Object

Representation ID: 22295

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

3.12 Draft Policy TRAN8, proposals for low emission vehicles will be supported by “ensuring that new developments include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks…”
3.13 As set out in the Department of Transport consultation on Electric Vehicle Charging in Residential & Non-Residential Buildings (ended on 7th October 2019), the Government's preferred option is the introduction of a new requirement for EVCPs under Part S of the Building Regulations. The inclusion of EVCP requirements within the Building Regulations will introduce a standardised consistent approach to EVCPs in new buildings across the country and supersede the BCA’s policy approach.
3.14 Until the introduction of proposed changes to Part S of the Building Regulations, Investin considers that the physical installation of active EVCPs is inappropriate, as a passive cable and duct approach means that householders can later arrange and install an active EVCP of their choice.
3.15 NPPF paragraph 16d states that policies should be “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.” The policy should therefore be clearer in specifying if adequate provision for charging infrastructure is a requirement for a passive cable and duct approach or installation of active EVCPs.
3.16 Draft Policy TRAN8 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