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Representations on VALP Proposed Submission - C3 Renewable Energy
OBJECT FCC Environment represented by Sirius Yorkshire (Joanna Berlyn)
Compared to strategic objective 7, policy C3 appears to relate to specific developments rather than being a consideration within their strategic policies when determining location for growth. Thus, the Proposed Submission VALP fails to proactively consider and identify opportunities for decentralised renewable or low carbon energy supplies when locating development, as required by the NPPF (para 95). Buckinghamshire's Energy from Waste facility (Greatmoor) is located within Aylesbury Vale District. In line with the NPPF, areas and sites surrounding this facility should have been considered in more detail as areas for growth.
SUPPORT Wendover Neighbourhood Plan Steering Group (Mr Jonathan Clover)
All the above Policies are welcomed.
SUPPORT The Environment Agency (Michelle Kidd)
Policy C3 Renewable Energy states:
"Aylesbury Vale is located within an area of water stress and as such the Council will
seek a higher level of water efficiency than required in the Building Regulations, with
developments achieving a limit of 110 litres/person/day."
This policy sets out a good standard of water efficiency in new developments. The
standard of water efficiency required is also repeated in Policy I5 Water Resources. We are pleased with and support this part of the policy.
SUPPORT Historic England (Mr Martin Small)
we welcome criteria c. and p. as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by paragraphs 126 and 157 of the National Planning Policy Framework.
OBJECT Persimmon Homes North London represented by Woolf Bond Planning (Mr Steven Brown)
In its current form, Policy C3, which states that a feasibility assessment for district
heating and cooling utilising technologies such as combined heat and power will
be encouraged for all residential developments of 100 dwellings fails to provide
any form evidence that such policy is needed, deliverable or indeed viable.
OBJECT Richborough Estates represented by RPS Planning & Development (Mr Cameron Austin-Fell)
Requiring a feasibility assessment for Combined Heat and Power (CHP) for all developments over 100 units should be omitted. There is no support for such a stringent policy and no viability testing as to the implications of it.
OBJECT Waldridge Garden Village Consortium represented by Pegasus Group (on behalf of Jeremy Elgin) (Mr Neil Tiley)
Policy C3 requires that a feasibility assessment for district heating and CHP is provided for all proposals in excess of certain thresholds.
Where it is demonstrated to be feasible, the policy requires that 10% of the energy should be secured from decentralised, renewable or low carbon sources. These are not the only mechanisms to reduce the carbon footprint and other current and newly arising opportunities should also be facilitated, including a fabric first approach or new technologies as they arise.
Policy C3 fails to recognise other mechanisms to reduce the carbon footprint of a development.
OBJECT Arnold White Estates (Bob Williams) represented by Gardner Planning Ltd (Mr Geoff Gardner)
Policy C3 is supported (logged as object as they wish to speak at the examination though)
SUPPORT Berkshire, Buckinghamshire & Oxfordshire Wildlife Trust (Mr Neil Rowntree)
We support these policies which are necessary in order to comply with NPPF requirements regarding biodiversity and the natural environment, and the NERC Act (2006) duty with regard to biodiversity.
Note that we are aware that the Natural Environment Partnership (the NEP, which is the equivalent of a Local Nature Partnership in Buckinghamshire) is asking for a modification with respect to the supporting text of Policy I1 Green Infrastructure. We support that modification which in the interests of brevity we do not repeat here - please refer to the NEP response.
OBJECT Chiltern Area of Outstanding Natural Beauty Conservation Board (Dr Lucy Murfett)
The Chilterns Conservation Board has produced a Position Statement on Renewable Energy which could be referred to in relation to renewable energy proposal in or affecting the Chilterns AONB, available here
SUPPORT Elgin Energy represented by RPS Planning & Development (Mr. Richard Turner)
Elgin Energy supports the inclusion of a specific policy relating to development of renewable energy. However, it is considered that Draft Policy C3 should be more positively worded so as to proactively support applications for renewable energy development, as opposed to simply 'encouraging' them.
The detailed representations are attached along with recommended alternative wording for Policy C3, to ensure that this is consistent with Paragraph 97 of the NPPF and therefore can meet the test of soundness set out within Paragraph 182 of the NPPF.
OBJECT Define (on behalf of Bovis Homes) (Mr Mark Rose) represented by Define (on behalf of Bovis Homes) (Mr Mark Rose)
Bovis Homes object to Policy C3, which is considered unsound on the basis that it:
- is not effective as a means of ensuring development mitigates climate change without unduly restricting the viability and/or delivery of development; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure the housing requirements are not prohibitive to the delivery of development.
OBJECT Royal Society For Protection Of Birds (RSPB) (Mr Colin Wilkinson)
While we support the intention behind policy C3 we feel we must question whether, in practice, it will lead to any decisions allowing any significant renewable energy scheme in the lifetime of this Plan. The need to act positively and quickly is so overwhelming that we advocate a different approach based on spatial planning to identify areas where applications for renewable energy developments of different types will be positively welcomed by the Council. We refer to the RSPB's 2050 Energy Vision report for a possible model to take forward.