Proposed Submission Core Strategy
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Proposed Submission Core Strategy
7.7
Representation ID: 21156
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Para 7.7 add an objective to give particular attention to supporting developments that contribute to carbon reduction.
Para 7.7 add an objective to give particular attention to supporting developments that contribute to carbon reduction.
Object
Proposed Submission Core Strategy
13.15
Representation ID: 21157
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We do not agree with 13.15 "a local requirement to secure a proportion of energy in new developments is regarded as unnecessary"
There is a very good case for requiring developers to provide cost effective renewable energy where possible - in addition to building standards. New properties should have where possible south facing roofs and, if they do, developers should be required to install solar thermal - this is a highly cost effective technology and should enhance the value of the property.
We do not agree with 13.15 "a local requirement to secure a proportion of energy in new developments is regarded as unnecessary"
There is a very good case for requiring developers to provide cost effective renewable energy where possible - in addition to building standards. New properties should have where possible south facing roofs and, if they do, developers should be required to install solar thermal - this is a highly cost effective technology and should enhance the value of the property.
Object
Proposed Submission Core Strategy
Policy SRM1: Towards a low carbon future
Representation ID: 21158
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
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.
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.
Object
Proposed Submission Core Strategy
Policy SRM2: Water Management
Representation ID: 21159
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
"Promotion" of rainwater harvesting is not strong enough.
The policy should be to ensure that all developments consider rainwater and require larger developments to incorporate rainwater harvesting.
"Promotion" of rainwater harvesting is not strong enough.
The policy should be to ensure that all developments consider rainwater and require larger developments to incorporate rainwater harvesting.
Object
Proposed Submission Core Strategy
13.31
Representation ID: 21160
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The strategy should state that recycling and waste reduction are key elements in the Carbon Reduction Strategy and that new developments will incorporate features to facilitate this such as accessible storage area for recycling containers etc.
The strategy should state that recycling and waste reduction are key elements in the Carbon Reduction Strategy and that new developments will incorporate features to facilitate this such as accessible storage area for recycling containers etc.
Object
Proposed Submission Core Strategy
Policy CO5: Supporting Older People
Representation ID: 21161
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Policy CO5 Supporting Older People
Please add an initiative to reduce the cost of heating and energy use for older people as part of the overall carbon reduction strategy.
Policy CO5 Supporting Older People
Please add an initiative to reduce the cost of heating and energy use for older people as part of the overall carbon reduction strategy.
Object
Proposed Submission Core Strategy
15.7
Representation ID: 21162
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Please add an objective to support initiatives that improve insulation and reduce energy use in housing as part of the carbon reduction strategy.
Please add an objective to support initiatives that improve insulation and reduce energy use in housing as part of the carbon reduction strategy.
Object
Proposed Submission Core Strategy
15.23
Representation ID: 21163
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The definition of affordable housing should also take into the account the cost of heating and energy supplies and measures to reduce these should be incorporated in the construction and refurbishment of affordable housing.
The definition of affordable housing should also take into the account the cost of heating and energy supplies and measures to reduce these should be incorporated in the construction and refurbishment of affordable housing.
Object
Proposed Submission Core Strategy
16.10
Representation ID: 21164
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Economic Objectives (p127)
Add to develop the technical skills and business activities that support carbon reduction as a key economic sector.
Economic Objectives (p127)
Add to develop the technical skills and business activities that support carbon reduction as a key economic sector.
Object
Proposed Submission Core Strategy
Policy EC1: Fostering Economic Activity and Growth
Representation ID: 21165
Received: 11/11/2011
Respondent: Rother Environmental Group
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Investment in Training and business support should be given particularly to commercial activities and skills that support carbon reduction.
Investment in Training and business support should be given particularly to commercial activities and skills that support carbon reduction.
