Object

Representation ID: 4847

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The requirements for carbon emission reductions in Part 1 of NB6, go beyond the Government’s Future Homes Standard roadmap that most developers are working to and on which they have based their future plans.

The approach, based on the Future Homes target roadmap, takes a more gradual approach which is
the right approach.There are a number of reasons why building ahead of the Future Homes Standard now may not actually be the best solution. Principally, because of the potentially detrimental local impact on delivery through a lack of sufficiently skilled labour available to implement these new technologies at scale.

Regarding Part (b), in principle additional onsite renewable energy should be provided to assist in
meeting net zero regulated energy targets. However, South Staffordshire should to be flexible in the
application of this policy to take account of site-specific constraints which may constrain the onsite
provision of, or offsite connection to, renewable/low carbon energy generation.

Whilst in principle we do not object to a Whole Life Carbon Assessment (WLCA) there are issues surrounding data collection to be able to undertake a proper WLCA. Principally, many manufacturers are still lacking the creation and verification of data for
Environmental Product Declarations (EPDs). Though there are UK based EPDs, these are often generic values which will not accurately reflect a completed property, so it is important that South Staffordshire allow some tolerance when assessing any submitted WLCA.

If a WLCA is to be submitted, then it should be required as part of the planning conditions attached to a grant of detailed planning permission as it would prove difficult for applicants to submit a robust WLCA based on
Outline application parameters.

Regarding the requirement for a as built performance assessment, South Staffordshire should reconsider the requirement for immediate implementation of built assessments in the Local Plan and instead consider rolling out this requirement at a later date, once the Government undertake further national scale research projects into their implementation. If the policy is carried through to EiP stage, South Staffordshire will need to adequately demonstrate as part of their evidence base that the current as built assessment sector will be able to meet the resultant demand should all allocations in the Local Plan come forward for delivery on expected timescales.