Object

Representation ID: 44955

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy CC2 - Energy Infrastructure

22.1 Taylor Wimpey recognises the importance of mitigating and adapting to climate change but objects to Policy CC2 for the following reasons.

22.2 Parts 1 to 3 of Policy CC2 relate to decentralised energy networks. The requirements of the policy are vague and the provision of such networks on small to medium scale sites (the policy identifies a minimum of 10 homes or more) is not likely to be practical given size constraints and the viability implications of such provision. The reliance on connection to off-site sources is not practical as this may require connections through land outside of the ownership of the applicant and over which they have no control. Off-site sources which have not yet become operational would be particularly problematic as it would be difficult to guarantee that they would be available to serve the site when required or that they would be delivered and available for connection at all.

22.3 At present, the predominant technology for district-sized communal heating networks is gas combined heat and power (CHP). Meeting the Government’s climate target of reducing greenhouse gas emissions to net zero will require a transition from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery but at the moment one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. For the foreseeable future, it will remain uneconomic for most heat networks to install low-carbon technologies.

22.4 In addition, the information provided in the BCP Viability Study suggests that the provision of or connection to decentralised energy networks has not been factored into the viability assessment work. The viability implications of such provision have not therefore been adequately assessed.

22.5 We therefore consider that the policy requirements are not justified and suggest that the BCP Authorities consider whether Part 1 to 3 of the policy are necessary. The costs of the provision of or connection to decentralised energy networks will need to be properly considered in the Council’s viability evidence if this is to be pursued.