Object

Representation ID: 23342

Received: 11/10/2021

Respondent: Bloor Homes

Proposed policy CC7 requires developments of 10 or more dwellings to achieve a 19% carbon
reduction improvement upon the requirements of Part L 2013, or any higher standard required under Building Regulations. Major developments should also generate energy from renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion. An energy assessment must be submitted with the planning application to demonstrate these requirements have been met. Only if the achievement of the target would make the proposal unviable, or if there are practical constraints, can the target be reduced.

BHL recognise that increasing the amount of energy from renewable and low carbon technologies will help to make sure there is a secure energy supply and reduce greenhouse gas emissions to slow down climate change. BHL considers that planning has an important role in the delivery of new renewable and low carbon energy infrastructure, however, policies should ensure that they follow nationally consistent set of standards/timetables and are implementable.

BHL are aware that there is now a clearer and quicker roadmap to a lower-carbon future for new homes following the results of The Future Homes Standard 2019 Consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) finally published in January 2021. BHL note that from June 2022, new homes will have a 31% reduction in CO2, when compared to current standards which will be stated in the new interim Part L and Part F Legislation (December 2021); before bigger changes in 2025 that will mean a 75% reduction in CO2 in new dwellings. Yet, the
Government’s own response to The Future Homes Standard Consultation admits that that the interim Part L won’t see an immediate increase to install heat pumps, simply because the skills and supply aren’t yet set up at this scale. The Government also confirmed that the Planning and Energy Act 2008 will not be amended and therefore, BHL are aware that the BCA can set local energy efficiency standards for new homes.

However, BHL consider that the BCA should comply with the Government’s intention of setting standards for energy efficiency through the Building Regulations. BHL believe that the success of achieving a low carbon future is by standardisation rather than individual Council’s specifying their own policy approach to energy efficiency. In addition, the BCA has not provided any evidence to specify these local standards and so this policy is not in accordance with paragraph 31 of the
NPPF. BHL consider that the BCA should not set their own local energy efficiency standards to achieve the shared net zero goal because of the higher levels of energy efficiency standards already proposed in
the 2021 Part L uplift and the Future Homes Standard 2025.