Policy TRAN8 Planning for Low Emission Vehicles  

Support

Representation ID: 10981

Received: 19/09/2021

Respondent: Jonathan Browning

Support, but there should be a firm and explicit commitment to support LEV through provision of charging points on residential public roads, either through dedicated charging points or adapting lampposts for example, which is being done in other parts of the UK. Could offer reserved parking on residential streets for EVs

Comment

Representation ID: 11100

Received: 14/09/2021

Respondent: Miss Anne Nicholls

By 2030, the Government has committed to only new electric cars, therefore there must be sufficient off road charging points. This will prevent charging cables being extended out across pavements. Charging cables across pavements are a trip hazard for not just disabled people but for others and must be avoided at all cost.

Comment

Representation ID: 11106

Received: 23/09/2021

Respondent: Mr Lars Nielsen

I am commenting about the Worcester Lane sites DUH206, DUH207 and DUH209.

The plan is to build 155 new houses, which will involve about 150 new cars. As petrol and diesel cars will be phased out soon after the houses are completed, the houses will need electric charging points.

Comment

Representation ID: 12306

Received: 07/10/2021

Respondent: Access in Dudley

• This point is very important
• Each housing unit built either single unit or multiple units, houses, or flats/apartments should have parking with electric car charging points
• Flats should have at least one allocated ‘off road’ parking space with an electrical car charging facility in view of the incoming requirement to move to carbon free proposals for transport and the fact that is it illegal to trail a charging lead across a public highway of which included a pavement.

Comment

Representation ID: 21206

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy TRAN8 – Planning for Low Emission Vehicles

This policy seeks to ensure that new developments include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks, measures to encourage LEV use through travel plans and other initiatives.

Our Client supports the provision of electric vehicle charging points in principle, but has significant concerns about the practicalities of delivery, in light of wider infrastructure constraints. The additional loading created by car charging infrastructure is significant and it is essential that the Black Country Authorities liaise with electricity providers as part of the Black Country Plan process so that the implications in terms of network capacity can be understood and planned for. It cannot be left to individual developers to pick up the cost of what could be multi-million-pound upgrades to the Black Country’s electricity infrastructure.

It will also be important for the policy wording to maintain some flexibility so that in cases where the provision of such infrastructure would make a scheme unviable, an exception can be made.

Comment

Representation ID: 21266

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy TRAN8 – Planning for Low Emission Vehicles
This policy requires that new developments should include adequate provision for charging infrastructure but there are no specific requirements noted. However, the Viability and Delivery Study (May 2021) has assumed £800 per dwelling for electric vehicle charging points therefore clarity is sought on whether a specific percentage of electric charging points are being sought on sites. The policy should only require provision of infrastructure to fit EV points rather than the points themselves and should include reference to ‘where possible’ given there may be viability or practicality constraints.

Comment

Representation ID: 21296

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy TRAN 8 – Planning for Low Emission Vehicles

Draft Policy TRAN8 sets out how proposals for low emission vehicles will be supported. Whilst we are supportive of the principle of encouraging low emission vehicle use and providing infrastructure to facilitate this, it is considered that the current policy wording is too vague, particularly in relation to the provision of charging infrastructure. Paragraph 16d) of the NPPF states that Plans should contain policies that are unambiguous. Part a) of the Policy states that “adequate” provision for charging infrastructure should be provided as part of new developments, however it is not clear what is meant by this, as there is no indication / guidance as to what may be considered adequate. Without knowing what infrastructure may be required to be provided as part of new developments in relation to charging infrastructure, the viability implications cannot be fully understood. The Council should ensure that all of the anticipated development costs associated with all of the draft policies of the BCP have been taken into account, as required by National Policy (NPPF paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509). It is therefore considered that in order to ensure that the policy is realistic and deliverable, it should be amended to be more explicit in terms of what infrastructure will be expected to be delivered.

Comment

Representation ID: 21348

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY TRAN8 – PLANNING FOR LOW EMISSION VEHICLES
Policy TRAN8 states that proposals for low emissions vehicles will be supported by ensuring that new developments “include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks, measures to encourage LEV use through travel plans and other initiatives.”

Whilst the intention of this policy is recognised, it is considered more suitable for any requirement for electric vehicle charging points to be left to future updates to the Government’s Building Regulations, and for the policy to refer to that. Indeed, the Government’s ‘Electric Vehicle Charging in Residential & Non-Residential Buildings’ consultation set out the Government’s intention to implement a nationally standardised approach to EV charging through a new functional requirement under Schedule 1 to the Building Regulations 2010, with further guidance expected in late 2021. As such, Policy TRAN8 should not seek to pre-empt those requirements, which would be contrary to the Government’s desire to create a rationalised, streamlined system led by the Building Regulations rather than local requirements.

With that said, should Policy TRAN8 continue to pursue a policy requirement in relation to electric charging provision rather than referring to the Building Regulations, it is important that the policy clearly specifies what that requirement is (expressed as a percentage of dwellings) based upon evidence of need and reflective of current uptake. Should that approach be taken, the level of charging provision should be taken into account in a Viability Assessment that demonstrates that “the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Ref. 10-002-20190509). That assessment should take into account that electric vehicle charging can often be costly; particularly where residential plots are served by remote parking or where additional capacity is required in the local electricity grid to accommodate charging points. That matter should be considered carefully by the BCAs should they pursue a requirement.

Object

Representation ID: 21768

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

Draft Policy TRAN8, proposals for low emission vehicles will be supported by “ensuring that new developments include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks…”

3.13 As set out in the Department of Transport consultation on Electric Vehicle Charging in Residential & Non-Residential Buildings (ended on 7th October 2019), the Government's preferred option is the introduction of a new requirement for EVCPs under Part S of the Building Regulations. The inclusion of EVCP requirements within the Building Regulations will introduce a standardised consistent approach to EVCPs in new buildings across the country and supersede the BCA’s policy approach.

3.14 Until the introduction of proposed changes to Part S of the Building Regulations, St Philips considers that the physical installation of active EVCPs is inappropriate, as a passive cable and duct approach means that householders can later arrange and install an active EVCP of their choice.

3.15 NPPF paragraph 16d states that policies should be “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.” The policy should therefore be clearer in specifying if adequate provision for charging infrastructure is a requirement for a passive cable and duct approach or installation of active EVCPs.

3.16 Draft Policy TRAN8 is unsound because it fails the four tests of soundness as per NPPF paragraph 35 as it is not positively prepared, justified, effective and consistent with national policy

Support

Representation ID: 22281

Received: 21/01/2022

Respondent: Miss Jodi Stokes

8.3 Part A of draft Policy TRAN8 (Planning for Low Emission Vehicles) requires “that new developments include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks, measures to encourage LEV use through travel plans and other initiatives”. We agree that adequate provision should be made for low emission vehicles, as per paragraph 107 of the NPPF.

Object

Representation ID: 22295

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

3.12 Draft Policy TRAN8, proposals for low emission vehicles will be supported by “ensuring that new developments include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks…”
3.13 As set out in the Department of Transport consultation on Electric Vehicle Charging in Residential & Non-Residential Buildings (ended on 7th October 2019), the Government's preferred option is the introduction of a new requirement for EVCPs under Part S of the Building Regulations. The inclusion of EVCP requirements within the Building Regulations will introduce a standardised consistent approach to EVCPs in new buildings across the country and supersede the BCA’s policy approach.
3.14 Until the introduction of proposed changes to Part S of the Building Regulations, Investin considers that the physical installation of active EVCPs is inappropriate, as a passive cable and duct approach means that householders can later arrange and install an active EVCP of their choice.
3.15 NPPF paragraph 16d states that policies should be “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.” The policy should therefore be clearer in specifying if adequate provision for charging infrastructure is a requirement for a passive cable and duct approach or installation of active EVCPs.
3.16 Draft Policy TRAN8 is unsound because it fails the four tests of soundness as per NPPF paragraph 35 as it is not positively prepared, justified, effective and consistent with national policy

Comment

Representation ID: 22357

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

This policy seeks to ensure that new developments include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks, measures to encourage LEV use through travel plans and other initiatives.
Our Client supports the provision of electric vehicle charging points in principle, but has significant concerns about the practicalities of delivery, in light of wider infrastructure constraints. The additional loading created by car charging infrastructure is significant and it is essential that the Black Country Authorities liaise with electricity providers as part of the Black Country Plan process so that the implications in terms of network capacity can be understood and planned for. It cannot be left to individual developers to pick up the cost of what could be multi-million-pound upgrades to the Black Country’s electricity infrastructure.
It will also be important for the policy wording to maintain some flexibility so that in cases where the provision of such infrastructure would make a scheme unviable, an exception can be made.

Object

Representation ID: 22412

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

3.12 Draft Policy TRAN8, proposals for low emission vehicles will be supported by “ensuring that new developments include adequate provision for charging infrastructure e.g. electric vehicle charging points in car parks…”
3.13 As set out in the Department of Transport consultation on Electric Vehicle Charging in Residential & Non-Residential Buildings (ended on 7th October 2019), the Government's preferred option is the introduction of a new requirement for EVCPs under Part S of the Building Regulations. The inclusion of EVCP requirements within the Building Regulations will introduce a standardised consistent approach to EVCPs in new buildings across the country and supersede the BCA’s policy approach.
3.14 Until the introduction of proposed changes to Part S of the Building Regulations, St Philips considers that the physical installation of active EVCPs is inappropriate, as a passive cable and duct approach means that householders can later arrange and install an active EVCP of their choice.
3.15 NPPF paragraph 16d states that policies should be “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.” The policy should therefore be clearer in specifying if adequate provision for charging infrastructure is a requirement for a passive cable and duct approach or installation of active EVCPs.
3.16 Draft Policy TRAN8 is unsound because it fails the four tests of soundness as per NPPF paragraph 35 as it is not positively prepared, justified, effective and consistent with national policy

Comment

Representation ID: 22425

Received: 11/10/2021

Respondent: Mr Maurice Sanders

Agent: Avison Young

Policy TRAN8 – Planning for Low Emission Vehicles
This policy seeks to ensure that new developments include adequate provision for charging
infrastructure e.g. electric vehicle charging points in car parks, measures to encourage LEV use
through travel plans and other initiatives.
Our Client supports the provision of electric vehicle charging points in principle, but has significant
concerns about the practicalities of delivery, in light of wider infrastructure constraints. The
additional loading created by car charging infrastructure is significant and it is essential that the
Black Country Authorities liaise with electricity providers as part of the Black Country Plan process
so that the implications in terms of network capacity can be understood and planned for. It cannot
be left to individual developers to pick up the cost of what could be multi-million-pound upgrades
to the Black Country’s electricity infrastructure.
It will also be important for the policy wording to maintain some flexibility so that in cases where
the provision of such infrastructure would make a scheme unviable, an exception can be made.

Support

Representation ID: 22495

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

Paragraph 3.52 "Taylor Wimpey supports the provision of electric vehicle charging points in principle."

Object

Representation ID: 22496

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

Paragraphs 3.51-3.53 "The additional loading created by car charging infrastructure is significant and it is essential that the Black Country Authorities liaise with electricity providers as part of the Black Country Plan process so that the implications in terms of network capacity can be understood and planned for. It cannot be left to individual developers to pick up the cost of what could be multi-million-pound upgrades to the Black Country’s electricity infrastructure."

Comment

Representation ID: 23064

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy TRAN8 – Planning for Low Emission Vehicles
This policy requires that new developments should include adequate provision for charging infrastructure but there are no specific requirements noted. However, the Viability and Delivery Study (May 2021) has assumed £800 per dwelling for electric vehicle charging points therefore clarity is sought on whether a specific requirement is being sought. The policy should include reference to ‘where possible’ given there may be viability or practicality constraints.

Comment

Representation ID: 23334

Received: 11/10/2021

Respondent: Bloor Homes

Proposed Policy TRAN8 seeks to ensure that new developments include adequate provision for charging
infrastructure. Whilst BHL supports the scope of Policy TRAN8 and recognises the importance of a low carbon future, BHL are aware that the Government is seeking to introduce a new requirement for EVCP’s under Part S of the Building Regulations, which will inevitably supersede BCA’s policy approach.

Moreover, BHL requests an explanation on what is meant by “adequate provision”. In accordance with NPPF paragraph 16d, a policy should be “clearly written and unambiguous, so it is evident how a decision maker should react to development proposals”. If this policy is to be included in the BCP, it needs to modified to ensure that it is measurable to ensure consistency between planning applications and allow developers to take into account the implication of the requirement on scheme
viability.

Object

Representation ID: 43874

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

10.12 Policy TRAN8 (Planning for Low Emission Vehicles) requires developments to include 'adequate provision' for charging infrastructure. Whilst Taylor Wimpey is supportive of the transition towards electric vehicles (EVs) and the provision of EV infrastructure, it is considered that 'adequate provision' is vague and not clear and therefore does not accord with the requirements of with Paragraph 16 d of the NPPF ("Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals."). If it is the expectation that all development should include EV charging infrastructure, then Policy TRAN8 should be explicit that that is the case.

Comment

Representation ID: 44945

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy TRAN8 - Planning for Low Emission
Vehicles

16.1 Policy TRAN8 states that proposals for low emission vehicles will be supported by ensuring that new developments include adequate provision for charging infrastructure.

16.2 The Viability and Delivery Study does not appear to apply any cost to this policy requirement
but does cover electric vehicle charging points under Policy CC4. It notes that the current policy is for one electric vehicle charging point required for each home, where feasible and viable, as
set out in Black Country Air Quality SPD and states:

“For the purposes of our viability assessment, we have included £800 per unit for EV charging (and £5,000 for a multi-charging point for every 4 x flats). This is based on the Wolverhampton average cost”.

16.3 Typically, the provision of car charging points will require higher voltage cabling to be installed throughout the site, resulting in higher on-site infrastructure costs. The policy requirement as drafted is also onerous given that there can be varying requirements for the provision of car charging points across developments with some LPAs requiring the necessary infrastructure to be in place and others to deliver the actual charging point.

16.4 It is also possible that capacity for such voltage will not be available on the current network and therefore the costs to upgrade the network can be significant, requiring on site substations or off-site primary substation upgrades. These costs are extremely difficult to quantify and can exceed hundreds of thousands of pounds dependent on site size and current service capacity. This scenario is untested in the Viability and Delivery Study and should be considered further, particularly as the expectation to have usable and fit for purpose EVCPs is going to increase.

16.5 We also understand that the Government is proposing to introduce requirements for charging points under Schedule 1 to the Building Regulations 2010, which are expected to come into force in 2022. This will introduce a nationwide standardised approach to the provision of charging points in new buildings. It is therefore questionable whether this Policy is required as it will duplicate national policy. It is also considered that the £800 per unit under-estimates the actual cost for providing a charging point. The Government Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £1,000 per EVCP plus an automatic levy for upgrading networks capped at £3,600.

16.6 The Government’s intention is to ensure that the introduction of this requirement does not add such a burden on developers that certain developments become unviable.

Object

Representation ID: 44977

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

16.0 Policy TRAN8 - Planning for Low Emission
Vehicles
16.1 Policy TRAN8 states that proposals for low emission vehicles will be supported by ensuring that
new developments include adequate provision for charging infrastructure.
16.2 The Viability and Delivery Study does not appear to apply any cost to this policy requirement
but does cover electric vehicle charging points under Policy CC4. It notes that the current policy
is for one electric vehicle charging point required for each home, where feasible and viable, as
set out in Black Country Air Quality SPD and states:
“For the purposes of our viability assessment, we have included £800 per unit for EV charging
(and £5,000 for a multi-charging point for every 4 x flats). This is based on the
Wolverhampton average cost”.
16.3 Typically, the provision of car charging points will require higher voltage cabling to be installed
throughout the site, resulting in higher on-site infrastructure costs. The policy requirement as
drafted is also onerous given that there can be varying requirements for the provision of car
charging points across developments with some LPAs requiring the necessary infrastructure to
be in place and others to deliver the actual charging point.
16.4 It is also possible that capacity for such voltage will not be available on the current network and
therefore the costs to upgrade the network can be significant, requiring on site substations or
off-site primary substation upgrades. These costs are extremely difficult to quantify and can
exceed hundreds of thousands of pounds dependent on site size and current service capacity.
This scenario is untested in the Viability and Delivery Study and should be considered further,
particularly as the expectation to have usable and fit for purpose EVCPs is going to increase.
16.5 We also understand that the Government is proposing to introduce requirements for charging
points under Schedule 1 to the Building Regulations 2010, which are expected to come into force
in 2022. This will introduce a nationwide standardised approach to the provision of charging
points in new buildings. It is therefore questionable whether this Policy is required as it will
duplicate national policy. It is also considered that the £800 per unit under-estimates the actual
cost for providing a charging point. The Government Electric Vehicle Charging in Residential &
Non-Residential Buildings consultation estimated a cost of £1,000 per EVCP plus an automatic
levy for upgrading networks capped at £3,600.
16.6 The Government’s intention is to ensure that the introduction of this requirement does not add
such a burden on developers that certain developments become unviable.

Support

Representation ID: 45901

Received: 11/10/2021

Respondent: Transport for West Midlands

Firstly LEV’s should be changed to ZEV’s and this should take place across the entire Draft Black Country
Plan.

We fully support this policy but consideration of ZEV charging of public transport infrastructure may also be required for new developments. As part of the BSIP, by 2030, we aim to have nearly 90% of our regions 2,000 strong bus fleet zero emission.

Support

Representation ID: 46189

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Vulcan is supportive of encouraging a move away from fossil fuels vehicles through the introduction of all-electric and hybrid alternatives, as part of the West Midlands Combined Authority commitment to setting a 'net zero' emissions target by 2041, with a climate action plan being approved by the WMCA board by January 2020. This is set to be achieved through the to be achieved through amendments to the Building Regulations 2010, which suggests that there is no explicit need for policy TRAN 8 given the forthcoming standardised approach through building regulations.