Publication Plan November 2022

Object

Representation ID: 4931

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy requirement for regulated net zero is an unnecessary repetition of 2021 Part L Interim Uplift and the Future Homes Standard. It is the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to decarbonising Staffordshire’s energy demand is to recognise the need to move towards greater energy efficiency via a nationally consistent set of standards and timetable, which is universally understood and technically implementable. Therefore, the Council does not need to set local energy efficiency standards to achieve the shared net zero goal.

The policy requirements around sustainable construction should also be left to building regulations and should not require a betterment above the requirements in the latest Building Regulations.

Should the Council seek to continue with Policy NB6 in its current form, Gladman also hold several significant concerns in respect of the third element of the policy which states that all major development must demonstrate how the embodied carbon of the proposed materials to be used in the development has been considered and reduced where possible.

the policy fails to differentiate between the levels of detail required between Full, Outline and Reserved Matter applications which could seriously undermine the overarching aims.

relation to the performance and monitoring aspect of the third element of the policy, it is not clear what the Council would do with the information in relation to performance information or the monitoring information once the development is completed.

Gladman do not consider it is likely that any household would wish to share their personal energy usage information with the developer of the site or the Council. The requirements are exceptionally excessive and would appear to intrude into people’s privacy.