Object

Representation ID: 43883

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.33 Policy CC2 sets out energy infrastructure requirements. It requires any development of 10 or more dwellings to include opportunities for decentralised energy provision. Where there is existing decentralised energy provision close to the site, the development will be expected to link into it or be designed to accommodate a subsequent connection. This policy, in effect, requires all major developments to provide for renewable energy or for a connection into a district heat system.
11.34 Whilst Taylor Wimpey is supportive of the general policy approach, the Policy should make clear that a 'fabric first' method of reducing energy usage is preferable and most efficient. This approach also utilises existing well-tested technology, whereas some forms of energy generation have been adversely affected by products which are quickly obsolete or result in system failure.
11.35 The Policy goes on to refer to developments of 100 homes or more having energy provision developed and agreed between the Local Planning Authority and developer to establish the lowest lifetime carbon energy provision. The Policy identifies 10 individual requirements with regards to energy provision. Taylor Wimpey supports the need to minimise energy usage but question the approach taken in Policy CC2 which is requiring a number of specific energy elements to be analysed in an environment where much of both the technology and in particular ability to deliver items such as combined heat and power are at tentative early stages. Indeed, no reference is made in the Plan to any existing provision of combined heat and power within the Black Country and whilst it is understood that the plan is aspirational in this regard and that there is an overwhelming need to move towards a carbon neutral economy, providing a development plan policy with such specific requirements in an environment where there is little experience or existing provision points to a lack of evidence.
11.36 Instead, it is submitted that matters relating to the energy usage and efficiency of dwellings is deferred to Part L of Building Regulations and the roadmap to zero carbon and future homes standard.