Support

Representation ID: 22406

Received: 11/10/2021

Respondent: RCA Regeneration Ltd

HOU3 - Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing
2.11. We are broadly supportive of the affordable housing policy but would suggest the policy is
slightly reworded to make it absolutely clear that those minimum proportions should only be
required where viability demonstrates it is deliverable. Setting minimum levels are laudable, but
unlikely to make a difference in reality if viability is an issue (as is the case on many BC sites).
2.12. We are broadly supportive of the requirements to make more homes accessible for disabled
people.
2.13. The 5% self-build requirement does raise some concerns, however – related to maintaining
health and safety on large housing sites, as well as in relation to the ultimate control over
phasing. Given the council’s strong reliance on windfall sites – many of which are likely to be self
or custom build, we cannot see why the council can justify requesting a proportion of self-build
on large housing developments that are proposed for allocation.
CC2 – Energy Infrastructure
2.14. We are concerned about the proposal to require a decentralised energy network on sites of 10
dwellings or more. We remain unconvinced that decentralised energy is always appropriate in
anything other than unconstrained, strategic level development sites (000’s rather than 00’s of
dwellings), and certainly not for smaller schemes.
2.15. This is because of the limitations this can place on the ultimate consumer – where decentralised
energy can limit consumer choice in terms of energy provider and where the consumer may
wish to add further energy saving measures – such as solar power, heat pumps, etc.

2.16. It is not clear from this policy why it would be beneficial: district heating systems have had a
mixed result, where residents have had to sign up for long term contracts of 25 years or more.
Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same,
so the larger the scheme, the more viable it could be. The industry itself is not regulated in the
same way and physical problems with a district heating system or decentralised energy system
can often result in whole areas being without heating or hot water for period of time.
2.17. We would therefore urge the BC authorities to reconsider the wording of this policy to
‘encourage’ the use of such systems, but not to stipulate that they must be used.