Policy CC2 – Energy Infrastructure

Object

Representation ID: 11911

Received: 10/10/2021

Respondent: Ms Julie Edwards

We need re think on housing. All no builds should have solar panels, air pump heating as standard

Comment

Representation ID: 18033

Received: 11/10/2021

Respondent: Mr D S Golden

Environment As we relay on outher countrys for Gas and Ele as seen on TV relay on outher contrys to much if possible all housing flats or building old and new council and private should have solor panles fitted on roofs payid for by council & government conposray fitment starting asap free power clean energy should solve some of power problems put small wind turbine on roofs or in gardens as well as for cars hydro power only water comes out of exhust pipe instead of ele power no plug in cars less cost

Support

Representation ID: 20971

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.22 to 10.23 - Generally supportive but proposes an amendment for the preference of a fabric first method.

Object

Representation ID: 20974

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.24 - "L&Q Estates support the need to minimise energy usage but question the approach taken in Policy CC2 which is requiring a number of specific energy elements to be analysed in an environment where much of both the technology and in particular ability to deliver items such as combined heat and power are at tentative early stages."

Comment

Representation ID: 21209

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy CC2 – Energy Infrastructure

Parts 1 to 3 of this policy require new developments of 10 homes or more to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Where there is existing decentralised energy provision available close to the site, the development will be expected to link into it or should be designed to accommodate a subsequent connection.

Whilst Taylor Wimpey supports the principal of planning for development in ways which help, as much as possible, eliminate and mitigate greenhouse gas emissions, it has a number of concerns around the provisions of Policy CC2. Firstly, the assumption that developments can easily to offsite sources is problematic, as this may require connection through land outside of the ownership of the application and over which they have no control. As a result, it would be difficult to guarantee that such connections would be available to serve the site when required or that they would be available at all. 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. The costs of provision or of connection to decentralised energy networks will need to be properly considered in the Council’s viability evidence if this is to be pursued.

Part 4 of the policy goes on to deal with proposals for on-site energy provision and the means by which this can be achieved. These provisions (parts a to j of the policy wording) are detailed, but not clearly justified and so seem somewhat over prescriptive. We would recommend that the policy wording be revised to encourage developers and energy companies / bodies to engage in the early stage of the development process to establish the likely future energy and infrastructure requirements, and to engage with the relevant BCP authorities to determine the most appropriate solution.

Support

Representation ID: 21252

Received: 11/10/2021

Respondent: Newlands Developments

Policy CC2 (Energy Infrastructure) identifies that development proposals would need to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Such an approach is supported, given that the policy suitably reflects that opportunities for decentralised energy provision may not always be appropriate or viable.

Comment

Representation ID: 21273

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy CC2 – Energy Infrastructure
This policy requires major development sites to include opportunities for decentralised energy provision site – subject to viability and practicality. Savills has worked on numerous strategic residential schemes where this approach has been suggested at the policy making stage. However, to date we have not found any examples that have been delivered viably by house builders. Further clarity is sought from the Council on the practicality of delivering decentralized energy provision on sites in conjunction with other policy requirements proposed.

Comment

Representation ID: 21356

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY CC2 – ENERGY INFRASTRUCTURE
The intention of Policy CC2 is recognised by WDH. However, it is noted that the requirement for sites of 10 or more dwellings to “include opportunities for decentralised energy provision within the site” is not required by national policy and has not been justified based on proportionate evidence (in accordance with NPPF paragraph 35b).

Moreover, whilst the reference to any provision being subject to suitability, feasibility and viability is welcomed, it is important that the BCAs take that requirement into account in a full viability assessment should they proceed with including that policy requirement (if it is fully justified).

Object

Representation ID: 21826

Received: 11/10/2021

Respondent: Dr Osman Dervish

Agent: RCA Regeneration Ltd

2.13. We are concerned about the proposal to require a decentralised energy network on sites of 10 dwellings or more. We remain unconvinced that decentralised energy is always appropriate in anything other than unconstrained, strategic level development sites (OOO's rather than OO's of dwellings), and certainly not for smaller schemes.
2.14. This is because of the limitations this can place on the ultimate consumer -where decentralised energy can limit consumer choice in terms of energy provider and where the consumer may wish to add further energy saving measures - such as solar power, heat pumps, etc.
2.15. It is not clear from this policy why it would be beneficial: district heating systems have had a mixed result, where residents have had to sign up for long term contracts of 25 years or more. Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same, so the larger the scheme, the more viable it could be. The industry itself is not regulated in the same way and physical problems with a district heating system or decentralised energy system can often result in whole areas being without heating or hot water for period of time.
2.16. We would therefore urge the BC authorities to reconsider the wording of this policy to
'encourage' the use of such systems, but not to stipulate that they must be used. CC7 - Renewable and Low Carbon Energy and BREEAM Standards
2.17. We consider that, linked to the above policy CC2, the aims of CC7 are laudable, it is clear that there is some duplication between this planning policy and Building Regulations, which are delivered in any case. There are therefore elements of this policy which are not particularly justified or necessary, insofar as they effectively repeat Building Regulations requirements.

Support

Representation ID: 21827

Received: 11/10/2021

Respondent: Dr Osman Dervish

Agent: RCA Regeneration Ltd

2.13. We are concerned about the proposal to require a decentralised energy network on sites of 10 dwellings or more. We remain unconvinced that decentralised energy is always appropriate in anything other than unconstrained, strategic level development sites (OOO's rather than OO's of dwellings), and certainly not for smaller schemes.
2.14. This is because of the limitations this can place on the ultimate consumer -where decentralised energy can limit consumer choice in terms of energy provider and where the consumer may wish to add further energy saving measures - such as solar power, heat pumps, etc.
2.15. It is not clear from this policy why it would be beneficial: district heating systems have had a mixed result, where residents have had to sign up for long term contracts of 25 years or more. Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same, so the larger the scheme, the more viable it could be. The industry itself is not regulated in the same way and physical problems with a district heating system or decentralised energy system can often result in whole areas being without heating or hot water for period of time.
2.16. We would therefore urge the BC authorities to reconsider the wording of this policy to
'encourage' the use of such systems, but not to stipulate that they must be used. CC7 - Renewable and Low Carbon Energy and BREEAM Standards
2.17. We consider that, linked to the above policy CC2, the aims of CC7 are laudable, it is clear that there is some duplication between this planning policy and Building Regulations, which are delivered in any case. There are therefore elements of this policy which are not particularly justified or necessary, insofar as they effectively repeat Building Regulations requirements.

Object

Representation ID: 22164

Received: 06/10/2021

Respondent: Marlie Civils

Agent: RCA Regeneration Ltd

We are concerned about the proposal to require a decentralised energy network on sites of 10 dwellings or more. We remain unconvinced that decentralised energy is always appropriate in anything other than unconstrained, strategic level development sites {OOO's rather than OO's of dwellings), and certainly not for smaller schemes.

2.26. This is because of the limitations this can place on the ultimate consumer -where decentralised energy can limit consumer choice in terms of energy provider and where the consumer may wish to add further energy saving measures - such as solar power, heat pumps, etc.

2.27. It is not clear from this policy why it would be beneficial: district heating systems have had a mixed result, where residents have had to sign up for long term contracts of 25 years or more. Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same, so the larger the scheme, the more viable it could be. The industry itself is not regulated in the same way and physical problems with a district heating system or decentralised energy system can often result in whole areas being without heating or hot water for period of time.

2.28. We would therefore urge the BC authorities to reconsider the wording of this policy to
'encourage' the use of such systems, but not to stipulate that they must be used.

Comment

Representation ID: 22198

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

We object to the requirement that all developments of 10 or more houses or more than 1,000 square metres should include opportunities for decentralised energy provision. Whilst in theory the use of decentralised energy has a number of sustainability benefits, the reality is that incorporating it in new development is very difficult and expensive on small schemes making it unviable. Similarly, the end user i.e. home owners, commonly have next to no experience of using shared heating systems and this can often by a detractor. As such, there is no desire to develop the technology as ultimately there is no demand from the purchasers.

Object

Representation ID: 22221

Received: 11/10/2021

Respondent: Steve Crutchley

Policy CC2 – Energy Infrastructure

We object to the requirement that all developments of 10 or more houses or more than 1,000 square metres should include opportunities for decentralised energy provision. Whilst in theory the use of decentralised energy has a number of sustainability benefits, the reality is that incorporating it in new development is very difficult and expensive on small schemes making it unviable. Similarly, the end user i.e. home owners, commonly have next to no experience of using shared heating systems and this can often by a detractor. As such, there is no desire to develop the technology as ultimately there is no demand from the purchasers.

Support

Representation ID: 22288

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Energy Infrastructure

9.7 Draft Policy CC2 (Energy Infrastructure) requires that “any development including ten homes or more, or non-residential floorspace of 1,000 sqm or more must include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks”. We consider that this requirement complies with paragraph 157 of the NPPF.

Comment

Representation ID: 22363

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

Parts 1 to 3 of this policy require new developments of 10 homes or more to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Where there is existing decentralised energy provision available close to the site, the development will be expected to link into it or should be designed to accommodate a subsequent connection. Whilst Taylor Wimpey supports the principal of planning for development in ways which help, as much as possible, eliminate and mitigate greenhouse gas emissions, it has a number of concerns around the provisions of Policy CC2. Firstly, the assumption that developments can easily to off-site sources is problematic, as this may require connection through land outside of the ownership of the application and over which they have no control. As a result, it would be difficult to guarantee that such connections would be available to serve the site when required or that they would be available at all. 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. The costs of provision or of connection to decentralised energy networks will need to be properly considered in the Council’s viability evidence if this is to be pursued.
Part 4 of the policy goes on to deal with proposals for on-site energy provision and the means by which this can be achieved. These provisions (parts a to j of the policy wording) are detailed, but not clearly justified and so seem somewhat over prescriptive. We would recommend that the policy wording be revised to encourage developers and energy companies / bodies to engage in the early stage of the development process to establish the likely future energy and infrastructure requirements, and to engage with the relevant BCP authorities to determine the most appropriate solution.

Object

Representation ID: 22513

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

Paragraph 3.57-3.59 Off site decentralised energy provision may be out of the control of landowners and have viability issues which the policy viability evidence has not considered. "Part 4 of the policy goes on to deal with proposals for on-site energy provision and the means by which this can be achieved. These provisions (parts a to j of the policy wording) are detailed, but not clearly justified"

Comment

Representation ID: 23071

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CC2 – Energy Infrastructure
This policy requires major development sites to include opportunities for decentralised energy provision site – subject to viability and practicality. Savills has worked on numerous strategic residential schemes where this approach has been suggested at the policy making stage. However, to date we have not found any examples that have been delivered viably by house builders. Further clarity is sought from the Council on the practicality of delivering decentralized energy provision on sites in conjunction with other policy requirements proposed.

Comment

Representation ID: 23090

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust’s waterways provide a heat source that can be effectively used to provide heat and hot water to adjacent developments using water sourced heat pumps. We welcome the expectation in policy CC2 that heat sources for a communal heating system should be chosen to minimise likely emissions. The use of fossil fuels and all forms of energy generation that rely upon the combustion of carbonaceous feedstocks will need to be phased out and replaced by zero carbon, non-polluting and energy-efficient sources. Sustainably maximising the use of heat extraction from the canal network should have a valuable role to play in this.

The expectation that eat sources for a communal heating system should be chosen to minimise likely emissions could be strengthened by setting out a hierarchy against which developers and decision makers will be expected to assess proposals. Such an approach is set out in policy SI 3 (D) of the recently adopted
London Plan. It gives preference to zero-emission and local secondary heat sources over lower emission solutions like combined heat and power. The definition of secondary heat within the plan includes heat that exists naturally within the environment (air, ground and water)

Object

Representation ID: 23319

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We object to the requirement that all developments of 10 or more houses or more than 1,000 square metres should include opportunities for decentralised energy provision. Whilst in theory the use of decentralised energy has a number of sustainability benefits, the reality is that incorporating it in new development is very difficult and expensive on small schemes making it unviable. Similarly, the end user i.e. home owners, commonly have next to no experience of using shared heating systems and this can often be a detractor. As such, there is no desire to develop the technology as ultimately there is no demand from the purchasers.

Comment

Representation ID: 23337

Received: 11/10/2021

Respondent: Bloor Homes

Proposed Policy CC2 requires development of 10 or more dwellings to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Where there is existing decentralised energy provision in close proximity to the site, the development will be required to connect to it or should be designed to accommodate a subsequent connection if a source
has not yet become operational.

BHL are aware that decentralised energy networks can deliver benefits, including low carbon heat to residents, helping to reduce the carbon footprint. Yet, notwithstanding its merits, there are certain difficulties in its application. For example, in the case of communal heat networks, currently the predominant technology for district-sized communal heating networks is still gas
combined heat and power (‘CHP’). The alternatives of large heat pumps, hydrogen or waste-heat recovery has been relatively slow on the uptake by heat network projects due to the large up-front capital cost. BHL consider that this will remain uneconomic for most heat networks to install low-carbon technologies for the foreseeable future.

Furthermore, BHL are aware of some reports and research that states that biomass renewable energy
plants are one of the biggest single sources of carbon dioxide and PM10 (particulate matter of 10 micrometres and smaller) air pollution of all EU power stations- more so than some of Europe’s Coal Plants. The UK Government treats bioenergy as immediately carbon neutral on the assumption that forest regrowth soaks up the carbon again but recent science disputes its carbon neutrality. BHL considers that more research needs to be done before decentralised energy provision is mandatory in local planning policy.

Object

Representation ID: 23357

Received: 30/09/2021

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

CC2 – Energy Infrastructure
2.13. We are concerned about the proposal to require a decentralised energy network on sites of 10
dwellings or more. We remain unconvinced that decentralised energy is always appropriate in
anything other than unconstrained, strategic level development sites (000’s rather than 00’s of
dwellings), and certainly not for smaller schemes.
2.14. This is because of the limitations this can place on the ultimate consumer – where decentralised
energy can limit consumer choice in terms of energy provider and where the consumer may
wish to add further energy saving measures – such as solar power, heat pumps, etc.
2.15. It is not clear from this policy why it would be beneficial: district heating systems have had a
mixed result, where residents have had to sign up for long term contracts of 25 years or more.
Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same,
so the larger the scheme, the more viable it could be. The industry itself is not regulated in the
same way and physical problems with a district heating system or decentralised energy system
can often result in whole areas being without heating or hot water for period of time.

2.16. We would therefore urge the BC authorities to reconsider the wording of this policy to
‘encourage’ the use of such systems, but not to stipulate that they must be used.

Comment

Representation ID: 23433

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.20 We are generally supportive of Draft Policies CC2 and CC7 which relate to the mitigation of, and adaptation to, climate change.

However, it is important to note that decentralised energy provision and renewable and low carbon energy dwellings may not always be practicable or viable in new developments. Therefore, we are supportive of Draft Policies CC2 and CC7 insofar as they allow for such requirements to be reduced where it can be clearly demonstrated that it is not practical or viable

Comment

Representation ID: 23526

Received: 11/10/2021

Respondent: Historic England

Development proposals will need to consider the harm to the historic environment and ensuring that any proposals protect the significance of heritage assets, including their setting.

Object

Representation ID: 43848

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

2.15. We are concerned about the proposal to require a decentralised energy network on sites of 10 dwellings or more. We remain unconvinced that decentralised energy is always appropriate in anything other than unconstrained, strategic level development sites (000’s rather than 00’s of dwellings), and certainly not for smaller schemes.

2.16. This is because of the limitations this can place on the ultimate consumer – where decentralised energy can limit consumer choice in terms of energy provider and where the consumer may wish to add further energy saving measures – such as solar power, heat pumps, etc.

2.17. It is not clear from this policy why it would be beneficial: district heating systems have had a mixed result, where residents have had to sign up for long term contracts of 25 years or more. Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same, so the larger the scheme, the more viable it could be. The industry itself is not regulated in the same way and physical problems with a district heating system or decentralised energy system can often result in whole areas being without heating or hot water for period of time.

2.18. We would therefore urge the BC authorities to reconsider the wording of this policy to ‘encourage’ the use of such systems, but not to stipulate that they must be used.

Object

Representation ID: 43883

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.33 Policy CC2 sets out energy infrastructure requirements. It requires any development of 10 or more dwellings to include opportunities for decentralised energy provision. Where there is existing decentralised energy provision close to the site, the development will be expected to link into it or be designed to accommodate a subsequent connection. This policy, in effect, requires all major developments to provide for renewable energy or for a connection into a district heat system.
11.34 Whilst Taylor Wimpey is supportive of the general policy approach, the Policy should make clear that a 'fabric first' method of reducing energy usage is preferable and most efficient. This approach also utilises existing well-tested technology, whereas some forms of energy generation have been adversely affected by products which are quickly obsolete or result in system failure.
11.35 The Policy goes on to refer to developments of 100 homes or more having energy provision developed and agreed between the Local Planning Authority and developer to establish the lowest lifetime carbon energy provision. The Policy identifies 10 individual requirements with regards to energy provision. Taylor Wimpey supports the need to minimise energy usage but question the approach taken in Policy CC2 which is requiring a number of specific energy elements to be analysed in an environment where much of both the technology and in particular ability to deliver items such as combined heat and power are at tentative early stages. Indeed, no reference is made in the Plan to any existing provision of combined heat and power within the Black Country and whilst it is understood that the plan is aspirational in this regard and that there is an overwhelming need to move towards a carbon neutral economy, providing a development plan policy with such specific requirements in an environment where there is little experience or existing provision points to a lack of evidence.
11.36 Instead, it is submitted that matters relating to the energy usage and efficiency of dwellings is deferred to Part L of Building Regulations and the roadmap to zero carbon and future homes standard.

Comment

Representation ID: 44852

Received: 11/10/2021

Respondent: Ruskin Properties

Criterion 4) in relation to future energy and infrastructure requirements places a significant burden on a developer at the planning application stage of a project when no certainty exists in relation to planning permission being secured. Whilst this strategic approach is acknowledged as important for large scale developments, the threshold of 100 homes seems to low. It is unlikely that energy providers will engage with this process at such an early stage with them requiring certainty on start dates, which without the benefit of planning permission will not be available.

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.

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.

Comment

Representation ID: 46197

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

20 Paragraph 16 of the Framework is clear that development plans should contain policies that are clearly written and unambiguous. Draft policy CC2 is not clear in respect of on what grounds applicants will be able to demonstrate that development is not suitable, feasible or viable for district heat or decentralised power networks. Draft policy CC2 needs to provide clear direction in this regard. It is also without justification why the threshold for compliance is ten units/1,000 sq. m and why there are no further thresholds at greater unit numbers/floorspace, which would allow for proportionate consideration of proposals relative to scale. The draft policy should be revised to remove ambiguity and introduce additional trigger thresholds to ensure that it is sound in the context of being clear and positively prepared.