Object

Representation ID: 1088

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We note the requirement in Part 3 of the policy that major developments creating 10 or more homes must incorporate the generation of energy from renewable or low carbon sources sufficient to offset at least 20% of the estimated residual energy demand of development on completion. It is not clear on what basis the requirement for a 20% energy reduction has been based on and it seems an arbitrary figure without any justification. Whilst Barberry are supportive in principle of new development achieving energy reductions and sustainability we consider that building regulations are the most appropriate way of securing energy reduction targets. Building regulations are constantly updated and will ensure that new development is able to achieve the requisite energy reduction standards in place at the time of construction. Building regulations are, therefore, more responsive to changes in Government and national policy whereas the Local Plan policy would be static until the Local Plan was reviewed. The policy is a duplication of control with other legislation and as such it is considered unnecessary.

Object

Representation ID: 1202

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

The LPA is not promoting climate change resilience measures within its proposed spatial planning policy approach being taken towards the distribution of new development. We are alarmed that the council’s planning policy team considers it appropriate to re-develop established urban woodlands within heavily constrained urban areas for new housing development. The plan making approach being taken forward by the LPA strongly conflicts with climate change resilience focused national planning guidance set out under paragraphs
157 to 159 of the Revised NPPF (December 2023).

Object

Representation ID: 1224

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

46. There is a lack of sufficient in-house specialist technical expertise within both Dudley Council’s Planning Policy and Development Management Teams to effectively deliver Net Zero policies being taken forward within the emerging Local Plan Review. This will have a damaging impact on the private sector bringing forward new planning applications as the council will continue to use a one-size-fits-all approach and continue to place excessive and heavily onerous demands on private sector housing developers bringing forward new planning applications. A more flexible planning policy approach should be used by the LPA in relation to these policy requirements, given the highly adverse economic circumstances currently affecting housing developers. This flexible planning policy approach will not be possible given the lack of in-house technical expertise.
47. Goldfinch Town Planning Services has concerns that highly onerous Climate Change Net Zero policies are being taken forward within the emerging Local Plan Review which will place a financially damaging burden on new housing development proposals coming forward at a time when the house building construction industry is operating within a severe 300-year-economic recession-event climate, and at a time when the construction industry is being adversely affected by prolonged and stubbornly high interest rates, high inflation and a varied range of other factors considered within the Appendix section of this Local Plan Representation. The Council should ensure that the approach taken towards Local Plan preparation is based on the most up-to- date and robust economic evidence in order for the Plan making approach to respond effectively to paragraphs 31, 35 (indent b) and 86 (indent d) of the Revised NPPF (December 2023).

Object

Representation ID: 1332

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP47: Renewable and Low Carbon Energy and BREEAM Standards is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not in line with national policy.

HBF's concerns include:

Mandatory On-Site Renewable Energy Generation: HBF opposes mandatory requirements for on-site renewable energy generation, suggesting that it should be applied flexibly. While acknowledging the potential for on-site energy generation, they argue that larger-scale, more efficient sources might be more sustainable. Additionally, the policy does not account for the decarbonization of the national grid over time, which will reduce reliance on on-site renewable energy.
HBF advocates for flexibility in the implementation of renewable energy generation and emphasizes that national grid decarbonization should be considered in the policy.

Object

Representation ID: 1338

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

These three policies in the emerging Plan set out various policy measures relating to sustainable design and construction in order to achieve the Council’s aspiration of mitigating and adapting to climate change. As identified through previous representations, it is considered that the policies should be reviewed and amalgamated, in order to streamline policy requirements and reduce duplication, consistent with the requirements of Paragraph 16 of the Framework. It should be considered whether policy requirements could be identified in more simple terms, with more detailed policy suggestions identified through Supplementary Planning Documents, whilst also recognising the increased requirements for renewable energy and other sustainable technologies advanced through changes to Building Regulations.

Comment

Representation ID: 1376

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

DLP47 may be intended to be a counterpart to DLP42. Logically it should follow DLP42, so that the requirements for different kinds of housing and other development are placed together. Even so, there appears to be no provision (as there should be) for discouraging the placing of solar panels on productive agricultural land, including prime pasture (grade 3B) as well as Best and Most Versatile Agricultural Land.

Object

Representation ID: 1393

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

These three policies in the emerging Plan set out various policy measures relating to sustainable design and construction in order to achieve the Council’s aspiration of mitigating and adapting to climate change. As identified through previous representations, it is considered that the policies should be reviewed and amalgamated, in order to streamline policy requirements and reduce duplication, consistent with the requirements of Paragraph 16 of the Framework. It should be considered whether policy requirements could be identified in more simple terms, with more detailed policy suggestions identified through Supplementary Planning Documents, whilst also recognising the increased requirements for renewable energy and other sustainable technologies advanced through changes to Building Regulations.

Comment

Representation ID: 1453

Received: 29/11/2024

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

**Summary:**

The three policies on sustainable design and construction in the emerging Plan aim to mitigate and adapt to climate change. However, it is suggested that these policies be reviewed and merged to streamline requirements and reduce duplication, in line with Paragraph 16 of the Framework. The policies should be simplified, with detailed requirements outlined in Supplementary Planning Documents, while also considering the increased standards for renewable energy and sustainable technologies introduced by changes to Building Regulations.

Comment

Representation ID: 1497

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterate previous Regulation 18 comments.

Request inclusion of our network within the policy and justification text in relation to the potential for use of our network for water-source heat pumps.