Comment

Representation ID: 21771

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

3.28 Draft Policy CC7 states that major developments creating ten or more homes must “achieve a
19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013, or achieve any higher standard than this that is required under new national planning policy or building regulations.”

3.29 St Philips supports the objective of achieving net zero carbon development but considers that the BCP should comply with the Government’s intention of achieving net zero carbon development through the Building Regulations. As such, the BCA’s proposed policy approach is unnecessary because of the higher levels of energy efficiency standards for new homes proposed in the 2021 Part L uplift and the Future Homes Standard 2025.

3.30 Draft Policy ENV9 is unsound because it fails the four tests of soundness as per NPPF
paragraph 35 as it is not positively prepared, justified, effective and consistent with national policy.