Our Local plan consultation response

15 December 2017

Local plan consultation response. 


10.1.3 New built development should be designed to reduce carbon emissions as close to zero as practicable. Design and Access Statements accompanying planning applications for major developments should identify cost effective approaches to low carbon development, which will be guided by the energy hierarchy. This requires that the design of any development should consider use of the following energy options in priority order:  

• passive design considered first as a means to reduce emissions,  

• then the energy efficient design of building services, including decentralised energy networks,  

• and finally, including renewable energy at building or site level. 


Commercial volume developers will always engineer a way in which they can deliver housing at the maximum profitability to themselves. With the Council having been barred in law, by the deregulation bill, from specifying higher building specifications they should instead develop a robust model by which to appraise developer viability assessments to ensure that they do not over inflate their costs in order to escape their moral responsibilities. 


With the potential for rules regarding Councils building/commissioning housing there should be a provision to ensure the Council will always develop to the highest thermal standards to BRE’s Home Quality Mark sustainability standard: http://www.homequalitymark.com 


There should be a provision for all new builds to produce at least 15% of their energy requirements onsite 

commercial developments should require a 40% BER improvement, this means that they will probably have to incorporate one or a combination of the following:  

a) highly insulated building fabric 

b) photovoltaic arrays  

c) a CHP unit or connection to an existing District Heat Network 


Local authorities can require commercial refurbishments to meet BREEAM Refurbishment and Fit-Out standards, as a minimum BREEAM ‘Very Good’ is recommended: http://www.breeam.com/refurbishment-and-fit-out 


The following sustainability requirements are recommended for inclusion in Local Plans: Considerate Constructors Scheme registration, cycle storage standards, minimum daylighting standards, ecological mitigation and enhancement, environmental impact of materials, external lighting (low energy), flood risk assessments (FRA) and site waste management plans (SWMP).  


The above requirements can be implemented through a Sustainability Checklist. Applicants would be required to must submit a completed sustainability checklist when a planning application is made. Richmond Upon Thames Council has successfully operated such a checklist for a number years (London Borough of Richmond Upon Thames (2016) Sustainable Construction Checklist. Available at: http://www.richmond.gov.uk/scc_spd_guidance_0116.pdf). 


The majority of the homes in Harborough District are of a low thermal performance and their improvement will perhaps make the biggest contribution. For refurbishment planning applications, the BREEAM for Domestic Refurbishment standard can be applied if included in the Local Plan or associated guidance. As a minimum it is recommended that housing undergoing refurbishment achieves a BREEAM ‘Very Good’ rating: http://www.breeam.com/index.jsp?id=1182 and the Passive Haus Enerphit standard introduced to householders as an option. 


Can a provision be made within Council tax banding to support higher standard buildings? 


10.3.3 The Planning for Climate Change: Renewable Energy Opportunities study, May 2008 found that wind turbines, biomass plants (including combined heat and power), solar thermal heating, photovoltaic energy, and energy from waste all have a potential to be utilised and developed within the District. The assessment identified wind energy as a noteworthy source of potential renewable energy generation for the District.  


This definition should exclude incineration and Energy from waste solutions. These are not only detrimental to the health of the local population through the emissions of dioxins they also have the legacy of toxic fly ash that needs to be land filled as well as creating a need for large volumes of rubbish which diverts potential waste streams from the local recycling industry. 


10.3.6 Community owned energy is an important means of engaging communities with their own energy generation. Community owned energy projects are encouraged within the District. A local community energy company has been set up as part of the Sustainable Harborough Challenge, called Harborough Energy, specifically to enable community owned renewable energy projects. The first two solar projects were commissioned in 2016. 

There was some confusion at the beginning of this project, it was called simply "Sustainable Harborough" 


11 Infrastructure IN1 Infrastructure provision  

1. Major development will be permitted where there is, or will be when needed, sufficient infrastructure capacity to support and meet all the requirements arising from it, including those away from the site and its immediate vicinity, whether within Harborough District or outside.  

2. Direct provision and/or financial contributions towards meeting all the eligible costs of infrastructure directly required by a major development (or cumulatively with other major developments within Harborough District or outside) will be sought from the scheme promoter whenever this is necessary. Planning obligations under Section 106 of the Town and Country Planning Act 1990 (as amended) will be required taking into account the viability of the development. This will be in addition to the affordable housing requirement as set out in Policy H2.  


Is there a mechanism included to gather contributions from developers who phase their developments in such a way as to avoid developer contributions but cumulatively place a great burden on the local facilities. 


11.3.5 The Council is anxious to ensure that both the occupiers and users of new development, and those elsewhere who may be affected by it indirectly, will not be subjected to below acceptable standards of air quality. Therefore, in controlling the potential impact of development upon air quality, the Council will require an effective air pollution mitigation strategy if a development proposal would be likely to either: 

 • have a moderate adverse, or worse, impact upon air quality within an existing Air Quality Management Area (AQMA) whether the proposal is inside or outside of that AQMA; or 

 • contribute directly or indirectly to the declaration of another AQMA be it in this district or an adjoining one. 


This clause can only be met if monitoring of the local area has been undertaken for 1 year to establish a baseline. For instance, HDC only has a single monitoring point in the settlement of Harborough. Who knows what affects development will have around the town without a baseline. 


Developers should be made to provide the council with the funding to gather this information and the viability assessments should include a worst case provision for mitigation should it be needed. 


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