Comment

Representation ID: 23334

Received: 11/10/2021

Respondent: Bloor Homes

Proposed Policy TRAN8 seeks to ensure that new developments include adequate provision for charging
infrastructure. Whilst BHL supports the scope of Policy TRAN8 and recognises the importance of a low carbon future, BHL are aware that the Government is seeking to introduce a new requirement for EVCP’s under Part S of the Building Regulations, which will inevitably supersede BCA’s policy approach.

Moreover, BHL requests an explanation on what is meant by “adequate provision”. In accordance with NPPF paragraph 16d, a policy should be “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals”. If this policy is to be included in the BCP, it needs to modified to ensure that it is measurable to ensure consistency between planning applications and allow developers to take into account the implication of the requirement on scheme
viability.