Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21667

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

Various comments to Points 2, 4, 9 & 10 pf the Policy.

Full text:

Point 2: Persimmon Homes (Anglia) recognise the importance of delivering new and changing technologies in terms of supporting a healthy economy, satisfying modern business needs and for social well-being.

With respect to electric vehicles, Persimmon Homes (Anglia) acknowledge the environmental importance of ensuring that all new cars are effectively zero emissions by 2040 and share the Government’s ambition to achieve this target. We also recognise that the transition to electric vehicles is still at a relatively early stage of development and, as such, the existing electricity network may be limited in terms of accommodating electric vehicle charging with respect to the associated increase in domestic energy demand that such provision is likely to generate.

Policy 2 must therefore be informed through consultation with UKPN to ensure that the associated requirements are deliverable without creating any unsustainable pressure upon the network.

Whilst the delivery of new and changing technologies is supported, these must be factored into the Council’s Viability Report as they will undoubtedly carry cost implications for new development.

Point 4: The approach to encouraging higher densities in more sustainable locations is supported, but it is considered that indicative minimum densities across the plan area should be higher, especially if the policy objective of making efficient use of land is to be realised. It is considered that a minimum indicative density of 30 dwellings per hectare would be more appropriate in this respect, but that the Policy should acknowledge the suitability for higher densities more generally, for example in town centres where sustainable transport links and good access to jobs/services are more likely to be available.

Persimmon Homes (Anglia) does not consider that additional Strategic Gaps need to be designated. Since the existing Strategic Gaps were designated based on high level landscape assessment, policies should include sufficient flexibility to enable development in the Strategic Gaps where site specific LVIAs demonstrate there would not be a significant adverse impact.

Points 9 & 10: In terms of water efficiency and energy demand, Persimmon Homes (Anglia) would support a policy approach that delivers consistency with the most up-to-date Building Regulation standards. In this respect, the Policy must be updated to take account of Part L of the Building Regs (future homes standard) once this has been formally implemented. The update to Part L of the Building Regulation may include a requirement for 31% reduction in carbon emissions compared to the current standard. It is imperative that the Council’s Viability Report makes an assessment of the potential cost implications of the amended Building Regulations (Part L).

Moving forward, between now and adoption, there needs to be a mechanism enabling continual review of any further change to national regulations that might carry implications for development viability so that these can be captured in the plan making process.

Persimmon Homes (Anglia) recognise the contribution that battery storage can make in terms of enhancing energy resilience. However, at present, the costs of providing such infrastructure are high and the industry is hampered by a skills/knowledge gap. An opportunity exists for local government to work collaboratively with developers to help research and fund energy storage schemes through pilot projects. Such an approach should be adopted before this aspect of the policy is taken forward.