Draft Black Country Plan

Comment

Representation ID: 44973

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

13.0 Policy HOU3 - Delivering Affordable,
Wheelchair Accessible and Self Build /
Custom Build Housing
Part 2
Part 2 of the Policy states that all developments of ten homes or more should provide a
proportion of affordable housing, where this is financially viable. It advises that the minimum
proportion of affordable housing that should be provided is:
a On all sites in lower value zones and brownfield sites in medium value zones: 10%
affordable housing;
b On greenfield sites in medium value zones: 20% affordable housing;
c On all sites in higher value zones: 30% affordable housing.
13.2 The 2021 Strategic Housing Market Assessment [SHMA] notes the following:
“The total annual affordable housing need in the Black Country of 867 per year (as set out in
Chapter 6) represents 21.6% of the annual dwelling growth of 4,019 in the housing market
area as assessed using the revised Standard Method. It would be reasonable to expect this
proportion of new housing as affordable to be delivered on a large housing site in the Black
Country, where a figure of 25% would be plausible (subject to viability). The Councils can
therefore be confident that the affordable housing need identified in the model will be
addressed by the dwelling growth identified by the Standard Method and no adjustment is
required to this figure”.
13.3 Whilst TW supports a differentiated approach to the provision of affordable housing to reflect
different value zones in principle, we note that the proposed percentages set out in Policy HOU3
are above the recommendations of the BCP Viability Study.
13.4 We would note that any affordable housing policy requirement needs to be tested though the
Viability evidence on an ongoing basis as the BCP progresses to ensure that it accounts for any
changes to policy requirements which may have a subsequent impact upon site viability.
13.5 It is also noted that the type and tenure of affordable housing sought is ambiguous. The
Framework (§16d) states that policies should be clearly written so that a decision maker knows
how to react to a development proposal. To be effective, the BCA should provide further
clarification of its requirements, which should be justified by supporting evidence.
Part 4
13.6 Part 4 of Policy HOU3 states that all developments of ten homes or more should provide a
proportion of wheelchair accessible housing, where this is financially viable. The stated
minimum proportion that should be provided on greenfield sites in medium or higher value
zones is 15% of homes to meet the optional Building Regulations Requirement M4(3):
Wheelchair User Dwellings and all remaining homes to meet the optional Building Regulations
Requirement M4(2): Accessible and Adaptable Dwellings.
13.7 Whilst Taylor Wimpey generally supports the provision of homes that are suitable to meet the
needs of older people and disabled people in principle, we object to Part 4 of the policy as we are
concerned that the standards proposed are not fully justified and do not accord with the Practice
Guidance25. The evidence on future need provided in the 2021 SHMA does not support the
proportions identified in the policy.
13.8 For M4(3): Wheelchair User Dwellings, the SHMA26 indicates that 1,674 dwellings are required
in 2039. It states that 1,456 should be in the general housing stock and 217 in supported
accommodation. It indicates that by the end of the plan period, around about 0.3% of the total
stock should be available to meet this criteria. However, there is no clear explanation as to how
a 15% policy requirement has been derived from this identified need. In addition, it provides no
information on the availability of existing stock to meet this need and does not consider the
potential for the conversion of existing properties either. The actual likely requirement is
therefore likely to be significantly lower than this.
13.9 The evidence does not identify any local circumstances, which demonstrate that the needs of the
Black Country differ substantially to those across the West Midlands or England. If the
Government had intended that evidence of an ageing population alone justified adoption of
optional standards, then such standards would have been incorporated as mandatory in the
Building Regulations, which is not currently the case.
13.10 The evidence provided does not therefore justify the 15% requirement identified. In addition,
we note that the policy identifies no requirement for the provision of M4(3) dwellings in lower
value zones. This does not make any sense as the need for these properties will inevitably be
spread through all parts of the BCP area, not just the higher value areas.
13.11 Taylor Wimpey considers that the most effective way to provide sufficient housing to meet
M4(3) category requirements in the correct locations would be to increase the proportion of this
type of accommodation in specialist housing for older people. This could involve the allocation
of specific sites to help meet this need. We recognise that not all wheelchair housing will be
provided through such specialist housing and consider that any requirements for M4(3)
dwellings on market housing sites could be based on assessments of local need at the time of a
planning application.
13.12 For M4(2): Accessible and Adaptable Dwellings, the SHMA identifies that in total 17,866
accessible and adaptable homes are required in 2039 across the Black Country. However,
limited evidence has been provided on the size, location, and quality of dwellings needed to
address the need identified and it is not therefore clear what requirements are and how they
differ across the different authority areas.
13.13 Taylor Wimpey is also concerned that the suitability of existing housing stock has not been
properly assessed against the future requirements identified. In this regard, the SHMA notes27
that there is not a detailed profile of the current stock from which to derive a net requirement.
In addition, the SHMA28 recognises that the Councils help people to remain in their current
home and any adaptions to dwellings provided through this mechanism could reduce the
requirement for new homes meeting the M4(2) standard. Improvements to existing homes
funded through Disabled Facilities Grants will inevitably contribute towards this uplift, reducing
the need for provision in new housing stock.
13.14 The requirement in Policy HOU3 for all remaining homes to meet the optional Building
Regulations Requirement M4(2) is therefore completely unjustified.
13.15 It is important to note that not all health issues affect housing needs. Many older people already
live in the Black Country and are unlikely to move home. No evidence is presented to suggest
25 Planning Practice Guidance ID: 56-007-20150327
26 The Black Country Housing Market Assessment – March 2021 §7.40
27 The Black Country Housing Market Assessment – March 2021 §7.38
28 The Black Country Housing Market Assessment – March 2021 §7.42
that households already housed would be prepared to leave their existing homes to move into
new dwellings constructed to M4(2) and / or M4(3) standards. Adaption of existing stock will
form an important part of the solution.
13.16 For the above reasons, we consider that the percentage provisions for M4(2) housing and M4(3)
housing have not been fully justified and cannot be sought through Part 4 of the policy.
Part 6
13.17 Part 6 of the policy states that on developments of 100 homes or more, where there is currently
a need for self-build and custom build plots identified in the self-build and custom build register
for the local authority where the site is located, at least 5% of plots should be made available for
self-build or custom build, or sufficient to match the current number on the register if lower.
Whilst it is accepted that new development should contribute to achieving an appropriate mix of
housing, Taylor Wimpey objects to Part 6 for a number of reasons.
13.18 Councils have a legal obligation to grant sufficient planning permissions to meet the demand for
self and custom build properties. Taylor Wimpey considers the current policy approach to be
ineffective because it would not guarantee that the Council’s obligation to ensure enough self
and custom build properties have been provided to meet demand. It cannot be known what
level of provision will be achieved on schemes by market housing developers and when; and
therefore, the Council cannot rely on these sites as their supply for self-build and custom-build
housing.
13.19 The evidence provided in the SHMA also indicates that demand is low across the Black Country
with only 32 individuals on the self-build register in Walsall and 8 in Dudley. Data from the Self
Build Portal also indicates that demand is lower than average. There is therefore no clear
justification for the 5% requirement identified.
13.20 Market Housing development and Self or custom build rarely work together. Providing self or
custom build on market housing sites is unlikely to work and will severely impact upon a
scheme layout. It will also create issues with the apportionment of planning obligations
between the housing market area and self -build plots. In addition, it is unlikely that self and
custom build serviced plots on residential sites of more than 100 dwellings will appeal to those
wishing to build their own home. No justification has been provided for the 10 dwelling
threshold identified either.
13.21 In addition, the impact of this policy requirement on scheme viability does not appear to have
been considered in the BCP Viability Study.
13.22 Taylor Wimpey therefore considers that this policy requirement should be deleted and the
Councils should identify stand alone sites which are specifically allocated to meet the local
demand for self and custom build dwellings.
Parts 7 and 8
The option to provide to provide financial viability assessments where affordable housing or
wheelchair accessibility requirements can be demonstrated to make the development unviable,
is welcomed. However, the BCP authorities should ensure that this situation is avoided where
possible by ensuring the requirements of the policy are properly justified and tested through the
viability evidence informing the BCP.

Comment

Representation ID: 44974

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

14.0 Policy HOU5 - Education Facilities
14.1 Part 2 of Policy HOU5 states that where a housing development of ten or more homes would
increase the need for education facilities to the extent that new or improved facilities would be
required to meet this need, planning obligations or Community Infrastructure Levy will be
secured sufficient to meet the need, where this is financially viable. For strategic allocations, it
states that the likely requirement for on-site provision of new schools is set out in Chapter 13. In
this regard we note that Policy WSA.2 suggests that a new primary school will be required on the
allocation.
14.2 Whilst Taylor Wimpey recognises the need to provide sufficient education facilities to support
new development where there is an identified shortfall, we object to the policy as it does not
currently appear to be supported by any evidence to identify the impact of future development
on current provision and the subsequent needs for additional school places.
14.3 It is vital that this evidence is produced as part of the preparation of the BCP. The need for
education facilities should be established now as this is the only way that the policy
requirements for strategic allocations and future contribution from sites where on-site provision
is not being made can be transparently and accurately assessed.
14.4 With regard to these policy requirements, the BCP Viability Study29 states the following for
generic typologies and Key Large Sites [KLS]:
“For both the generic Typologies and the KLS we have included the sum of £4,471.40 per home,
unless there is a site-specific assumption for the cost of a new school to be provided to serve a
KLS.
Notwithstanding these allowances, the policy is specifically stated to be ‘subject to viability’”
14.5 The BCP Viability Study provides no explanation as to how this £4,471.40 cost has been derived
so it is not clear whether it is justified and whether it would be effective in providing sufficient
mitigation. Further information needs to be provided to clearly explain how this cost has been
derived and why this amount is sought.
14.6 In addition, the Viability Study30 states that a separate confidential report provides viability and
delivery advice in respect of the portfolio of KLSs so this information is not available for review
and cannot therefore be assessed on this basis. Taylor Wimpey considers that this information
should be provided as part of the BCP evidence base in order that the cost applied for such
provision can be properly reviewed to ensure that it is sound.
14.7 The justification text to Policy HOU5 [§6.50] states that depending on the extent of other
planning obligations required, this provision may not be viable on some sites. This appears to
be inconsistent with §4.21 of the Draft BCP which states that greenfield sites and most
brownfield sites will be able to sustain the full range of planning obligations required. It is
therefore essential that clarity is provided on any education contributions required and their
associated costs.
29 Black Country Viability and Delivery Study, 2021, page 26
30 Black Country Viability and Delivery Study, 2021, §1.13

Comment

Representation ID: 44975

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

CEN1 - The Black Country Centres
Taylor Wimpey supports the identification Of Stourbridge as a Tier 2 Centre in Table 7 Of the
Draft BDP given the district centre function it plays in sewing the needs of development in the
area. We consider that the allocation of land at Clent View Road would support this role by
helping to ensure its future vitality and viability, and to meet needs in the most accessible and
sustainable way by providing new development with access to the centre via sustainable
transport options.
We also note that Streetly is identified as a I,ocal Centre in the emerging BCP. Therefore, the
provision of housing to maintain its role in the settlement hierarchy of Walsall and the wider
Black Country is important. The development of the Chester Road site would support Streetly
as a Local Centre by contributing to local convenience and comparison retail, services,
community facilities and other amenities.

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.

Comment

Representation ID: 44978

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

Policy ENV1 Nature Conservation
policy ENVI seeks to safeguard nature conservation in the Black Country including locally
designated nature conservation sites (Sites of Local Importance for Nature Conservation).
As noted in our response to policy WSA.2, we would request further clarification in the BCp on
the implications of the proposed SLINC on the Mob Lane site for development in this part of the
site in order to inform future development proposals.

Comment

Representation ID: 44980

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

ENV2 Development Affecting Special Areas of Conservation (SACs)
Taylor Wimpey's Mob Lane site lies within the 15km Zone Of Influence for the Cannock Chase
SAC, shown in Figure 11 Of the Draft BCP.
Policy ENV2 states that an appropriate assessment Will be carried out for any development that
leads to a net increase in homes or creates visitor accommodation within 15km Of the boundary
of the SAC. If the appropriate assessment determines that the development is likely to have an
adverse impact upon the integrity of the SAC, then the developer will be required to
demonstrate that sufficient measures can be provided to either avoid or mitigate the impact. The
policy notes that acceptable mitigation measures will include proportionate financial
contributions towards the current agreed Cannock Chase SAC Partnership Site Access
Management and Monitoring Measures (SAMMM).
The Black Country Plan Interim Regulation 18 HRA Report" notes that appropriate assessment
will now be undertaken and a HRA Report will then be prepared at the Regulation 19 Stage Of
the plan making process.
Taylor Wimpey considers that any adverse impacts on the SAC and the measures required to
mitigate impact need to be clearly identified in the appropriate assessment so it is clear to
developers What the implications Will be and any associated costs can be factored into the BCP
viability work.
Any guidance produced to set out the detailed procedure and the level of financial contributions
required needs to be consulted upon as part Of the emerging BCP and should not be produced
following the adoption of the Plan as this will not allow the viability implications to be properly
considered through the BCP.

Object

Representation ID: 44981

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

Policy ENV3 Nature Recovery Network
and Biodiversity Net Gain
Taylor Wimpey objects to part Of Policy ENV3 which requires all development to deliver the
Nature Recovery Network Strateor. Taylor Wimpey notes that locally developed Nature
Recovery Network Strategies are due to be introduced through the Environment Bill which has
yet to achieve Royal Assent (as set out in further detail below). The precise detail of the
requirements cannot therefore be confirmed at this Stage.
justification text to the policy notes that the Black Country Authorities have commenced
work on a Incal Nature Recovery Network However, a copy of the document is not
available for review and comment as part ofthe consultation on the Draft BCP so it is not
possible to ascertain what the implications of the document will be for individual sites and
respond accordingly. Taylor Wimpey therefore considers that the inclusion Of this requirement
in the policy is not justified at this stage.
Taylor Wimpey objects to part 2 Of the policy which requires development to deliver a minimum
10% net gain in biodiversity value when measured against baseline site information. Taylor
Wimpey is concerned with the timing of this policy as it precedes the introduction of the
relevant legislation on Biodiversity Net Gain LBNGI.
Environment Bill, within which the legislation in relation to BNG is enshrined is still
making its passage through parliament and has yet to reach Royal Assent. At this point it is not
therefore confirmed what the final content of the legislation will be.
In addition, once the Environment Bill achieves Royal Assent, there may be a transition period
and it is likely that secondary legislation and national policy will set out transitional provisions
in relation to local plans and applications that fall between the old regime and the new BNG
requirements under the Bill.
secondary legislation will deal with a significant amount of detail and powers will be
available to the Secretary Of State to make regulations including to amend the net gain
objective currently identified in the legislation and to amend the type of developments which
will be required to deliver net gain. It may also be the case that regulations concerning other
matters are introduced. This could include matters such as the procedure for approving a
biodiversity gain plan, and factors to be taken into account when determining whether to
approve a plan, and how to submit and who may submit a plan, and any further matters the plan
needs to address.
With regard to this matter the BCP Viability Study' states:
"For the purposes of our plan viability assessment a net biodiversity net gain/habitats
charge has been explicitly included in our appraisals. We have included a Net gain delivery
cost Of 21,003 per housing unit for greenfield development and E268 per housing unit for
brownfield development. This is based upon the West Midlands regional cost (central
estimate) in the Net gain delivery cost tables (Tables 16 and 17) from the DEFRA Biodiversity
net gain and local nature mcovery strategies Impact Assessment 15/10/2019
However, in the absence of the relevant legislation at the current time , it is not clear whether
the costs applied provide an accurate assessment on the likely cost Of BNG. Taylor Wimpey is
concerned that this cost may be too low and may not reflect the situation •on the ground' on sites
in the Black Country.
Black Count" Viability and Del
study, 2021, page 37

P rt 7 of the policy states that compensation
only be accepted in exceptional circumstances
should be pmvided prior to development. Taylor Wimpey considers that the provision of
compensation prior to development is not likely to be practicable in all instances as it may be
necessary to use receipts from the sale of dwellings on the site in order to fund this
compensation. This funding would not therefore be available prior to development and would
start to come forward during the development process as dwellings are completed and released
for sale. It is therefore considered that a better approach would be to allow for the timing of
payments to be secured through legal agreements and the policy wording should be amended to
allow for this approach.

Object

Representation ID: 44982

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

ENV4 — Provision, retention and
protection of trees, woodlands and
hedgerows
Taylor Wimpey recognises the important contribution that trees make to the character and
quality Of urban environments and mitigating climate change. However, this needs to be
balanced with the need to make efficient use of land as advocated by the Framework (51241.
part 1 Of the policy requires development adjacent to ancient woodland to provide an
appropriate landscaping buffer, with a minimum depth of 15m and a preferred depth of 50m.
However, theræ is no clear justification for the preferred 50m buffer in the BCP and Taylor
Wimpey considers that this preferred depth should be deleted from the policy.
Part 13 of the Policy ENV4 states that new developments should make a minimum contribution
Of 20% canopy cover across the development site and a recommended contribution Of 30%
canopy cover across the development site. We note that this requirement is based upon
recommendations prepared by the Woodland Trust" rather than being informed by Government
policy and guidance so is not based around any national policy requirement. We consider that
this minimum contribution and recommended contribution are completely unrealistic.
It would be necessary to ensure that this level Of planting would not cause unacceptable harm in
terms of shading and the need to distance dwellings accordingly would have a resultant impact
upon the areas within site where homes can be located. As a result, we consider that the policy
requirement would prejudice the ability for developers to make the efficient use Of land as
required by the Framework It also fails to take into account other policy requirements
which need to be considered in the development of sites and have a further impact upon density,
such as the provision Of open space and highways infrastructure. Taylor Wimpey therefore
considers that Part 13 of the policy should be deleted.
part 14 Of the policy states that new houses and Other buildings must be carefully designed and
located to prevent an incompatible degree of shade being cast by both existing and new trees
that might result in future pressure for them to be removed. Taylor Wimpey agrees with this
approach and considers that the requirements Of Part 13 Of the policy are completely at Odds
with this aim as the canopy cover sought would undoubtedly lead to pressure for trees to be
removed in the future.
Part 15 of the policy suggests that the positioning of trees in relation to streets and buildings
should not worsen air quality for people using and living in them by allowing street level
ventilation to occur. It is not clear how this could be accurately assessed or achieved in practice
and we do not consider that part 15 would be effective. On this basis we consider that Part 15
should be deleted.
Part 18 of the policy requires trees proposed for removal during development to be replaced at a
ratio of at least three for one. There is no clear justification in the Policy or explanatory text for
the additional replacement trees. Taylor Wimpey is concerned that this requirement would
place unnecessary burdens upon developers and could limit the development potential Of
residential sites if land is lost to facilitate the additional planting of trees and hedgerows.
As the wording of the policy states "a ratio of at least 3 for one" this indicates that the Council
could seek a higher provision than the three to one ratio. The justification text to the policy
notes that there Will be circumstances where the ratio Of replacement planting Will be greater
Emergency Tree plan for the — The 2020
th n this — especially in cases where significant / mature trees contributing to the vi
ecological amenity of an area and its character are to be removed.
As this will vary on a site by site basis, it is not possible to ascertain the impact the Policy would
have upon the development potential and viability of sites.
The justification text to the policy states that where a development site cannot accommodate
additional planting, replacement trees will be expected to be planted in an appropriate off-site
location. It is that this approach would be practical and whether it would actually be
implementable in practice as there may be no additional land available within the developers
ownership to provide this off-site mitigation.
The financial and practical burdens placed on developers by the requirements of Part 18 could
impact on the development potential of sites and therefore cannot be seen to be positively
prepared. In addition, the impacts of this policy requirement do not appear to have been fully
considered in the BCP Viability Assessment. 'Ille replacement of trees on a ratio of one for one
is therefore considered to be appropriate and the policy should be amended to reflect this.

Comment

Representation ID: 44983

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

DESIGN QUALITY
Part 2 of the policy identifies a number of matters that development proposals must address.
However, these matters are very high level such as addressing " the townscapes and landscapes
of the Black Country". As with Policy CSP4, Part 2 of the policy would benefit from further
clarification either within the policy text itself or the justification text and it may be worthwhile
for a design guide to be prepared as part Of the BCp which reflects local character and design
preferences and would provide more specific guidance to developers on design requirements.
e policy requirements should be set out in sufficient detail to determine a planning
application Without relying on, Other criteria or guidelines set out in a separate SPD.
It is essential that this is prepared as part of the BCP so that any cost implications can be
properly viability tested in conjunction With Other policy requirements.
Part 3
part 3 States that new residential development Will be required to meet water efficiency
standards of 110 litres per person per day. If the BCA wish to adopt the optional standard for
water efficiency of 110 litres per person per day then they need to justify doing so by applying
the criteria set out in the practice Guidance". The Water Cycle Study (2020) identifies the
Severn Trent Water and South Staffordshire Water supply regions as areas of only moderate
water stress. A clear local need has not been demonstrated.
Taylor Wimpey thereforæ considers that Part 3 of the Policy should be deleted.
Part 4
Taylor Wimpey objects to Part 4 of Policy ENV9 which requires all new msidential development
to meet the Nationally Described Space Standards LNDSSI.
Taylor Wimpey notes that the Government's decision to make these standards optional suggests
that they do not expect all properties to be built in accordance with them. If the standards are to
be applied, the Practice Guidance'S sets out a clear set of criteria local planning authorities
should address in order to justify them, these being:
need — evidence should be provided on the size and type of dwellings currently being built in
the area, to ensure the impacts Of adopting space standards can be properly assessed.
viability — the impact Of adopting the space standard should be considered as part Of a plan's
viability assessment with account taken of the impact of potentially larger dwellings on land
supply. Local planning authorities will also need to consider impacts on affordability where
a space standard is to be adopted.
timing — there may need to be a reasonable transitional period following adoption Of a new
policy on space standards to enable developers to factor the cost of space standards into
future land acquisitions.
With regard these criteria, we firstly note that no need evidence is provided to justify the policy
requirement. The justification text to the policy suggests that the standard is generally met in
most new build housing across the Black Country but no further information on this matter is
provided and it does not appear to have been covered in the evidence base, so there is nothing to
Planning Practice Guidance ID : 56-014-20150327 and ID : 5&015-201S0327
s Planning Practice ID: 56-020-20150327
r tify this. With regard to viability, the BCP Viability Study states that the NDSS has been
applied within the appraisals as the minimum standard. However, it is not clear whether the
impact upon affordability has been considered.
•fie BCA's policy approach should recognise that customers have different budgets and
aspirations. An inflexible policy approach to NDSS for all new dwellings Will impact on
affordability and effect customer choice. Well-designed dwellings below NDSS can provide a
good, functional home.
For the above reasons, Taylor Wimpey considers that Part 4 of the policy should be deleted.
If the Council is able to provide sufficient evidence to justify the policy, Taylor Wimpey
considers that a transitional period should be applied. It is not clear whether a large proportion
of new dwellings currently meet the standard, and the cost of such provision may not therefore
be factored into current and past land acquisitions. A reasonable transitional period following
adoption of a new policy would help enable developers to factor the cost of space standards into
future land acquisitions.

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.