Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14645
Received: 14/12/2020
Respondent: Heyford Developments Ltd (Dorridge Site)
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Requirement for a 30% reduction in energy demand/carbon reduction improvement over and above the requirements of Building Regulations goes beyond the Future Homes Standard (2019) consultation proposals and beyond the current PPG.
Under Point (viii) developments are required to provide one electric charging point per vehicle. Proposals must be supported by evidence to demonstrate that they are deliverable.
In Point 3 (i) energy and carbon reduction are two separate measurements. The Future Homes Standard (2019) refers to carbon emission reductions; this should be clarified.
The Viability Study does not test the impact of the 15% energy from renewable/low carbon sources requirement, contrary to the PPG and the ‘energy efficiency hierarchy’.
Unclear what up to date local evidence informs the requirements.
Policy does not contain sufficient clauses related to site specific viability or site-specific constraints which may impact upon the implementation of the requirements.
The Policy P9 Points 3 (i), (ii) and (iv) requirements should be removed, or at the very least additional clauses should be included within the policy that allow for site specific flexibility in relation to viability and site-specific constraints.
See attached documents