Object

Representation ID: 1087

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Barberry object to the requirement that residential development of 10 or more homes must include opportunities for decentralised energy provision. Whilst in principle the idea of centralised energy provision is helpful, in reality the delivery of it from a private housing development makes it impractical. Particularly, where individual family homes are proposed as opposed to a single multi-apartment block where there might be a case for including it. As such, we do not consider that such schemes are feasible or deliverable and that any provision should be optional based on the developer’s objectives rather than a requirement for all new development.

Object

Representation ID: 1330

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy DLP42: Energy Infrastructure is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not in line with national policy.

Key concerns raised by HBF:

Mandatory District Heating Networks: HBF opposes mandatory requirements for developments to connect to district heating networks. They argue that this should be implemented flexibly. Currently, most district heating networks rely on gas-fired combined heat and power (CHP) plants, and transitioning to low-carbon alternatives (like large heat pumps, hydrogen, or waste-heat recovery) will be costly and economically unfeasible for the foreseeable future. The Council should consider alternative energy provisions, as low-carbon technology adoption remains financially challenging.

Government Consultation on Heat Network Zoning: HBF highlights a Government consultation that identifies exemptions to mandatory connections, such as where a connection would result in sub-optimal outcomes, affect consumer bills, or be impractical due to distance from the network.

Consumer Satisfaction and Costs: HBF points out that consumers using heat networks often face higher costs and lower satisfaction compared to traditional gas and electricity network consumers. Heat network consumers also lack the ability to switch suppliers, unlike other utility users, which raises concerns over consumer protection.

Excessive Requirements on Energy Efficiency: HBF argues that the policy goes beyond national standards like the 2021 Part L Interim Uplift and Future Homes Standard without justification. They stress that energy efficiency standards should be standardized through national regulations, rather than being set locally, to avoid undermining economies of scale for manufacturers, suppliers, and developers.

On-Site Renewable Energy Generation: HBF raises concerns about mandatory on-site renewable energy generation, suggesting it may not be suitable for all developments. They reference their comments in response to Policy DLP47.

HBF urges the Council to align with national energy efficiency and decarbonization strategies and avoid imposing unnecessary and potentially uneconomical requirements on developers.

Object

Representation ID: 1372

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The threshold of 100 houses is too high. It should be possible to devise simpler systems suitable for smaller developments, down to putting solar panels on the roofs of single new dwellings.
The policy seems to lack any provision requiring (or at least encouraging) solar electricity generation by placing solar panels on roofs (both domestic and commercial), above car parks and on brownfield sites that cannot be used for other purposes. It ought to require such. It is possible that this is implicit in the very generalised expressions used, but if so, it would be better if the supporting text provided examples of what is intended by these expressions; otherwise this policy is effectively gobbledegook.

See CPRE reports on this: https://www.cpre.org.uk/wp-content/uploads/2024/04/CPRE-Report-Lighting-the-way-final-version.pdf and https://www.cpre.org.uk/wp-content/uploads/2023/05/Rooftop-Revolution-Report.pdf
Copies of these reports are sent with this objection

Comment

Representation ID: 1556

Received: 29/11/2024

Respondent: Historic England

Policy DLP42 Clause d

This policy should refer to preventing harm to heritage assets and protecting the significance of heritage assets including their setting. Could refer to avoiding harm and then continue the sentence re significance.