings to reduce the energy consumption from the outset? eg:
locate all building (domestic and commercial) to maximise their passive solar gain;
require all buildings (domestic and commercial) to minimise their heat loss by construction methods and by their physical orientation;
require all commercial buildings with a roof space in excess of 100m2 to install solar panels.
require minimum levels of insulation.

All development for new build should require an energy statement.

We support the Council's recognition that the thresholds for delivering renewable and low carbon energy and combined heat and power generation (CHP) in Core Strategy Policy SRMl(i) are too low. We agree that there should be a higher requirement for 'energy statements'.

We support the proposed threshold for 50 residential units or 5,000m2 of non-residential development.