Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15904

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16463
BDW supports a clear and consistent approach to sustainable design and energy efficiency. The National Design Guide energy hierarchy provides a nationally recognised and balanced framework that prioritises energy demand reduction, energy efficiency, and the use of low-carbon and renewable energy sources. As such, BDW considers it appropriate for the Local Plan to adopt this hierarchy, provided it is applied flexibly and in a manner proportionate to site-specific constraints and viability considerations. It is important that any adopted energy hierarchy aligns with national policy and avoids introducing prescriptive local requirements that could conflict with or duplicate national standards.

Comment

Representation ID: 15906

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16465
BDW does not support the introduction of higher local standards that go beyond those set out in national Building Regulations. The Building Regulations are the appropriate mechanism for securing energy efficiency and carbon reduction in new development, and they are subject to regular review and updates to reflect national policy objectives, including the transition to net zero. Introducing locally specific standards risks fragmenting policy requirements, adds complexity to the planning process, and may impact development viability. As above, BDW therefore considers that the Local Plan should align with national standards and avoid setting additional local requirements.

Comment

Representation ID: 15909

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16468
BDW are generally supportive of the suggested policy requirements in principle, recognising the importance of promoting energy efficiency, low-carbon energy supply, and water conservation in new development. However, it is noted that the proposed criteria may be overly prescriptive, particularly if all developments, including at the outline stage, are expected to meet all requirements without exception. It is therefore essential that the policy incorporates a degree of flexibility to reflect site specific constraints, viability considerations, and practical feasibility. BDW also supports the inclusion of a carbon/energy offsetting contribution mechanism as a final resort, where on-site measures cannot reasonably be achieved, to ensure a deliverable approach to meeting the Council’s wider sustainability objectives. 

Comment

Representation ID: 15913

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16472
BDW supports the proposed policy approach under DS2, which provides an alternativeroute to compliance where residential development achieves a recognised certification, such as the PassivHaus standard. In such cases, a full sustainable design statement would not be required, and the submission of technical information demonstrating compliance with the relevant standard would be accepted. BDW welcomes this approach. This flexibility is particularly beneficial for volume housebuilders, as it enables sustainability objectives to be met through an approach that is tailored to the specific nature and scale of development. BDW considers that recognising established industry standards is a positive mechanism to support delivery, while avoiding duplication of requirements or the achievement of requirements which are not applicable to certain types of developments.