Object

Representation ID: 44985

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

23.0 Policy CC7 - Renewable and Low Carbon
Energy and BREEAM Standards
23.1 Taylor Wimpey objects Policy CC7 which requires that major developments creating ten or more
homes must:
a achieve a 19% carbon reduction improvement upon the requirements within Building
Regulations Approved Document, Part L 2013, or achieve any higher standard than
that is required under new national planning policy or building regulations;
b 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 on
completion.
23.2 It also requires assessment of the use of district heat and / or decentralised energy networks.
23.3 Taylor Wimpey recognises the benefits of reducing energy use and promoting renewable
technologies and meets Part L on all sites and regularly seeks efficiencies above the
recommended standard. However, we consider that no clear evidence has been provided in the
Draft BCP to confirm why a 19% reduction has been identified and why it is justified.
23.4 In addition, the policy relates to a proposed reduction in Building Regulation targets. The
control of emissions is controlled through Building Regulations and the application of a Local
Plan policy which seeks a reduction below these targets is not appropriate. In order to ensure
consistency with the Building Regulations, it is considered that any reduction in emissions
should be informed by up to date Building Regulations targets rather than through the
application of a local plan policy.
23.5 Taylor Wimpey also notes that no clear justification or evidence is provided for the 20%
renewable or low carbon sources requirement in Part 3(b) of the policy. It appears that the BCP
authorities have selected an arbitrary figure for this requirement which is based on policy
aspiration only and is not supported by any evidence.
23.6 The justification text to the policy indicates that the 20% requirement should be applied to the
residual energy demand of the development, after application of the 19% carbon reduction
improvement required by policy CC7. The costs to developers of meeting these requirements
would therefore be significant .
23.7 The Viability Study indicates that cost applied to meet these standards is £4,615 per unit which
is the cost of Option 2 Part L Interim Uplift 2021. The cost of Future Homes Standard 2025 will
be much higher and further extra-over costs should be included. We also note that the BCP
Viability Study excludes any additional costs associated with compulsory connections to heat
networks.
23.8 Taylor Wimpey considers that the BCA should comply with the Government’s intention of
achieving net zero carbon development through the Building Regulations. The proposed policy
approach is unnecessary because of the higher levels of energy efficiency standards for new
homes proposed in the 2021 Part L uplift and the Future Homes Standard 2025.
23.9 Policy CC7 is considered to be contrary to the Framework [§35] as it is not justified and based on
proportionate evidence. In order to ensure that the Policy is sound Taylor Wimpey considers
that Parts 3, 4 and 5 of Policy CC7 should be deleted.