ipswich.gov.uk
DM2 - Dencentralised Renewable or Low Carbon Energy
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5330
Received: 05/03/2015
Respondent: Crest Strategic Projects
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Emerging Policy DM2: Decentralised Renewable or Low Carbon Energy replicates adopted Policy DM2 by requiring all new development of 10 or more dwellings to provide at least 15% of their energy requirements from decentralised and renewable or low-carbon sources. We object to the principle of this policy as there is no robust evidence base to justify the requirement and there has been no regard to potential viability issues.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5366
Received: 05/03/2015
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Gladman reiterate the point made above when discussing policy CS1 that in seeking to ensure that all new build development of 10 or more dwellings shall provide at least 15% of their energy requirements from decentralised and renewable or low-carbon sources, this policy should comply with the requirements set out in paragraphs 173 and 174 of the Framework.
Policy DM2: Decentralised Renewable or Low Carbon Energy
Gladman reiterate the point made above when discussing policy CS1 that in seeking to ensure that all new build development of 10 or more dwellings shall provide at least 15% of their energy requirements from decentralised and renewable or low-carbon sources, this policy should comply with the requirements set out in paragraphs 173 and 174 of the Framework.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5373
Received: 05/03/2015
Respondent: Mersea Homes Limited
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The provisions of Policy DM2 are not consistent with national policy on sustainable design and construction and are contrary to the provisions of paragraphs 95 and 173 of the NPPF. The evidence base which purports to assess the viability implications of the policy demonstrates that this policy has a significant impact on the viability of sites, and will therefore affect deliverability. The Borough's own evidence also failed to assess the implications of the Policy on the IGS. The policy cannot therefore be considered the most appropriate strategy.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5423
Received: 05/03/2015
Respondent: Mr Arwel Owen
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The provisions of Policy DM2 are not consistent with national policy on sustainable design and construction and are contrary to the provisions of paragraphs 95 and 173 of the NPPF, which requires sustainability polices to be set in a way which is consistent with the Government's own approach. The evidence base which purports to assess the viability implications of the policy demonstrates that it has a significant impact on the viability of sites, and will therefore affect deliverability. NPPF paragraph 173 is clear that this adverse consequence should be avoided. Its implications for the IGS have not been assessed.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5550
Received: 02/03/2015
Respondent: Home Builders Federation Ltd (HBF)
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The policy is unsound because it is contrary to national policy.
Policy DM2: Decentralised renewable or low carbon energy
The policy is unsound because it is contrary to national policy.
This policy is contrary to the Government's policy on how the energy efficiency targets are achieved including its statement on how residential developers will be able to meet the target for zero carbon homes from 2016 onwards. The DCLG in its paper entitled Next Steps to Zero Carbon Homes - Allowable Solutions (DCLG, July 2014) has made it clear that residential developers are not obliged to pursue any particular route to achieve the carbon efficiency targets under Part L of the Building Regulations that may be suggested by the local authority. The house builder will be free to choose the most appropriate measure (see paragraph 8 of the report). The Council, therefore, cannot require that developers provide for at least 15% of their energy requirements from decentralised and renewable or low-carbon sources. They may decide to, but they cannot be compelled to do so. Nor is the applicant required to justify what particular approach he/she has decided to adopt in order to achieve the carbon efficiency targets. Nor is the applicant required to design the development to allow for the application of feed-in tariffs.
This is not a planning matter and should be deleted in respect of residential development.