Object

Representation ID: 43887

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.42 Policy CC7 relates to renewable and low-carbon energy. It states that major developments of 10 or more homes must achieve a 19% carbon reduction improvement over the requirements of the Building Regulations Part L 2013 or achieve any higher standard than this that is required under new national planning policy or Building Regulations and, in addition, incorporate generation of energy from renewable or low-carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development. This requirement would clearly impose a significant burden upon even relatively small scale proposals. The justification does not identify any evidence as to why 19% is the appropriate target. As is the case with other policies relating to energy generation and/or nature conservation, referring to either separate regulatory regimes or standards that are not currently in force, is not appropriate for a development plan policy.
11.43 In addition, it is also recognised in the justification of the policy (Paragraph 10.211) that the 20% renewable energy requirement will impact on some major developments within the Black Country from a viability perspective. If this is already acknowledged on the macro level, before site specific circumstances which can impose further development costs are established, then it is not sound to include a blanket policy requirement of this type. In addition, the justification indicates that as well as the 19% carbon reduction improvement required for major development under Policy CC7, the requirement for energy generation (20%) would be beyond the already discounted figures. This is unduly onerous and not backed up by evidence.