BASE HEADER

No

ID sylw: 107952

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

This policy stipulates new buildings should be designed and built to be net zero. This exceeds requirements in the Building Regulations. The Government’s response to the Future Homes Standard consultation in 2023 stated policy shouldn't be prescriptive on methodology and technology. Until there is an upgrade to the grid, developers only need to demonstrate dwellings are zero carbon enabled.

The Government don't expect plan-makers to set standards that go beyond current or planned Building Regulations. Existing standards don't have to be duplicated in planning policies. The Councils don't have a well-reasoned and robustly-costed rationale and haven't undertaken viability assessments. This policy is therefore unsound. Onerous energy efficiency requirements can severely undermine development viability. This should have been acknowledged in the SA.

The industry is moving towards zero-carbon ready housing as standard. Transitional arrangements must be in place to ensure this can be done smoothly. The plan must avoid onerous requirements which may jeopardise short-term delivery. Note that achievement of net zero is unlikely to be feasible for all developments, particularly urban brownfield developments. Policy should be flexible/deferential to changes in national standards.

The stepped change to zero carbon under the programmed future Building Regulation changes gives developers certainty and allows the industry to develop solutions collaboratively. Following this standard allows the industry to benefit from cost efficiencies and certainty associated with delivery of mass-produced proprietary products, which will better address viability and delivery of development to meet the Council’s planned housing trajectory.

The supporting text indicates relying on Building Regulations alone will be insufficient to achieve net zero by 2050. However, Building Regulations are under continuous review and the Government are aware of the need to meet net zero. Building regulations will continue to evolve when appropriate..