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ID sylw: 108472

Derbyniwyd: 07/03/2025

Ymatebydd: Magdalen College, Oxford

Asiant : Savills

The Magdalen College, Oxford is committed to highly energy efficient development so the principle of this Direction is supported. However, we strongly consider that the drive to net zero should be achieved through a national approach.
Criterion A of the proposed policy position would require all new development to demonstrate net zero operational carbon from total energy use (by achieving a 63% reduction in regulated emissions on site compared to 2021 building regulations. All improvements will be calculated using SAP.
The College considers that building regulations is the appropriate mechanism for delivering carbon reduction emissions. This standard approach provides certainty to housebuilders as efficiencies in supply chains will encourage delivery. These locally set standards complicate matters and could frustrate development.
Any locally set requirements must be consistent with the Written Ministerial Statement (WMS) published on the 13th of December 2023 and this has been confirmed by case law during 2024. The WMS sets out concerns that setting local standards increases complexity, reduces economies of scale and adds to the cost of building new homes. It is noteworthy that the Future Homes Standard will also be introduced nationally before this Plan is adopted and will likely further make the need for local standards superfluous.
Furthermore, there should be allowances for individual developments to make a financial viability case when achieving the requirements of this policy would render a proposal unviable.
It is important that the effect of costs is considered cumulatively along with other development costs. It is also particularly important to undertake ongoing monitoring and ensure that the standards sought are achievable so that housing delivery is not unduly restricted.