Publication Plan November 2022

Support

Representation ID: 5313

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Support policy.

Comment

Representation ID: 5314

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Policy is not unsound but could be improved with the amendments suggested.

Miller wish to emphasise the importance of the policy requirements being drafted in line with the requirements of the Environmental Bill in respect of net gain.

Miller are committed do maximising environmental gains, but suggest a flexible approach to the delivery of the BNG within sites. In a comparable manner to open space discussed above, a pragmatic approach to BNG should be taken where improvements to biodiversity can be delivered in conjunction with open space provision, so as not to put unreasonable pressure on developable area and associated viability on sites.

Support

Representation ID: 5315

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Support policy.

However welcome confirmation that the previously suggested approach of offsite Suitable Alternative Natural Greenspaces (SANGs), is not being pursued at this time.

Support

Representation ID: 5316

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Support policy

Object

Representation ID: 5317

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 justified or consistent with national policy as currently drafted and should be amended as suggested unless further evidence is provided.

As noted by the HBF, the key to success is standardisation and avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for suppliers and developers. Variations in regulations also provides developers with less certainty in terms of what is required of them. The Council does not need to set local energy efficiency standards to achieve the shared net zero goal,
because of the higher levels of energy efficiency standards for new homes set out in the 2021
Part L Interim Uplift and proposals for the 2025 Future Homes Standard.

It is noted that Inspectors examining the Salt Cross DPD in West Oxfordshire have raised concerned over a requirement for development to demonstrate net zero operational carbon on-site through ultra-low energy fabric specification, low carbon technologies and on-site renewable energy generation. The Inspectors have proposed instead that development will be required to demonstrate an ambitious approach to the use of renewable energy, sustainable design and construction methods, with a high level of energy efficiency in new buildings. Whilst the justification for this amendment is awaited, the difference between national and local requirements has clearly been held to be unsound.

There are concerns that the figures in the 2022 Viability Study for assumed carbon reduction measures include no detailed workings to support these percentage costs.

A case for clear need to introduce these optional water efficiency standards has yet to be provided. Indeed, we note that The Water Cycle Study (2020) identifies the Severn Trent Water and South Staffordshire Water supply regions as areas of only moderate water stress. Therefore, this policy is unsound until this information has been provided, as there must be a clear and robust evidence base to support this.

Support

Representation ID: 5318

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Support policy

Support

Representation ID: 5319

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Generally supportive of the proposed framework but additional clarity requested.

We do not make any detailed comments on the proposed monitoring framework in Appendix J other than to note it only addresses the strategic objectives of the plan and their associated key policies. We presume this covers all strategic policies, but this is not made clear, and therefore it would be useful to confirm in this section (or the list of policies at the beginning) those which are subject to monitoring and those which aren’t.