South Gloucestershire New Local Plan Phase 1 Responses

Local Plan 2020

List of answers to the specified question
NameResponseDate
Redcliffe Homes No comments. 01 Jun 2021 13:16
Waddeton Park Ltd - Land at Hi… 74. As a general principle, Waddeton Park Ltd supports the need to deliver net Carbon zero development in a managed way that is viable, but it must be consistent with the Future Homes Standard being rolled out in 2021/2022 and fully applied by 2025.

75. The approach to achieving net zero Carbon will often be different on each site, depending upon its location, landform, and other factors such as the need to respond to the character of a particular area. Whichever route is followed by SGC, it should not over prescribe the method of reaching net zero Carbon and should not compete with changes to statutory Building Regulations which in due course will also prescribe necessary standards and approaches.

76. Off-setting should not just be related to a fixed payment per tonne of CO2 but should equally be able to form part of a wider on or off-site mitigation scheme and the policy should reflect this.

77. If the Council were to consider pursuing Option 2, the application of item 2(b) in respect of residential development is too prescriptive.

78. Whether Option 1, Option 2 or another option is pursued, it will need to form part of the whole Plan viability testing exercise to demonstrate that it is deliverable alongside other obligations. Indeed, SGC may need to focus on infrastructure efficient schemes to support the proposed approach and reduce environmental and financial costs which can be recycled into energy management.

79. Given the very specific nature of the proposals for addressing Energy Management it is suggested that SGC engages with the development industry to collectively explore ways in which the policy can be delivered. This would lend support to the process and reduce viability risks being raised later in the Plan’s preparation. We would welcome an opportunity to discuss energy management and how it can be delivered with SGC. The only concern at this stage is the ability of complex Brownfield sites which underpin the Urban Lifestyles approach, to viably delivery the energy management expectations. SGC will need to present evidence to show that a range of Brownfield sites can achieve this.
17 May 2021 18:40
Ivywell Capital (IC) 6.6 Again, we support the need for Carbon neutrality to be secured in new housing and for this to be achieved from the outset, rather than through opportunities for retrofitting at a later date.

6.7 The only matter that is worth noting is that unregulated energy is difficult to predict given that it is heavily influenced by user behaviour. In the interests of clarity, we would welcome a fixed per dwelling target being set out within the policy which has been subject to a robust viability assessment. This will make it clear at the Development Management stage where compliance or non-compliance has been demonstrated with this policy.
17 May 2021 15:38
Bristol and England Properties… 6.6 Again, we support the need for Carbon neutrality to be secured in new housing and for this to be achieved from the outset, rather than through opportunities for retrofitting at a later date.

6.7 The only matter that is worth noting is that unregulated energy is difficult to predict given that it is heavily influenced by user behaviour. In the interests of clarity, we would welcome a fixed per dwelling target being set out within the policy which has been subject to a robust viability assessment. This will make it clear at the Development Management stage where compliance or non-compliance has been demonstrated with this policy.
17 May 2021 10:52
South West Housing Association… We support the Council’s commitment to be Carbon neutral by 2030. As Housing Associations we recognise the need to future proof homes particularly with Future Homes Standard due to be adopted by 2025. Our members are already building energy efficient homes in advance of the Future Home Standard adoption. Moreover, promoting sustainable development is the core objective of the planning system and it is important all new developments continue to support this aim.

There are a number of working draft policies at Appendix 2 which concern Climate Change mitigation, energy management and electric car charging. We support these draft policies where the Council can show that they have been robustly viability tested. While these policies are essential for futureproofing our communities, they should not restrict the delivery of much needed affordable housing in South Gloucestershire, especially as affordability remains a key issue for the Council.
14 May 2021 19:19
Newland Homes - Land at Aust Road 6.7 Again, we support the need for Carbon neutrality to be secured in new housing and for this to be achieved from the outset, rather than through opportunities for retrofitting at a later date.

6.8 The only matter that is worth noting is that unregulated energy is difficult to predict given that it is heavily influenced by user behaviour. In the interests of clarity, we would welcome a fixed per dwelling target being set out within the policy which has been subject to a robust viability assessment. This will make it clear at the Development Management stage where compliance or non-compliance has been demonstrated with this policy.
14 May 2021 17:12
Newland Homes - Land West of T… 6.6 Again, we support the need for Carbon neutrality to be secured in new housing and for this to be achieved from the outset, rather than through opportunities for retrofitting at a later date.

6.7 The only matter that is worth noting is that unregulated energy is difficult to predict given that it is heavily influenced by user behaviour. In the interests of clarity, we would welcome a fixed per dwelling target being set out within the policy which has been subject to a robust viability assessment. This will make it clear at the Development Management stage where compliance or non-compliance has been demonstrated with this policy.

6.8 My client has committed on existing ongoing development sites in South Glos to Carbon zero (energy) and are very much committed to addressing Climate Change on this site at Thornbury.
13 May 2021 17:52
Persimmon Homes Severn Valley Please see attached document.

New Policy: Energy Management in New Development:

6.6 We support the principle of this policy, however, it is important that proposals are considered on their individual merits including taking into account factors such as the availability of technology and viability. We note that the supporting text describes Option 1, that is to say, requiring a 100% reduction in Carbon emissions from regulated energy use has been tested through the Local Plan viability study, however, the link to that document has been omitted.

6.7 We also note that Option 2, that is to say requiring a 100% reduction in Carbon emissions from regulated and unregulated energy use has not been tested through the Local Plan viability study. It is also difficult to understand how the approach to unregulated energy use could be enforced in the longer term and once the developer had moved off the site.

6.8 As observed above, the link to the Local Plan viability study appears to be missing from the consultation document. We note that the Local Plan Evidence webpage includes a document entitled “Cost of Carbon reduction in new buildings” but it is not clear whether this is the document being referred to. Notwithstanding that, it is dated December 2018 and is therefore considered dated.

6.9 It is also of relevance that the Future Homes Standard (FHS) was consulted on by Central Government in early 2020 with the Government’s response to those comments received being published on 19th January 2021.

6.10 As this (the FHS consultation) represents the first stage of a two-part consultation on proposed changes to Part L (Conservation of fuel and power) of the Building Regulations, we would suggest that the outcome of the entire process should be considered in formulating future policy.
11 May 2021 18:35
Strongvox Homes Energy Management in New Development:

6.6 Again, Strongvox Homes are committed to delivering Carbon neutral homes and buildings on their sites and wholeheartedly support the need for this to be achieved from the outset, rather than through opportunities for retrofitting at a later date.
11 May 2021 18:08
Progress Land Ltd No. 11 May 2021 13:45
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