The document is a 3 page report regarding Issue 15 on layout and design principles in the development plan. It summarizes a representation made by Homes for Scotland requesting changes to paragraphs regarding low carbon technologies, energy efficiency, and greenhouse gas emissions. The planning authority rejects the requested changes, citing its requirements under the Climate Change Act and Scottish Planning Policy to incorporate policies addressing these issues in local plans.
The document is a 3 page report regarding Issue 15 on layout and design principles in the development plan. It summarizes a representation made by Homes for Scotland requesting changes to paragraphs regarding low carbon technologies, energy efficiency, and greenhouse gas emissions. The planning authority rejects the requested changes, citing its requirements under the Climate Change Act and Scottish Planning Policy to incorporate policies addressing these issues in local plans.
The document is a 3 page report regarding Issue 15 on layout and design principles in the development plan. It summarizes a representation made by Homes for Scotland requesting changes to paragraphs regarding low carbon technologies, energy efficiency, and greenhouse gas emissions. The planning authority rejects the requested changes, citing its requirements under the Climate Change Act and Scottish Planning Policy to incorporate policies addressing these issues in local plans.
Page 2 of 3 Issue 15 Layout and Design Principles Development Plan reference: Creating Sustainable Communities (Pages 36-37, Paragraphs 5.26, 5.28, 5.30) Reporter: Body or person(s) submitting a representation raising the issue (including reference number):
Homes for Scotland (CLDP041f, CLDP041g, CLDP041h)
Provision of the development plan to which the issue relates: Principles underpinning how Layout and Design will be delivered through the LDP. Planning Authoritys summary of the representation(s):
Homes for Scotland (CLDP041f, CLDP041g, CLDP041h) believe that reference to the use of low and zero carbon generating technologies should be removed from this section, and that some wording should be amended in order to highlight the role of planning in passive reduction of greenhouse gas emissions through layout, siting and design and not through materials and insulation.
Homes for Scotland also believes that the energy efficiency of housing units should be left to the regulations in Building Standards rather than planning. Homes for Scotland argues that in a fragile economy where the Scottish Government priority is to stimulate housing supply further burdens should not be added to the house building industry that make it uneconomic to build. This is especially applicable in a low value housing market such as Clackmannanshire where private housing sites are of marginal viability in many cases.
Modifications sought by those submitting representations:
Homes for Scotland (CLDP041f) believe that reference to the use of low and zero carbon generating technologies should be removed from paragraph 5.26.
Homes for Scotland (CLDP041g) request that paragraph 5.28 should be removed.
Homes for Scotland (CLDP041h) request and that paragraph 5.30 should have its wording amended to highlight Plannings role in the passive reduction of greenhouse gas emissions through layout, siting and design and not through materials and insulation.
Summary of responses (including reasons) by Planning Authority:
Homes for Scotland (CLDP041f) The Council stresses that local authorities, under the requirements of the Climate Change (Scotland) Act 2009 (CD015) currently in force, are required to address low and zero carbon generating technologies, and thus it would be inappropriate to remove the wording. Page 3 of 3
The specific requirement in Section 72 of the Act is, "A planning authority, in any local development plan prepared by them, must include policies requiring all developments in the local development plan area to be designed so as to ensure that all new buildings avoid a specified and rising proportion of the projected greenhouse gas emissions from their use, calculated on the basis of the approved design and plans for the specific development, through the installation and operation of low and zero-carbon generating technologies. Consequently, reference to low and zero-carbon generating technologies should not be removed from this paragraph. No changes are therefore sought to the LDP.
Homes for Scotland (CLDP041g) Homes for Scotland rightly observes that Section 72 of the Climate Change (Scotland) Act 2009 requires Local Authorities to incorporate carbon reduction policies within their local development plans. If the Act is amended as under Section 73 the Council would have to revise its policies but the requirement as it stands is as in Section 72. Consequently, this paragraph should not be removed. No changes are therefore sought to the LDP.
Homes for Scotland (CLDP041h) This refers to paragraph 5.30, but should refer to paragraph 5.29. Although Homes for Scotland argue that the energy efficiency of housing units should be a matter for Building Regulations rather than planning, the requirement stated in Scottish Planning Policy (SPP 2010) (paragraph 39) (CD001) is that, "Decisions on the layout and design of new development should encourage energy efficiency through the orientation and design of buildings, choice of materials and the use of low and zero carbon generating technologies". Consequently, the wording should not be amended. The draft SPP (CD002) published for consultation in 2013 made similar provision. No changes are therefore sought to the LDP.