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ID sylw: 50814

Derbyniwyd: 02/08/2012

Ymatebydd: Bluemark Projects

Asiant : Pegasus Group

Crynodeb o'r Gynrychiolaeth:

There is concern that this policy approach lacks flexibility and is not the most appropriate strategy. In particular, it is not in accordance with Paragraph 95 of the NPPF.
Reducing energy use through a 'fabric first' approach is something that many developers are currently looking at and is therefore a realistic and deliverable way forward for reducing carbon emissions. For example the AimC4 consortium is seeking ways to achieve the 25% CO2 reduction required between the future Part L 2013 building regulations and the current Part L 2010 building regulations at no additional cost. This would effectively move, in relation to Part L, from Code for Sustainable Homes Level 3 to Level 4 without increasing build costs.

Any future policy on CO2 reduction should begin with energy conservation and efficiency before looking at on-site or off-site renewables / low carbon solutions. The way in which new residential development will meet the carbon reductions required in building regulations is not prescribed and therefore could comprise of a range of solutions but it appears that 'fabric first' is generally the route being pursued by house builders, and as such is a realistic cost effect way of delivering reductions. In view of the fact that carbon reduction is enshrined in current and future building regulations legislation there is no basis for adding a further layer of policy through in the Local Plan. In addition, all development must be planned for its lifetime. Reliance on technologies which may well stop working or become obsolete before the end of the life of the development should therefore be avoided. It is, for example, questionable whether solar PV panels imported from the Far East and added to developments represent a sustainable, long term solution to reducing carbon emissions.

The reference to on-site energy efficiency measures and low or zero carbon energy generation to meet a carbon reduction equivalent to 20% of predicted energy requirements is not considered to be justified. As noted above the 2013 Part L building regulations will already see a 25% improvement in CO2 emissions over current Part L building regulations (and a 44% improvement over the 2006 version). By aligning Category 1 (Energy and Carbon Dioxide Emissions) of the Code for Sustainable Homes with Part L of the building regulations the Government are maintaining a realistic timetable to reducing carbon emissions. The emerging Local Plan is taking a contrary approach whereby it is seeking to force measures onto new development prior to the national timetable without exploring the consequences.
In reality, in respect of house building it is the market that will really dictate the level of energy efficiency and carbon reduction in new homes over and above legal requirements. If buyers are prepared to pay the additional premium for zero carbon homes then the development industry will build them. However at the moment evidence suggests that reducing carbon emissions is not top of the list when purchasing a property, particularly when peoples' incomes are under pressure from other sources.