Comment

Draft Black Country Plan

Representation ID: 21356

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Representation Summary:

POLICY CC2 – ENERGY INFRASTRUCTURE
The intention of Policy CC2 is recognised by WDH. However, it is noted that the requirement for sites of 10 or more dwellings to “include opportunities for decentralised energy provision within the site” is not required by national policy and has not been justified based on proportionate evidence (in accordance with NPPF paragraph 35b).

Moreover, whilst the reference to any provision being subject to suitability, feasibility and viability is welcomed, it is important that the BCAs take that requirement into account in a full viability assessment should they proceed with including that policy requirement (if it is fully justified).