Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14766
Received: 09/12/2020
Respondent: St Philips Land - Land at Smiths Lane Browns Lane & Widney Manor Road
Agent: Savills
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Additional requirements on development sites in order to reduce energy demand and minimise carbon dioxide emissions are over and above the requirements of PPG. 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”.
In considering viability, Solihull has not sufficiently justified why a 30% uplift is proposed.
The capital cost and land take to achieve the requirement for at least 15% of energy from renewables, should be considered. There is no evidence of this.
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.
See attached documents