Object
Publication
Representation ID: 24385
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The proposed policy requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations is not robustly supported by the Local Plan evidence base. As such, the Plan has not been positively prepared, is not justified, will not be effective, and is not consistent with national policy.
The ‘Greater Norwich Energy Infrastructure Study’ states at para. 5.4.1, that to respond to the aim to ‘minimise energy demand of the new development’ that: “New residential … developments need to meet Part L building regulations relevant at the time of construction …” (emphasis added). As such this is a proposed local policy requirement which needs to be robustly considered in terms of viability implications for all development if it is to be applied. The supporting evidence base does appear to demonstrate this.
Remove reference to the proposed requirement that all new development provide a 20% reduction against Part L of the 2013 Building Regulations as it does not appear to be justified by the evidence base.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).