Comment

Representation ID: 21348

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY TRAN8 – PLANNING FOR LOW EMISSION VEHICLES
Policy TRAN8 states that proposals for low emissions vehicles will be supported by ensuring that new developments “include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks, measures to encourage LEV use through travel plans and other initiatives.”

Whilst the intention of this policy is recognised, it is considered more suitable for any requirement for electric vehicle charging points to be left to future updates to the Government’s Building Regulations, and for the policy to refer to that. Indeed, the Government’s ‘Electric Vehicle Charging in Residential & Non-Residential Buildings’ consultation set out the Government’s intention to implement a nationally standardised approach to EV charging through a new functional requirement under Schedule 1 to the Building Regulations 2010, with further guidance expected in late 2021. As such, Policy TRAN8 should not seek to pre-empt those requirements, which would be contrary to the Government’s desire to create a rationalised, streamlined system led by the Building Regulations rather than local requirements.

With that said, should Policy TRAN8 continue to pursue a policy requirement in relation to electric charging provision rather than referring to the Building Regulations, it is important that the policy clearly specifies what that requirement is (expressed as a percentage of dwellings) based upon evidence of need and reflective of current uptake. Should that approach be taken, the level of charging provision should be taken into account in a Viability Assessment that demonstrates that “the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Ref. 10-002-20190509). That assessment should take into account that electric vehicle charging can often be costly; particularly where residential plots are served by remote parking or where additional capacity is required in the local electricity grid to accommodate charging points. That matter should be considered carefully by the BCAs should they pursue a requirement.