Bloor Homes broadly support the aspiration of this policy. However, the policy must be sufficiently flexible to allow for location and context-specific considerations to be taken into account in the delivery of development. For instance, it might not be feasible or viable for specific mitigation measures, such as renewable energy, to be incorporated into a specific development scheme.

Bloor Homes has adopted a holistic fabric first approach in their house type design as an alternative to renewable energy infrastructure, which seeks to reduce each dwelling's inherent energy demand. The approach also includes the installation of water saving appliances to aid water efficiency, highly efficient gas condensing boilers to reduce fuel costs, and gas savers and waste water heat recovery systems to reduce carbon emissions. This fabric first approach has a number of clear benefits, notably that it is built into the property for its whole life and achieves the aim of reducing CO2 emissions. In comparison to renewable technologies there is no maintenance required, and it avoids the concern as to whether the technologies are actually being used.

Part 1 of the policy should, therefore, allow greater flexibility by including reference to the potential inclusion of alternative measures to mitigate climate change. As with Part 2 of Policy CC1 in relation to SDAs, reference should also be made within Part 1 to the associated impact on the viability of development in demonstrating what measures can be incorporated into a scheme.

Soundness:
Bloor Homes object to Policy CC1, which is considered unsound on the basis that it:
- is not effective as a means of ensuring development mitigates climate change without unduly restricting the viability and/or delivery of development.

Proposed Changes:
To remedy the flaws in the soundness of the plan the policy should be reworded include reference to "alternative measures, such as a fabric first approach, as appropriate to the site and demonstrated by the developer to meet overarching climate targets".