Question 4 relates to biomass/wood fuel from local sources, and Core Strategy Policy SRM1 (i), which requires schemes of 100+ dwellings to consider the potential for CHP. Para 6.22 of the DaSa confirms that evidence to date suggests that this threshold is too low, and it is noted that a CHP could not be secured at the strategic development at North East Bexhill, for over 1,000 units.

Since the Core Strategy was adopted, there have been a number of changes to the Governments approach to energy, and standards set out within planning policy. Most recently (via the Housing and Planning Bill) the Government has committed to a review of energy performance requirements under Building Regulations. The Government is clear that it aims to strike a balance between carbon goals and
the stimulation of growth in the house building industry.

The NPPF (para 173) states that, when pursing the delivery of sustainable development, careful attention must be given to the 'viability and costs in the plan-making and decision process/ CHP are expensive, and have the potential to render housing development unviable. This would not aid the stimulation of housing delivery, in accordance with Government objectives. Rather, it could hinder the delivery of growth by imposing increased costs on development, and is not "justified" or "effective", in accordance with the NPPF.

In this regard, no viability assessment work is available to demonstrate that RDC has considered the implications of CHP on sites of any size. It is therefore considered that reference to the consideration of CHP should be removed in totality, rather than a new "threshold" being set.