Object

Representation ID: 22972

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

With advances in building fabric technology our client supports the approach to increase energy efficiency for new homes rather than focussing on energy generation. Notwithstanding this, our client questions whether the 20% reduction against Part L of the 2013 Building Regulations (amended 2016) is achievable in the short to medium term. We 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).’

The wording of Policy 2 must be amended so that matters such as viability can 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, especially brownfield sites and sites with costs associated with remediation of land, which could be in highly sustainable urban locations.