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ID sylw: 108826

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land-Land east of Stratford-on-Avon

Asiant : Savills

Bellway supports the need to utilise low carbon heating for new development. However, further consideration needs to be given to the feasibility and suitability of including requirements for decentralised energy systems to provide heating and cooling.
The 2025 Future Homes Standard (FHS) and Future Buildings Standard (FBS) Consultation { https://www.gov.uk/government/consultations/the-future-homes-and-buildings-standards-2023-consultation/the-future-homes-and-buildings-standards-2023-consultation} set out requirements which will significantly reduce the energy demand of new homes and buildings, this will reduce the thermal demand of new development.
Currently the majority of district heating schemes make use of gas fired Combined Heat and Power (CHP) systems to generate electricity and heat. However, the continued decarbonisation of the electricity network means that this option will emit more carbon than compared to an individual gas boiler.
Future Heat Networks will need to incorporate low carbon technologies, for example Air Source Heat Pumps, or make use of low carbon waste heat from other sources. This type of system does not benefit from the electricity generation in a CHP system which has implications for the financial viability of alternative sources.
Development coming forward after the introduction of the FHS and FBS will only be able to connect to heat networks where the energy demand of the new buildings is matched by equivalent low carbon heat, i.e. delivered through the use of a heat pump.
There may be discrete opportunities for heat networks where there are opportunities around an existing low carbon heat course, or sufficient density, for example large scale blocks of flats. This is noted in the FHS consultation, which states, ‘New low carbon communal and district heat networks will likely be the preferred way of providing heating and hot water to blocks of flats under the Future Homes Standard’. However the consultation anticipates the use of heat pumps in homes and buildings to provide heating and hot water, the policy is therefore unlikely to suit new low density development.
Further to the technical constraints noted above the Council’s evidence base supporting this particular policy does not adequately consider the implications of the FHS and FBS on the likely heating requirements and heat density of new development. Nor does it consider the cost and viability of this type of system at this stage. When considering cost consideration should be given to the implications of delivering heat networks and tying residents into long term heating contracts with no options on choice of network supplier. It is noted that while work is ongoing to regulate heat networks, heat networks are currently not regulated by Ofgem and pricing is not restricted which may impact residents energy costs.
In this context it is considered unlikely that the reduced energy demand of new development is unlikely to provide sufficient heat demand for a low carbon heat network to be feasible or viable for low destiny development. It is recommended the Council give further consideration to the technical feasibility of heat networks and costs as part of the next stage of Plan preparation to ensure any proposals are feasible and viable.