Policy HC13: Parking Provision

Comment

Representation ID: 4090

Received: 13/12/2022

Respondent: Staffordshire Police

EV charging points should be installed on all properties. Apartment blocks should have an EV charging point within the parking court, as well as industrial estates and businesses futureproofing for the increase of electric and hybrid vehicles in the future.

Object

Representation ID: 4187

Received: 21/12/2022

Respondent: Mr John Marsh

Legally compliant? No

Sound? No

Duty to co-operate? No

See attachment

Comment

Representation ID: 4475

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the proposed parking standards contained within the Publication Plan.
In respect of EVCPs, The Department of Transport Consultation Response: Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings (with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per
EVCP. This cost is below the Government’s cost estimate and excludes any costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4510

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the proposed parking standards contained within the Publication Plan.
In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500
per EVCP. This cost is below the Government’s cost estimate and excludes any costs for upgrading local networks. The Department for Transport - Electric
Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4539

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the proposed parking standards contained within the Publication Plan.
In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential
Buildings dated November 2021 sets out that from 15th June 2022 new dwellings with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
The EVCP standards set out in Appendix I of the Publication Plan are supported in respect of dwellings as this position aligns to Requirement S1 and Regulation 44D.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per EVCP. This cost is below the Government’s cost estimate and excludes any
costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading
networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4565

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the proposed parking standards contained within the Publication Plan.
In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per EVCP. This cost is below the Government’s cost estimate and excludes any
costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading
networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4590

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Taylor Wimpey supports the proposed parking standards contained within the Publication Plan.
In respect of EVCPs, The Department of Transport Consultation Response: Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per EVCP. This cost is below the Government’s cost estimate and excludes any costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4622

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings
with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per EVCP. This cost is below the Government’s cost estimate and excludes any
costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading
networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4678

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs.
It is noted that the Council’s Viability Assessment includes a cost of only £500 per EVCP. This cost is below the Government’s cost estimate and excludes any
costs for upgrading local networks. The Department for Transport - Electric Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading
networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Comment

Representation ID: 4718

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

In respect of EVCPs, The Department of Transport Consultation Response:
Electric Vehicle Charging Points (EVCP) in Residential & Non-Residential Buildings dated November 2021 sets out that from 15th June 2022 new dwellings with associated parking within the boundary of the dwelling) will have at least 1 EVCP per dwelling. Therefore, it is no longer necessary for the Council to have a proposed policy requirement for EVCPs. It is noted that the Council’s Viability Assessment includes a cost of only £500
per EVCP. This cost is below the Government’s cost estimate and excludes any costs for upgrading local networks. The Department for Transport - Electric
Vehicle Charging in Residential & Non-Residential Buildings consultation estimated a cost of £974 per EVCP plus an automatic levy for upgrading networks capped at £3,600. This is not reflected in the Stage 2 Viability Study.

Object

Representation ID: 4767

Received: 19/12/2022

Respondent: Mrs Joanne Harding

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The HBF is supportive of encouragement for the use of electric and hybrid vehicles via a national standardised approach implemented through the Building Regulations to ensure a consistent approach to future proofing the housing stock. Part S of the Building Regulations ‘Infrastructure for the charging of electric vehicles’ has now been published and took effect from 15th June 2022.

Object

Representation ID: 4826

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Support the provision of electric vehicle charging points in principle. Part S of the Building Regs. now set out the national requirements for EV charging point requirements in new developments. There is no need to repeat these and no justification to go beyond them, therefore the references in the plan to EV charging points in Appendix 1 should be deleted.

Object

Representation ID: 4836

Received: 22/12/2022

Respondent: South Staffordshire College

Agent: Carter Jonas

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

At South Staffordshire College, due to the campus' location, 1 space per 5 staff and 1 space per 3 students would be excessive and lead to a significant amount of cycle storage remaining unused, detracting from the character and appearance of the site and surrounding area.

We request an additional sentence is added into Draft Policy HC16: South Staffordshire College (Rodbaston) to confirm the parking requirements set out in Appendix I are not applicable to our client’s site. This would ensure the Development Plan is justified by creating an appropriate strategy based on proportionate evidence.

The Parking Standards also require colleges to provide 20% of available car parking spaces to be fitted with a fast charge socket and a further 20% of available spaces to be provided with power supply to provide additional fast charge sockets. We strongly support the principle of providing the infrastructure to enable the transition towards electric vehicles. However, South Staffordshire College have power limitations which will restrict the infrastructure which can be brought forward without the provision of an additional power line which would be a significant financial expense. To ensure the Publication Plan is deliverable over the plan period and therefore meets the test of ‘soundness’ in respect of effectiveness, the wording should be amended to caveat that it will be assessed on a case by case basis, taking into account viability and existing infrastructure provision.

Object

Representation ID: 4846

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Part S of the Building Regulations ‘Infrastructure for the charging of electric vehicles’ has now taken effect and provides guidance on the installation and location of electric vehicle charge points (EVCPs). The policy should avoid repeating electric vehicle requirements which are otherwise secured through Building Regulations and which may risk a lack of accordance with the Regulations should requirements change during the lifetime of the Plan.

Comment

Representation ID: 4890

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Part (e) of the Policy references Appendix I of the Plan which sets out parking standards, in relation to electric vehicles. Bellway support the Council’s endeavours to
encourage electric vehicle uptake.
Part S of the Building Regulations ‘Infrastructure for the charging of electric vehicles’ has now taken effect and provides guidance on the installation and location of electric vehicle charge points (EVCPs). It states that a new residential building with associated parking must have access to EVCPs and that their total number must be equal to the number of parking spaces if there are fewer parking spaces than dwellings, or the equal
to the number of dwellings where there are more parking spaces. The Regulations also set technical requirements for the charging points these include having a nominal
output of 7kW and being fitted with a universal socket.
The policy should avoid repeating electric vehicle requirements which are otherwise secured through Building Regulations and which may risk a lack of accordance with the Regulations should requirements change during the lifetime of the Plan.

Comment

Representation ID: 4929

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

Part (e) of the Policy references Appendix I of the Plan which sets out parking standards, in relation to electric vehicles. Bellway support the Council’s endeavours to
encourage electric vehicle uptake.

Part S of the Building Regulations ‘Infrastructure for the charging of electric vehicles’ has now taken effect and provides guidance on the installation and location of electric vehicle charge points (EVCPs). It states that a new residential building with associated parking must have access to EVCPs and that their total number must be equal to the number of parking spaces if there are fewer parking spaces than dwellings, or the equal
to the number of dwellings where there are more parking spaces. The Regulations also set technical requirements for the charging points these include having a nominal
output of 7kW and being fitted with a universal socket.

The policy should avoid repeating electric vehicle requirements which are otherwise secured through Building Regulations and which may risk a lack of accordance with the Regulations should requirements change during the lifetime of the Plan.

Object

Representation ID: 5016

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey recommends that the Council acknowledges the diversity of different charging speeds depending on the type of vehicle and charging location. At present, there are many different types of EVCP infrastructure depending on the manufacture of the EV. As such, one EVCP may not suit the EV demands of all future residents. This reflects the fact that the EV market is still at a relatively early stage but is becoming increasingly diverse. Moreover, one disadvantage of installing EVCPs across an entire development is that there is a significant level of uncertainty over how much infrastructure will be required by when.
In consideration, Taylor Wimpey considers that a planning policy that requires the provision of underground cabling and/or ducting for an EVCP is put in place. This would allow for the proportional expansion of the charging network in the future as demand grows, with minimal disruption and additional cost for excavation and labour. This would allow residents to easily install the necessary EVCP required to meet their needs as when this is required; a process that does not require planning permission and can be done through Permitted Development Rights (Part 2 Class D & E). Such modified wording would ensure the Policy is justified as per NPPF paragraph 35(b), and “aspirational but deliverable” as per NPPF paragraph 16(b).Taylor Wimpey considers that it would be more appropriate for developments to make provision for appropriate cabling/infrastructure rather than installation of EVCP themselves. This is because this allows future residents to ensure vehicle specific EVCP are installed at the relevant time they take occupation of the house. Fundamentally, it ensures a consistent approach to future-proofing the housing stock and allows the policy to be more flexible as demand and technologies change and improve over time.
It has been acknowledged that the cost of EVCPs has been included within the Council’s Viability Assessment which includes an allowance of £500 per dwelling for an EVCP. However, neither the Viability Assessment nor its Appendix 1 justify this cost. Taylor Wimpey notes that the Government’s estimated cost for the installation of EVCPs is £976 per car parking space for an average home

Support

Representation ID: 5304

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Support proposed parking standards and particularly reductions in on site parking where developments well served by public transport. It is noted that council’s estimate for costs per EVCP is lower than the Government’s cost estimate and excludes costs for upgrading local networks.

Object

Representation ID: 5305

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is not consistent with national policy as currently drafted and should be amended as suggested.

If the policy is to be retained, it should accurately reflect the national Building Regulations standard which states that the total number of charging points must be equal to the number of parking spaces if there are fewer parking spaces than dwellings, or equal to the number of dwellings where there are more parking spaces.

The Council will also need to keep monitoring viability implications here, as the 2022 Viability Study recognises that the cost of providing charging points has increased significantly since 2021,

Object

Representation ID: 5395

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

If policy to be retained it should reflect national building regulations. Council need to keep monitoring viability implications to accurately reflect EV charging point costs.