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ID sylw: 107908

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Whilst Terra supports the SWAs moving towards Net Zero Carbon development, as set out
in detail in Terra ’s response to Draft Policy Direction- 24 (Embodied carbon), if the SWAs
wish to deviate from the Future Homes Standard and Building Regulations, sufficient
evidence will need to be prepared to justify this – in accordance with NPPF paragraph 32,
the PPG and the 2023 WMS.
2.103 In addition, the NPPF is clear that planning policies should have regard to the economic
viability of sites (Para 72) and should not undermine the deliverability of the Local Plan
(Para 35). To this end, the SWLP will need to be supported by a Viability Assessment that
cumulatively tests the impact of policy and infrastructure requirements on the viability of
sites allocated in the SWLP. This should include any Net Zero Carbon requirements.