Comment

Representation ID: 19

Received: 18/11/2023

Respondent: Miss Alana Moss-Deeley

- What standard will the homes be built to? In the UK we create generally poor quality and inefficient
homes. It would be great to see at least some of these built from timber frames or SIPS panels. This
will create better-insulated homes for local people reduce energy bills, improve the cost of living,
reduce remand on fossil fuels, and help us reach our carbon emissions. It would be fantastic to see
some level of environmental certification too such as Passivhaus although I am probably expecting too
much there
- All south or southeast-facing houses to be fitted with solar panels as standard
- EV charging points for every single home as standard
- Ground source heat pumps considered

Object

Representation ID: 127

Received: 20/12/2023

Respondent: Mr John Maxted

Whilst admirable in it intent, Policy DLP47 fundamentally misinterprets the requirements and process for BREEAM assessments. BRE ensures that only 10% of assessed projects nationally achieve a 'Excellent' rating and 1% 'Outstanding'. By stipulating these requirements the LPA guarantees issues with projects achieving compliance and/ or changes to the requirements being made by BRE. A better solution would be to require a BREEAM assessment to take place on proposals and minimum standard (such as the one for WAT 01) being made. Currently the policy highlights the lack of understanding that the Council has on BREEAM matters.

Comment

Representation ID: 321

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 47 Renewable and Low Carbon Energy and BREEAM Standards
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 10% 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.

Comment

Representation ID: 386

Received: 21/12/2023

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Policy DLP 47 Renewable and Low Carbon Energy and BREEAM Standards
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 10% 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 WL 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.

Comment

Representation ID: 411

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

HBF is concerned about any policies which mandate on-site renewable energy generation. HBF considers that it is important that this is not seen as a requirement and is instead implemented on a flexible basis. HBF recognises that there may be potential for renewable energy generation on-site, however, it may be more sustainable and efficient to use larger scale sources rather than small-scale, it is also noted this policy also takes no account of the fact that over time energy supply from the national grid will be decarbonised.

Object

Representation ID: 455

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 47 Renewable and Low Carbon Energy and BREEAM Standards
Part 3 of the policy requires developments of 10 or more homes to incorporate measures for the generation of energy from renewable or low carbon sources sufficient to off set at least 10% of the estimated residual energy demand of the development on completion. It is not clear on what basis the requirement for a 20% energy reduction has been based on, it would appear to be an arbitrary figure without any justification.
Whilst we are supportive in principle of new development achieving energy reductions the 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.

Comment

Representation ID: 533

Received: 21/12/2023

Respondent: Churchill Retirement Living

Agent: Churchill Retirement Living

Policy DLP47 Renewable and Low Carbon Energy and BREEAM Standards - If the intended outcome of Policy DLP47 is the reduction of carbon emissions then we would query why the method for doing SO needs to be specified. We would also respectfully remind the Council that the costs of meeting enhanced sustainability standards must be accounted for the in the forthcoming Local Plan Viability Assessment.

Object

Representation ID: 549

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

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-economicrecession event climate, and at a time when the construction industry is being adversely affected by prolonged and stubbornly high interest rates, high inflation, high energy costs, and at a time when the construction industry is facing a huge spike in the financial costs of both building materials and significant increases in skilled construction labour costs. This will all mean that the financial viability of all new housing development schemes coming forward across the Dudley Metropolitan Borough and wider Black Country sub-region will be severely affected and very finely balanced from a financial viability perspective. 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 and 82 (indent d) of the Revised NPPF (2023).

Comment

Representation ID: 601

Received: 18/01/2024

Respondent: Environment Agency

We support Policy DLP47 which requires the achievement of full credits for water efficiency. However, we recommend that for non-residential development over 1000sqm, BREEAM ‘excellent’ standards for water consumption should be met when water resources are under pressure. As of July 2021, Severn Trent and South Staffs are now classed as operating in areas of serious water stress. The policy requires this standard from 2029 but we think there is sufficient evidence and reason to aim for this standard now. This would also align more with the aims of paragraph 158.

Comment

Representation ID: 750

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests inclusion of our network within Policy DLP47 Renewable and Low Carbon Energy and BREEAM Standards, and justification text para 12.56 in relation to the potential for use of our network for water-source heat pumps (ACTION REQUEST)

Comment

Representation ID: 810

Received: 30/01/2024

Respondent: Historic England

DLP47. We consider it would be more suitable to have a specific clause for the historic environment that considered the issues that might arise and ensured the protection of the significance of heritage assets, including their setting.