Object

Representation ID: 44984

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

Policy CC2 - Energy Infrastructure
Taylor Wimpey recognises the importance Of mitigating and adapting to climate change but
objects to Policy CC2 for the following reasons.
parts 1 to 3 of policy CC2 relate to decentralised networks. The requil•ements 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.
At present, the predominant technology for district-sized communal heating networks is gas
combined heat and power (CHI'). 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.
In addition, the information provided in the BCP Viability Study suggests that the provision of
or connection to decentralised enerv networks has not been factored into the viability
assessment work. The viability implications Of such provision have not therefore been
adequately assessed.
We therefore consider that the policy requil•ements 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
or connection to decentralised enerw networks will need to be properly considered in the
Council's viability evidence ifthis is to be pursued.
Taylor Wimpey considers that part 4 Of the policy which relates to on-site enerw provision is
overly prescriptive and not clearly justified. We recognise the importance of engaging with
energy companies and bodies at an early stage in the development process to establish likely
future enerw and infrastructure requirements and welcome engagement with the relevant BCP
authorities on this matter. Howewer, it is not clear why the information set out in parts (a) to (i)
is required to identify a preferred solution and there is no clear justification for a number of the
requirements listed. We therefore consider that the final sentence of part 4 and parts (a) to (j) should be deleted.