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ID sylw: 107744

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

Bellway supports the transition to delivering Net Zero development, however has concerns over elements of the policy as currently drafted which go against national Government guidance, have design implications which have not been thought through, and will have viability issues not yet considered. Below a number of key issues have been identified and are considered.
As part of the Bristol Local Plan Review examination the Examiner has reviewed Bristol’s Net Zero policies which set out similar energy performance targets, and as part of the main modifications has removed these requirements3 . In place of the energy performance targets the modifications include a requirement for development to achieve a 100% reduction in regulated carbon emissions only. This reason for the change is noted as the 2023 WMS set out above.
In this context it is considered that as proposed Policy contradicts the Government’s WMS and as such the space heating, total energy use and energy performance requirements should be removed or reconsidered to align with the 2023 Future Homes and Buildings Standard Consultation and WMS which describes Net Zero Ready development.
While we support the delivery of low carbon development it is considered any targets should be restricted to regulated energy only.
With regards to air tightness the FHS consultation notes that as part of the consultation consideration was given to, ‘better walls, floors, roofs, triple glazing and improved thermal bridging. However, the only cost effective and practical improvement we found could be made to the standard was an improvement in airtightness. This improvement in airtightness is matched with the change to a decentralised mechanical extract ventilation system’.
We support the provision of Solar PV to provide onsite energy generation, however, this expectation is not likely to be feasible across a development with a mix of housing including flats, bungalows and homes. Delivering 3kWp – 4kWp per dwelling will require c.24-32m2 of roof space, which for smaller units will not be achievable. Furthermore, where there may be sufficient roof space available it is likely that this requirement would have unintended design implications, reducing the potential for design including roof lights, dormer windows, split roofs etc which are often considered a requirement to create a well-designed development.
It is noted that the form factor targets set out here are recommendations only, we would recommend that it is noted that these are set out in the context of needing to balance design with performance.
It is recommended that the Plan considers the approach and Policies set out in the Warwick District Council Net Zero DPD which requires development to achieve Net Zero Carbon in operation. This provides a route to achieving Net Zero this which aligns with the Governments 2025 FHS and FBS, and 2023 Written Ministerial Statement on setting requirements which exceed the requirements of the Building Regulations.