Comment

Representation ID: 44853

Received: 11/10/2021

Respondent: Ruskin Properties

It is unclear whether the requirement for small development to derive energy from renewable sources sufficient to off-set at least 10% of the estimated residual energy demand and for major development to achieve a 19% carbon reduction improvement from Part L of the Building Regulations has been factored into viability work undertaken as part of the plan. On what basis has the additional 19% been sought for the Black Country?
The policy requires a variety of renewable and low carbon energy sources and generation to be costed, including on and off-site sources. It would be difficult to achieve this level of input at the planning application stage due the technical stage of a scheme not having been reached. Given that many brownfield sites are on the margins of viability, it does not seem reasonable to seek standards for developments locally that will exceed standards sought by Building Regulations.
Like many of the aspirational policies on energy and low carbon it is unclear how these will be implemented or what information will be sought to support planning application submissions. Many of the policies appear to be requiring more and more up-front work to be prepared with planning applications prior to designs being finalised or planning permission being granted. This seems unreasonable at this stage. If such policies are to remain, these should form conditions to planning permissions.