Comment

Representation ID: 23073

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CC7 – Renewable and Low Carbon Energy and BREEAM Standards
The Policy requires that major developments should achieve a 19% carbon reduction improvement and incorporate renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion. These requirements are considered to be over and above the requirements of PPG which states that Local Plans “can set energy performance standards for new housing or the adaptation of buildings to provide dwellings, that are higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes” (Reference ID: 6-012-20190315).
The PPG also states that if a Council is “considering policies on local requirements for the sustainability of other buildings, local planning authorities will wish to consider if there are nationally described standards and the impact on viability of development” (Reference ID: 6-009-20150327). The Viability and Delivery Study (May 2021) has assumed £4,615 per unit for this policy. We consider that this is a significant amount of money per dwelling just to meet energy requirements without any of the other requirements being sought in the plan to be taken into account e.g. affordable housing, specialist housing, accessible dwellings, Green – Belt compensation and other S106 contributions and CIL monies that will be sought by the Council and statutory consultees.
In relation to developments providing at least 20% of energy from renewables, consideration should be given to the capital cost and land take involved to achieve this requirement which we do not consider has been undertaken in the Council’s evidence base. Furthermore, it should be noted that it is now the case that sourcing energy from the National Grid can actually, in some cases be more sustainable than small scale renewable energy production as each year they are sourcing more of their energy from renewable sources.
We consider that the policy should be amended to ‘encourage’ development to apply the energy hierarchy to reduce energy demand and minimize carbon dioxide emissions. The policy should state that this will be subject to viability and suitability considerations at the application stage.