Object
Publication Draft
Representation ID: 66809
Received: 26/06/2014
Respondent: Gallagher Estates
Agent: Pegasus Group
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The policy is generally supported as realistic and achievable and consistent with national guidance. It is considered, however, that the requirement for applicants to consider the incorporation of CHP on the strategic sites goes beyond what is justified. Paragraph 154, NPPF is clear that local plans should be aspirational but realistic. Specific reference to CHP on site is at risk, therefore, of going beyond what might reasonably be achieved. There is certainly no requirement for CHP to be provided on sites in order to meet national targets or standards. It is for the industry to develop cost effective means of delivering carbon reduction. There may well be issues in respect of viability and introducing potential obstacles to meeting housing needs. As such we do not consider it necessary or justified for the Policy to include specific reference to CHP on the strategic sites. This is at risk of being unsound and should be deleted.
see attached.