Object

Representation ID: 22805

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

There is an absence of any evidence to suggest that the 20% reduction against Part L of the 2013 Building Regulations (amended 2016) is achievable in the short to medium term. We therefore object to the current wording of this requirement and suggest that a more flexible approach be taken to this policy requirement with the wording ‘All new development will seek to provide a 20% reduction against Part L of the 2013 Building Regulations (amended 2016).’

It is important that the wording of Policy 2 explicitly allows matters such as viability to be taken into account when considering the merits of particular development sites. Whilst the Council estimates that the measures to deliver a 20% reduction would cost between £2,000 and £7,000 per dwelling (which is a significant range of cost impact in itself), this additional cost could impact negatively on the delivery of sites whether other costs such as infrastructure, ground contamination, etc. were already impacting on viability. Moreover, the ‘alternative approaches’ text suggests that anything more than a 20% reduction would be universally unviable. Given the other site-specific requirements that will also impact upon the delivery of individual sites having a requirement for a 20% reduction that is so close to rendering sites unviable is not a sound approach to securing the delivery of new homes. Therefore, as worded the Policy requirement for a 20% reduction against Part L of the 2013 Building Regulations (amended 2016) could prevent sites coming forward.