Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 1997

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2113
The HBF considers that the Council should ensure that this policy does not conflict with other requirements in terms of design, renewable provision, BNG, density etc, and in terms of other regimes such as building regulations.

Comment

Representation ID: 1998

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2114
Heat networks are one aspect of the path towards decarbonising heat, however currently the predominant technology for district-sized communal heating networks is gas combined heat and power (CHP) plants. Over 90% of district networks are gas fired. As 2050 approaches, meeting the Government’s climate target of reducing greenhouse gas emissions to net zero will require a transition from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery but at the moment one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. The Council should be aware that for the foreseeable future it will remain uneconomic for most heat networks to install low-carbon technologies. Furthermore, some heat network consumers do not have comparable levels of satisfaction as consumers on gas and electricity networks, and they pay a higher price. Currently, a consumer living in a building serviced by a heat network does not have the same opportunities to switch supplier as they would for most gas and electricity supplies.

Comment

Representation ID: 1999

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2115
The HBF considers that the Council should ensure that all of their policy requirements are fully justified and evidenced, the proposed evidence is likely to be necessary alongside other documents to justify the policy requirements in the Plan. The Council will also need to ensure that they have considered viability, viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative costs of all relevant policies will not undermine deliverability of the Plan. The Council needs to ensure that policy requirements should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned development to be deliverable without need for further viability assessment at the decision-making stage.

Comment

Representation ID: 2000

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2116
The HBF recommends that the Council include an appropriate monitoring framework which sets out the monitoring indicators along with the relevant policies, the data source and where they will be reported, this should also include the targets that the Plan is hoping to achieve and actions to be taken if the targets are not met. The HBF recommends that the Council provide details as to how the plan will actually be monitored, and identifies when, why and how actions will be taken to address any issues identified.