Comment

Draft Black Country Plan

Representation ID: 21209

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Representation Summary:

Policy CC2 – Energy Infrastructure

Parts 1 to 3 of this policy require new developments of 10 homes or more to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Where there is existing decentralised energy provision available close to the site, the development will be expected to link into it or should be designed to accommodate a subsequent connection.

Whilst Taylor Wimpey supports the principal of planning for development in ways which help, as much as possible, eliminate and mitigate greenhouse gas emissions, it has a number of concerns around the provisions of Policy CC2. Firstly, the assumption that developments can easily to offsite sources is problematic, as this may require connection through land outside of the ownership of the application and over which they have no control. As a result, it would be difficult to guarantee that such connections would be available to serve the site when required or that they would be available at all. In addition, the information provided in the BCP Viability Study suggests that the provision of or connection to decentralised energy networks has not been factored into the viability assessment work. The viability implications of such provision have not, therefore, been adequately assessed. The costs of provision or of connection to decentralised energy networks will need to be properly considered in the Council’s viability evidence if this is to be pursued.

Part 4 of the policy goes on to deal with proposals for on-site energy provision and the means by which this can be achieved. These provisions (parts a to j of the policy wording) are detailed, but not clearly justified and so seem somewhat over prescriptive. We would recommend that the policy wording be revised to encourage developers and energy companies / bodies to engage in the early stage of the development process to establish the likely future energy and infrastructure requirements, and to engage with the relevant BCP authorities to determine the most appropriate solution.