Comment

Representation ID: 161

Received: 19/12/2023

Respondent: Pam Archer

I think the most important things in an area based local plan MUST include plans for dealing with climate change, which is the biggest threat our whole planet has ever faced. We all need to change our way of life which will be most uncomfortable for most of us, as multinational
organisations have frequently demonstrated, when they say they will work towards ensuring that the global temperature rise will be kept to below 1.5%. But their actions don’t tell the same story. I hope yours do.

Comment

Representation ID: 180

Received: 22/12/2023

Respondent: Mark Richards

Please find attached our Dudley Climate Action Plan which we are submitting in response to your
consultation as a local voluntary community group based in Dudley Borough. This plan was produced by
Dudley residents following public consultation events with in 2019/20 with local data researched by Friends
of the Earth. It has continued to be updated from national research and residents input in 2021, 2022 and
2023. See attachment.

Object

Representation ID: 320

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 42 Energy Infrastructure
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.

Comment

Representation ID: 360

Received: 12/12/2023

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

Policy DLP42 – Energy Infrastructure
6.6.
Turning to Policy DLP42 of the Local Plan, the Council proposes to require all major developments of ten or more homes to include opportunities for decentralised energy provision unless it can be demonstrated that the development is not suitable, feasible, or viable for district heat or decentralised power networks. However, where there is existing decentralised energy provision available
Policy DLP42 expects new developments to link into it, or be designed to accommodate a subsequent connection. Although the broad principle of this Policy is supported, it must be ensured that aspirations to secure connections to decentralised energy provisions do not compromise the viability and delivery of new developments, particularly where the policy as currently drafted is proposed to apply to schemes of as few as ten dwellings. Whilst part 1a of Policy DLP42, which relates to on-site decentralised energy provision, takes viability and feasibility considerations into account, this is not replicated within Parts 1b to 1c of the Policy such that it is ambiguous as to whether the Council will have regard to viability and feasibility considerations in respect of requirements for new development to provide linkages to offsite decentralised energy networks. It is advised that the Policy is reworded to identify that the provision of either on-site decentralised energy provision, or linkages to an existing network are aspirational and to be achieved where suitable and viable to ensure that this Policy is clearly written and unambiguous in accordance with Paragraph 16 of the Framework. 6.7.
Notwithstanding the technical concerns raised within the above responses, it is considered that the number of policies which relate to design quality and sustainability is excessive. It is appreciated that the Council have sought to positively address the challenge of climate change through the Local Plan review, in accordance with Paragraph 16 of the Framework. However, it is considered that the number of policies proposed to address this matter, in addition to the quantum of text contained within each of these, fails to provide the requisite clarity as to how the Council’s sustainability aspirations are to be achieved through new development. It is there advised that Policies DLP39; DLP40; DLP41; DLP43; and DLP47 are revised to ensure that each of these is clearly written and unambiguous as required by Paragraph 16 of the Framework. In particular, the Council should amend these policies so that they are consciously written, recognising that further detail as to the proposed implementation of these policies can be provided through preparation of a Supplementary Planning Document where appropriate.

Comment

Representation ID: 410

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

HBF is concerned about mandatory requirements to connect to district heating networks. HBF considers that it is important that this is not seen as a requirement and is instead implemented on a flexible basis. Heat networks
are one aspect of the path towards decarbonising heat, however, currently the predominant technology for district-sized communal heating networks is gas combined heat and power (CHP) plants. Over 90% of district networks are gas fired. As 2050 approaches, meeting the Government’s climate target of reducing greenhouse gas emissions to net zero will require a transition
from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery but at the moment one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. The Council should be aware that for the foreseeable future it will remain uneconomic for most heat networks to install low-carbon technologies. This may mean that it is more sustainable and more appropriate for developments to utilise other forms of energy provision, and this may need to be considered.
Government consultation on Heat Network Zoning also identifies exemptions to proposals for requirements for connections to a heat network these include where a connection may lead to sub-optimal outcomes, or distance from the network connection points and impacts on consumers bills and affordability.
Furthermore, some heat network consumers do not have comparable levels of satisfaction as consumers on gas and electricity networks, and they pay a higher price. Currently, there are no sector specific protections for heat network consumers, unlike for people on other utilities such as gas, electricity or water. A consumer living in a building serviced by a heat network does not have the same opportunities to switch supplier as they would for most gas
and electricity supplies.
The Council’s proposed policy approach is unnecessary seeks to go beyond the 2021 Part L Interim Uplift and the Future Homes Standard without justification. It is the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to success is standardisation and avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers, suppliers and developers.
The Council should be aware that the long awaited consultation on the Future Homes standard was published on Dec 13th 2023 and consultation closes in 6 March 2024. The consultation documents can be found online at https://www.gov.uk/government/consultations/the-future-homes-and-
buildings-standards-2023-consultation
HBF is also concerned about any policies which mandate on-site renewable energy generation, which may not be appropriate in all cases- see comments in response to DLP47.

Object

Representation ID: 454

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 42 Energy Infrastructure
Revelan object to the requirement that residential development of 10 or more homes must include opportunities for decentralised energy provision. This is a significant development cost that could make schemes unviable.

Comment

Representation ID: 482

Received: 19/01/2024

Respondent: CPRE Worcestershire

CPRE West Midlands supports Policy DLP 42, as far as it goes, but it is deficient in that it fails to deal with energy generation, particularly where it is (and is not) appropriate to locate large solar arrays. It is our view that the right place for this is on rooftops and brownfield land, not on green field and certainly not on Green Belt land. The plan should contain a policy to this effect. See CPRE Rooftop Revolution Report (attached) on this subject.

Comment

Representation ID: 646

Received: 22/12/2023

Respondent: TfWM and WMCA

Paragraph 12.5 in the Climate Change section mentions decarbonising transport, but this should also include decarbonisation of transport infrastructure and in particular be mindful of the work WMCA is undertaking as part of Adept’s Live Lab 2 programme with the Centre of Excellence for the Decarbonisation of local Roads (CEDR).
Additionally, there needs to be more specific reference made to the climate adaptation requirements for the transport infrastructure

Support

Representation ID: 807

Received: 30/01/2024

Respondent: Historic England

DLP42. We welcome the insertion of clause 1) d.