Comment

Representation ID: 21357

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY CC7 – RENEWABLE AND LOW CARBON ENERGY AND BREEAM STANDARDS
The intention of Policy CC7 is recognised by WDH, who has adopted a holistic fabric-first approach in their house type design that seeks to reduce each dwelling’s inherent energy demand and aims to reduce energy waste and CO2 emissions by increasing energy efficiency.

However, as currently drafted the policy is not “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals” in accordance with NPPF paragraph 16d. For example, policy requirement 3a states that developments of 10 or more homes should “achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013, or achieve any higher standards than this that is required under new national planning policy or building regulations.” From that, however, it is not clear whether, at the point that the new national standards have been adopted, a 19% carbon reduction improvement will still be required, and whether a “higher standard” will then be required above that.

Notwithstanding that lack of clarity, requirements that go over and above the Government’s approved Building Regulations must be justified based on proportionate evidence, and should be taken into account in a Viability Assessment to ensure that the policy requirement, alongside the cumulative cost of other policy requirements, do not render developments unviable.

As such, it is suggested that Policy CC7 should not seek an uplift over and above the current Building Regulations given the lack of justification given, and also should not pre-empt any future Building Regulations requirements. Rather, it would be more suitable to seek adherence to “the Government’s latest Building Regulations”, which will ensure that the policy is not quickly rendered out-of-date or is not undeliverable.