BASE HEADER
CC3 Buildings Standards Requirements
Cefnogi
Publication Draft
ID sylw: 65557
Derbyniwyd: 27/06/2014
Ymatebydd: Keith Wellsted
Good idea
Good idea
Gwrthwynebu
Publication Draft
ID sylw: 65896
Derbyniwyd: 27/06/2014
Ymatebydd: Centaur Homes
Asiant : McLoughlin Planning
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Centaur Homes object to this policy. As part of the Housing Review, in March 2014
Central government has stated their intention to scrap the Code for Sustainable
Homes. Instead the aims of the scheme will be placed into the Building Regulations and become part of this process. Therefore, this policy will soon become unmanageable and will not comply with paragraph 154 of the Framework
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66015
Derbyniwyd: 27/06/2014
Ymatebydd: University of Warwick
Asiant : Turley
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Policy CC3: Buildings Standards Requirements is considered unsound as presently
drafted. In respect of residential buildings, the policy is no longer appropriate following the findings of the Housing Standards Review and publication of the related Ministerial Statement which has signalled the intention of the Government to wind down the Code for Sustainable Homes to coincide with national sustainability standards through the building regulations. Furthermore it is inconsistent with the guidance given in paragraph 95, NPPF.
Policy CC3 provides no supporting evidence confirming that it is feasible and viable for all non-residential development over 500 sq.m to meet the BREEAM Very Good standard. In respect of non-residential buildings, the University of Warwick has delivered a number of its buildings to the BREEAM standard and is committed to delivery of its estates strategy to the highest possible
environmental sustainability standards. However, the BREEAM standard is not always the most appropriate method to ensure the optimum sustainability performance of non-residential buildings and the policy could be more effective in allowing a greater degree of flexibility particularly for smaller development
projects.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66047
Derbyniwyd: 27/06/2014
Ymatebydd: Home Builders Federation Ltd
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Policy CC3 Building Standards Requirements - Residential Buildings requires all new dwellings to achieve Code for Sustainable Homes Level 4 from the date of adoption of the Local Plan and Level 5 from 2016 (or any future national equivalent) unless it can be demonstrated that it is financially unviable. This policy should be reviewed by the Council in response to the Governments recent consultation on the Housing Standards Review and the announcements on planning made in the recent Queen's Speech.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66111
Derbyniwyd: 27/06/2014
Ymatebydd: CALA Homes (mids) Ltd
Asiant : Cerda Planning Ltd
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Recent changes to Building Regulations is seeing the Code being moved from the Planning regime into its rightful place in Building Control. Although there is possibly justification for a policy which sets out the Council's carbon off-setting charge (to meet the difference between Code 4 and 5), it is considered that expecting developments to achieve a designated Code is duplicating separate legislation and is unnecessary.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66121
Derbyniwyd: 27/06/2014
Ymatebydd: Mr and Mrs Martin
Asiant : Cerda Planning Ltd
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
Recent changes to Building Regulations is seeing the Code being moved from the Planning regime into its rightful place in Building Control. Although there is possibly justification for a policy which sets out the Council's carbon off-setting charge (to meet the difference between Code 4 and 5), it is considered that expecting developments to achieve a designated Code is duplicating separate legislation and is unnecessary.
See attachment
Gwrthwynebu
Publication Draft
ID sylw: 66477
Derbyniwyd: 27/06/2014
Ymatebydd: Gladman Developments
Asiant : Stansgate Planning
Cydymffurfio â’r gyfraith? Nac Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Nac Ydi
Sets out all new dwellings required to achieve Code for Sustainable Homes Level 4 from the date of adoption and Level 5 from 2016. Outlines that Council will expect applicants to consider potential to incorporate large scale decentralised district heating networks on strategic sites identified through the Plan.
Applicants will be required to prepare Sustainable Buildings Statement demonstrating how proposals meet requirements of LP's climate change policies.
Policy Analysis
Submit that requirements set out in Policy CC3 are too onerous. Unclear whether justified by supporting evidence and properly tested for effects on viability. Remind Council of guidance in §173 of the Framework, which states that "Plans should be deliverable. Therefore, the sites and scale of development identified in the Plan should not be subject to such a scale of policy obligations that their ability to be developed viably is threatened".
Conclusions on Soundness
Whilst recognising aims of this policy, question whether requirements are appropriately justified. Risk that its provisions could threaten viability of development and consequently the delivery of the LP.
See attached
Gwrthwynebu
Publication Draft
ID sylw: 66555
Derbyniwyd: 27/06/2014
Ymatebydd: Friends of the Earth
Nifer y bobl: 4
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
There should be no need to include the viability clause - such clauses do not normally exist in considerations of Code or Building Regulations compliance.
Paragraph 5.114 first sentence - we suggest the wording should read 'on all residential developments'. Many of the supporting paragraphs in this section would be better located in Supplementary Planning Guidance as national guidance on the subject is in the process of change at present.
see attached
Gwrthwynebu
Publication Draft
ID sylw: 66591
Derbyniwyd: 27/06/2014
Ymatebydd: Catesby Property Group
Cydymffurfio â’r gyfraith? Ydi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Ydi
There are some imminent changes which are likely to render the policy out of date. This is a consequence of the Housing Standards Review 2013 and the Ministerial Letter outlining proposals for simplification of residential sustainability standards. This involves consolidating requirements into the Building Regulations with amendments to the Planning and energy Act 2008 to remove local authority's ability to set energy standards above Building Regulations. The announcement confirmed the Government's intention to wind down the Code.
Gwrthwynebu
Publication Draft
ID sylw: 66809
Derbyniwyd: 26/06/2014
Ymatebydd: Gallagher Estates
Asiant : Pegasus Group
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
The policy is generally supported as realistic and achievable and consistent with national guidance. It is considered, however, that the requirement for applicants to consider the incorporation of CHP on the strategic sites goes beyond what is justified. Paragraph 154, NPPF is clear that local plans should be aspirational but realistic. Specific reference to CHP on site is at risk, therefore, of going beyond what might reasonably be achieved. There is certainly no requirement for CHP to be provided on sites in order to meet national targets or standards. It is for the industry to develop cost effective means of delivering carbon reduction. There may well be issues in respect of viability and introducing potential obstacles to meeting housing needs. As such we do not consider it necessary or justified for the Policy to include specific reference to CHP on the strategic sites. This is at risk of being unsound and should be deleted.
see attached.
Gwrthwynebu
Publication Draft
ID sylw: 66835
Derbyniwyd: 27/06/2014
Ymatebydd: Europa Way Consortium
Asiant : AMEC
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Nac Ydi
Dyletswydd i gydweithredu? Heb nodi
the key issue is whether the Council can justify its request for Code Level 4 from plan adoption and Code Level 5 from 2016 given the potential impact on viability. DCLG's latest figures suggest an additional £1.4 - £2.4k per dwelling to achieve Code Level 4, and £14.1k - £16.8k per dwelling for Code Level 5. Therefore the Council needs to demonstrate that this policy is viable, considering the cumulative effect of other policies in the plan.
see attached