Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14170
Received: 14/12/2020
Respondent: Hampton Road Developments Ltd
Agent: Savills
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
At 3 i, it is not for the planning system to place requirements over and above building regulations. The PPG states that Local Plans can set higher standards but only up to the equivalent of Level 4 of the Code for Sustainable Homes”. If this is required, changes to Building Regulations should be brought forward.
In 3ii, the government does not require net zero carbon dwellings now or from April 2025. It is unclear what the rationale of this requirement is.
In 3 iv, the practicality of requiring at least 15% of energy to be provided form renewable sources should be considered.
In 4 ii, it should be noted that it is not always possible (for example due to site constraints) to orientate every home to enhance natural ventilation and lighting. This is unjustified.
With regard to viability, £6000 per dwelling just to meet energy requirements without any other requirements being taken into account is considered significant.
Amend Policy P9 to ‘encourage’ development to apply the energy hierarchy to reduce energy demand and minimise carbon dioxide emissions. The policy should state that this will be subject to viability and suitability considerations at the application stage. The requirement to reduce energy demand to over and above Building Regulations Part L should be removed as this does not comply with the PPG.
We are unclear whether the Future Homes Standard referenced in the viability report is the same as the net zero carbon dwellings that are required in 3 ii. Furthermore, other requirements such as the need to provide 15% of energy from renewable sources has not been considered within the viability report. We request clarification of whether full costings have been undertaken in relation to the delivery of such policy requirements. If this cannot be demonstrated we do not consider that this policy can be justified and effective.
See attached documents.