Comment

Representation ID: 46202

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

The supporting text to draft policy CC7 (paragraph 10.208) includes the caveat ‘…where financially viable’ to the requirement that major developments achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013. There will be reasons why some development cannot achieve 19% or there is a clear justification for it achieving a lesser carbon reduction. The policy text at CC7 (3a) does not include the same caveat, which it should do to ensure that there is consistency between the policy and supporting text and that the policy overall passes the test of soundness.

The support text (paragraph 10.210) also includes the caveat, in respect of all new development contributing towards renewable and low carbon energy generation, that this is where such a contribution is financially viable and feasible to implement. The draft policy text (at CC7 5a/5b) establishes the same caveats, and the same consistency needs to be applied in respect of carbon reduction at CC7 (3a).