Object

Draft Black Country Plan

Representation ID: 23357

Received: 30/09/2021

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

Representation Summary:

CC2 – Energy Infrastructure
2.13. 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.
2.14. 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.
2.15. 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.

2.16. 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.