BASE HEADER

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ID sylw: 108317

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited and Mixed Farms

Asiant : Nexus Planning

Whilst CEG and Mixed Farms understand the importance of planning for net zero carbon development as part of
the broader objective to address climate change. However there is significant concern regarding the approach set
out by Policy Direction 22, which outlines the potential for the SWLP to go beyond the requirements of Building
Regulations.
The Government’s approach to this is clear, and as set out in a Written Ministerial Statement (WMS) dated 13th
December 2023, confirming that planning policies should not impose standards for energy performance that
exceed the Code for Sustainable Homes Level 4, noting the Future Homes Standard (FHS) to be implemented in
2025.
The WMS outlined:
“the Government does not expect plan-makers to set local energy efficiency standards for buildings that go
beyond current or planned building regulations. The proliferation of multiple, local standards by local authority
areas can add further costs to building new homes by adding complexity and undermining economies of scale.
Any planning policies that propose local energy efficiency standards for buildings that go beyond current or
planned building regulations should be rejected at examination if they do not have a well-reasoned and robustly
costed rationale.”
Requiring development to exceed the requirements of Building Regulations is likely to result in unnecessary
complexity and additional costs for developers, threatening the viability of schemes and slowing down the ability
of the industry to respond to and meet the housing and economic needs of the SWLP.
CEG and Mixed Farms therefore strongly urge the reconsideration of the approach set out in Draft Policy
Direction 22 and avoid divergence from the FHS as per the recommendations of the WMS. Any policy which goes
beyond the FHS must be demonstrated to be viable and not hamper the delivery of development required to
meet the SWLP’s requirements.