5.11

Supports sustainable development and construction techniques as an important principle for the district and recognises the significance and wider implications of a commitment to reducing climate change through the planning system.

Objects that the SPD will be applied to all development irrespective of the scale of development. This approach differs from emerging policy SR3 in the RSS (Preferred Options) which only requires 10% for developments of 10 dwellings or 1000 sqm and Policy DP13 which only requires 10% in appropriate residential and non residential developments. To accord with RSS and Local Plan policy paragraphs 1.4 and 4.2 should be amended to clarify that the SPD only applies to significant developments.

The submission of an Energy Statement should not be necessary for all planning applications and the format of each statement may vary as not all categories in paragraph 3.2 will be attainable. A uniform approach should not be adopted as the submission and format of the statement should be dependant on the scale and nature of the proposal.

Welcomes the use of preapplication discussions to help ensure certainty for the developer as well as the Council.

Welcome the recognition that meeting the 10% requirement may not be appropriate for all developments and supports that the SPD recognises the difficulties faced on constrained town centre locations.

Support the inclusion of para 4.6 which identifies the importance of maintaining financial viability and not undermining the the delivery of development.

Support the inclusion of para 4.4 which identifies the potential conflict between the provision of renewable technology and the preservation of the historic environment.

Supports the recognition that the installation of renewables can detract from the historic integrity of the building but appreciates that with careful consideration some installations may be appropriate with the historic environment.

Renewables toolkit should be attached as an appendix and consulted on separately prior to the adoption of the SPD.

Objects to the contradiction between sections 4 and 5 with regard to new development and home extensions. There is concern that some developers may try to thwart the objectives while domestic extensions may be unreasonably denied particularly in older un insulated properties where using latest building regulations without applying renewables could acheive a greater energy saving.

Paragraph 8.4 should reflect the latest mandate that only permeable surfaces to domestic driveways shall be allowed.

It is questioned whether the renewable toolkits are representative. Do they consider acquisition in terms of carbon costs and whole life costs (reliability / maintainability) that would contribute to future carbon footprint through spares. Does the toolkit compare the relative merits of different types of renewable energy sources.