Comment

Representation ID: 21302

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy CC7 – Renewable and Low Carbon Energy and BREAAM Standards
This Draft Policy seeks to ensure that a high standard of sustainable design is secured on all new developments over the Plan period, primarily through a list of requirements and standards. All proposals of ten or more homes are to achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document Part L 2013. In addition, they must incorporate generation of energy from renewable or low carbon sources sufficient to off-set at least 20% of the residual energy demand of the development on completion. It is advised that a variety of renewable and low-carbon energy sources and generation methods should be assessed and costed, including on-site and off-site sources where appropriate, and the use of district heat and / or decentralised energy networks. An energy assessment must be submitted. Some flexibility is provided in the case of viability issues and practical constraints resulting in the requirements being unachievable.

Whilst the principle of addressing climate change via the design of new dwellings is supported as part of overall sustainable development, the costs associated with the local policy requirements proposed should be fully accounted for within the Viability Assessment (in line with the (NPPF, paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509). Whilst the Viability Assessment appears to reflect these considerations (in table 3.5) it notes the need for the assessment to be kept under review, particularly in light of the COVID-19 pandemic. It is recognised that viability is now to be considered ‘up front’ as part of the Local Plan process; nevertheless as the Viability Assessment still represents primarily a typology based approach, the Council’s policies should continue to offer site and scheme specific flexibility (in line with the NPPF, paragraph 58).