Q-C6.1: Please select the option which is most appropriate for South Warwickshire
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire We are generally supportive of Option C4.1c – a phased approach to net zero carbon -setting a future date by which all new development will need to achieve net zero standards. L&Q Estates are committed to responding to the climate crisis and are actively looking to deliver housing to standards above those set out in current building regulations in response to this challenge. Indeed, their most recent Corporate Strategy includes a commitment to setting an L&Q design standard in response to the emerging Future Homes Standard, as well as more broad investment in modern methods of construction. However, it is important to note that renewable and low carbon energy dwellings may not always be practicable or viable in new developments. Therefore, we are supportive of Option C4.1c insofar as this option allows time for the cost of achieving these standards to come down, and may mean that more affordable housing and community benefits can be secured from development.
selected
selected
selected
No answer given
Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. The council should include a policy that requires net zero carbon requirements for all building proposals that require planning permission, including conversions, changes of use, and householder residential applications.
selected
selected
selected
No answer given
Warwick District Council should set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. The council should include a policy that requires net zero carbon requirements for all building proposals that require planning permission, including conversions, changes of use, and householder residential applications.
selected
selected
selected
No answer given
Issue C4: New Buildings Q-C4.1 We consider that there is no requirement to have a specific policy covering the energy efficiency standards of new development. This would be a duplication of Building Regulations which are being updated regularly to reflect the national desire to reduce carbon dioxide emissions from previous standards. The frequency of changes to Building Regulations will probably mean that plans adopted to align with current standards will soon be out of date. Issue C6: Whole Life-Cycle carbon emissions assessments Q-C6.1c – none of these. The requirement for such an assessment would be unduly onerous on the developers and we would argue that Building Regulations and the need to comply with them, will adequately safeguard emissions to agreed levels (set nationally by the Government).
selected
selected
selected
Any threshold needs to be realistic and supported by evidence, with transitional arrangements to ensure the development industry is able to take account and adapt to these requirements.
Q-C4.1: Please select all options which are appropriate for South Warwickshire It is considered that Option C4.1 which does not seek a policy in respect of net zero carbon buildings and to allow compliance with Building Regulations is most appropriate. Applying standards in excess of Building Regulations, or standards which change part way through the Plan Period is considered wholly inappropriate and would create uncertainty and viability issues. By relying on Building Regulations, this will ensure a consistent approach and certainty for developers / housebuilders when calculating development costs. Q-C6.1: Please select the option which is most appropriate for South Warwickshire Option C.6.1.b – Include a policy that has different whole lifecycle reduction targets for different scales and types of developments and for different time periods As stated, this would allow time for the development industry to take account of and adapt to these requirements and ensure that developments are fully viable so that they can come forward to meet the area’s development needs. Any policy requiring these assessments to be completed would need to reflect and be proportionate to different scales of development. There are also references to both a reduction of 55% and 100% and it is unclear what the Council are seeking to achieve. We consider it is appropriate to have a high level policy that is then supported by more specific guidance in a future LPG (for example, how they have approached this with the London Plan 2021).
selected
selected
selected
Any threshold needs to be realistic and supported by evidence, with transitional arrangements to ensure the development industry is able to take account and adapt to these requirements.
Q-C4.1: Please select all options which are appropriate for South Warwickshire It is considered that Option C4.1 which does not seek a policy in respect of net zero carbon buildings and to allow compliance with Building Regulations is most appropriate. Applying standards in excess of Building Regulations, or standards which change part way through the Plan Period is considered wholly inappropriate and would create uncertainty and viability issues. By relying on Building Regulations, this will ensure a consistent approach and certainty for developers / housebuilders when calculating development costs. Q-C6.1: Please select the option which is most appropriate for South Warwickshire Option C.6.1.b – Include a policy that has different whole lifecycle reduction targets for different scales and types of developments and for different time periods. As stated, this would allow time for the development industry to take account and adapt to these requirements and ensure that developments are fully viable so that they can come forward to meet the area’s development needs. Any policy requiring these assessments to be completed would need to reflect and be proportionate to different scales of development. There are also references to both a reduction of 55% and 100% and it is unclear what the Council are seeking to achieve. We consider it is appropriate to have a high level policy that is then supported by more specific guidance in a future LPG (for example, how they have approached this with the London Plan 2021).
selected
selected
selected
No answer given
Q-C4.1: Should be aligned with the national approach. Q-C4.2: Should be aligned with the national approach. Q-C5: Should be aligned with the national approach. Q-C6.1: Should be aligned with the national approach. Q-C7: Should be aligned with the national approach Q-C8: Should be aligned with the national approach.
selected
selected
selected
No answer given
Chapter 7 – ‘A climate resilient and net zero carbon South Warwickshire’ The most important part of this section is 7.2 Zero Carbon Buildings. With currently circa 40% of CO2 from buildings (27% domestic and 13% non-domestic) the issue in terms of carbon reduction in relation to the climate emergency is of the utmost importance. Consider first the definitions included within the glossary of the consultation document. There are three definitions to consider which is quite confusing. Net Zero Carbon: Having Net Zero Carbon dioxide emissions, either by balancing carbon dioxide emissions with removal, or simply eliminating carbon dioxide emissions altogether. "Net Zero: The point at which the amount of greenhouse gases being put into the atmosphere by human activity in the UK equals the amount of greenhouse gases that is being taken out of the atmosphere. Source: Powering our Net Zero Future. Energy White Paper. Department for Business, Energy and Industrial Strategy. HM Government, Dec. 2020." "Zero-carbon: Where no carbon emissions are being produced from a product/service." "The Net Zero Carbon definition in the Glossary is ambiguous and also not completely transparent. What is meant by “balancing carbon dioxide emissions by removal”? Is this allowing offsetting and if so what offsetting is acceptable and what is not acceptable." The wording “….or simply eliminating carbon dioxide emissions altogether” is much clearer and unambiguous. As yet there is not a nationally agreed definition of net zero carbon. This is set to change with an initiative launched in 2022 -the UK Net Zero Carbon Buildings Standard. This is being developed by the following organisations (BBP, BRE, Carbon Trust, The Institution of Structural Engineers, LETI, RIBA Architecture, RICS, UK GBC) with the support of an advisory group of some 500 UK experts. The ambition is to have an agreed definition and a verification process by the summer of 2023. What is clear from the work of the advisory group is that it is almost impossible to get to net zero carbon using the tools currently within the building regulations namely SAP and SBEM. This fact is actually recognised by Warwick District Council (WDC). The following is an extract from a document included within the submission in 2022 for the WDC Net Zero Carbon DPD: "About the energy performance gap The energy performance gap is the difference between the predictions for a designed building's energy use, and the amount of energy it actually uses in operation. This gap arises from a combination of three factors: 1. Poor methods used to predict the energy use of a building (including poor calculations, incorrect assumptions, and exclusion of 'unregulated' energy loads) 2. Errors in construction which lead to worse airtightness or thermal envelope 3. Errors in system operation, and user behaviour different to assumptions (for example, residents turning up space heating while opening windows to dry laundry or not using heat system as intended, or spending more time in the building than anticipated, or retail tenants leaving bright lighting on overnight). Unfortunately, the calculation methods used in Building Regulations Part L (SAP and SBEM) are very poor predictors of the actual energy use of a building. SAP and SBEM are compliance tools. not really tools to predict energy and carbon performance (even though they purport to be). This is not only due to out-of-date carbon factors used for different energy sources, but the entire methodology. This is a key reason for point (1). For this reason, recalculating SAP on completion will not confirm that the building performs to the same metrics as in the SAP output (kWh/m2 and CO2/m2), only that it is built as designed in terms of installed specification of insulation, heating system and renewable energy generation. The nation-wide lack of post-occupation energy monitoring means that both developers and planning/building control enforcers are often unaware of the scale of difference between SAP outputs and actual performance. Point (2) above relates to how imperfections in the construction process can lead to worse energy performance than predicted, even if an accurate energy prediction methodology were used. For example, a building may leak a lot of heat if insulation is incorrectly installed, or if a hatch to a cold loft is put in the wrong place and has to be moved, resulting in unexpected holes in the air tightness membrane. Another risk is that lower-spec products may be used or poor substitutions made in the building - whether for cost-cutting reasons, supply difficulties, or simply because the right person was not available on site at the right time to make the decision within a set deadline." From the above it is clear that WDC are fully aware that the entire methodology of SAP and SBEM are not fit for purpose as compliance tools now and most especially for the requirements of true Net Zero Carbon. It should be noted that there are experts who are of the opinion that the WDC Net Zero Carbon title for the DPD is both incorrect and misleading. In order to provide guidance for a true net zero carbon definition the following might be useful: To understand what is required for true net zero carbon the direction of travel is to get away from % improvements and instead develop what is called an Energy Use Intensity (EUI) target. For housing this could be set at approximately 30 kWh/m2/yr. EUI will include all regulated and unregulated energy – i.e. All metered energy. For low rise housing ALL of the EUI will be met by on site renewables – usually photovoltaic (PV) panels. For apartments higher rise buildings and many non domestic buildings, it is generally not possible to meet all of the EUI with on site renewables and so appropriate offsetting (not including trees) is allowed. More on offsetting later. In order to give an insight of how policy requirements will deliver true net zero carbon the following is an extract from the Cornwall Climate Emergency DPD: "Net Zero Carbon Homes I Recommended Policy Requirements Based on Climate Change Committee guidance, which indicates that residual emissions from new buildings should be negligible, the following approach is recommended to deliver net zero carbon new buildings: Space Heating Demand Limit & Overheating Risk The energy used specifically for heating is a crucial and simple measure of how well the fabric of the building is performing. Space Heating Demand should be required to be less than 15-20 kWh/m2/yr. The risk of overheating should be assessed as 'Low' using the Good Homes Alliance Tool. Fossil Fuel Ban and Total Energy Use Limit There should be no fossil fuels used on site, i.e. no gas or oil boilers in any new properties and no new buildings should be connected to the gas grid. The predicted total energy use, expressed as an Energy Use Intensity (EUI) should be limited in order to ensure that efficient heating systems are adopted and general energy use is reduced.Total energy use in new houses and flats should be less than 35 kWh/m2/yr. Renewable energy to match consumption Photovoltaic arrays should be installed on-site with an output to match the calculated total energy use. In a limited number of cases this may be technically challenging. An energy credit mechanism will be needed to allow developers to pay for the installation of additional PVs elsewhere. Flexible Power Demand The home should be flexible in terms of when it needs to use electricity, so demand can be matched to windy and sunny periods. This can be achieved through good fab ric efficiency and hot water storage. Performance Gap Policy is required to address the performance gap to ensure that net zero buildings are delivered on site. There are various ways this could be achieved. A net zero energy balance on site is assumed to provide a reasonable proxy for net zero carbon, on the basis that solar generation displaces the majority of grid emissions that would otherwise occur. Once the electricity grid has decarbonised, a net zero energy balance ensures the energy needs of new homes are balanced by new solar generation, on a site that has already been developed, rather than a separate greenfield site. The example shown is for an efficient house heated by a heat pump. Each yellow block represents the energy produced by a single solar photovoltaic panel. Five key requirements for a net zero carbon ready new home 1. Ultra-low space heating demands 15kWh/m2/yr 2. No fossil fuels and low total energy use (EUI) 35kWh/m2/yr 3. Renewable energy generation Equal to the EUI 4. Flexible power demands 5. Reduced performance gap" Cornwall Council submitted the Climate Emergency DPD for independent examination in November 2021. The Planning Inspector has confirmed that the plan is sound subject to recommended modifications. The plan can now proceed to adoption on 21st February 2023. A similar ambitious document has also been confirmed as sound by the Planning Inspector in the Bath and Northeast Somerset Local Plan (BNES). Similar ambitious Local Plans are being prepared by Greater Cambridge and Central Lincolnshire amongst others. All have developed a similar direction of travel towards true Net Zero Carbon. It should be noted that a seismic change in building standards is underway in Scotland. All new build homes in Scotland will soon have to meet greater levels of energy efficiency after the Scottish Government agreed to progress legislation proposed by Scottish Labour MSP Alex Rowley. In December 2022 Scottish government ministers announced plans to make all new build housing meet a Scottish equivalent to the Passivhaus standard within the next two years. Work to develop the standard will commence early in 2023, seeking the laying of amending regulations in mid- December 2024. This is a HUGE and potentially game-changing move for building performance, comfort, low energy bills, and climate action in Scotland. Its ripples will extend far beyond Scotland and it is already attracting global attention.
selected
selected
selected
No answer given
7.2- Net Zero Carbon Buildings The consultation document says “With effect from June 2022, changes to Building Regulations mean that all new homes must produce 30% less carbon dioxide emissions than previous standards. From 2025 all new homes will be required to produce 75- 80% less carbon dioxide emissions and will need to be ‘zero-carbon ready’ requiring no further energy efficiency retrofit work to enable homes to become zero-carbon as the electricity grid decarbonises. “ In reality it is almost impossible to get to true net zero carbon using % reduction through the 2021 Building Regulations. The guaranteed way to get to true net zero carbon is to have specific energy targets known as Energy Use Intensity (EUI) – in kWh/m2/y and match this with the generation of renewable energy - where possible on site. (e.g. for low rise housing). A definition for Energy Use Intensity should be added to the Glossary. Importantly there is no mention of the Performance Gap, nor is there a definition of this in the Glossary. This needs to be addressed. Page 125 – states “The National Design Code 2019 identifies the need for new developments to follow the energy hierarchy to: 1. Reduce the need for energy through passive measures, including form, orientation and fabric 2. Use energy efficient mechanical and electrical systems, including heat pumps, heat recovery and LED lights; and 3. Maximise renewable energy especially through decentralised sources, including on-site generation and community-led initiatives” However the National Design Code 2019 has been replaced by the National Model Design Code 2021, which does not have this wording. We suggest the local plan should include the following wording: “ 1. Reduce the need for energy to a target EUI for example 30kWh/m2/yr. for dwellings. Separate targets are needed for regulated and unregulated energy the sum of which amount to the EUI. 2. Use energy efficient mechanical and electrical systems, including heat pumps, heat recovery and LED lights; 3. Renewable energy on site to at least match the EUI. Decentralised sources are not relevant for true net zero carbon low rise dwellings. BREEAM There is no mention of the use of BREEAM in the text. The only mention is in the information relating to existing policy documents from Stratford and Warwick. BREEAM should be included in the Glossary. Stratford use BREEAM ‘Good’ and Warwick use BREEAM ‘Very Good’. Regretfully both are totally inadequate. Clearly there will need to be some consistency across the districts. Although BREEAM does provide sustainable benefits it will not on its own deliver true net zero carbon as demonstrated in the following extract from the Cornwall Climate Emergency DPD recently approved by the Inspector: "Comment on BREEAM BREEAM for net zero carbon For non-residential buildings, a requirement to meet BREEAM Excellent or Outstanding has been considered as a simple and familiar requirement to encourage better energy and carbon performance. However, BREEAM is designed to deliver sustainable buildings but it is not a net zero carbon delivery platform. BREEAM does incorporate calculations of energy demand, energy consumption and carbon emissions but these are opaque measures that are not easily calibrated against other calculation methods. There are additional credits for Post Occupancy measurements which could potentially address Performance gap issues, but these are optional and not mandatory credits, so setting an overall BREEAM target does not give any certainty that this process would be undertaken. Alternative schemes NABERS UK has recently been launched. This is a Design for Performance process to target a specific energy rating at the design stage of a new office development or refurbishment and verify performance when the building is occupied. It is expected to be administered by the BRE, alongside BREEAM and may be suitable for larger commercial schemes. The BRE are currently considering updates to the BREEAM scheme that could, in the future, provide a better structure for delivering net zero carbon, but these are not yet available. Recommendation It is therefore recommended to use specific energy and carbon targets for non-residential buildings. BREEAM Excellent or Outstanding can be required in addition but not in lieu of these requirements." Issue C4 New buildings Page 127 of the consultation document says “Buildings are a major source of emissions for South Warwickshire and so the need to minimise those that are generated from new development is critical in achieving the climate emergency ambitions.” This is absolutely correct, however the way forward proposed in section 7.2 will not deliver this ambition. The document should contain reference to the tools available for the design and construction of new buildings. Commercial buildings: • BREEAM • NABERS • Passivhaus Domestic Buildings: • Passivhaus • AECB • BEPIT (Building energy performance improvement toolkit) • Assured Performance Process (APP) Definitions for all of these tools should be included in the Glossary. Issue C5: Existing Buildings There is a huge challenge in getting all existing buildings to be true net zero carbon. The policy needs to recommend that all retrofit should be undertaken to a specific standard. The reason for this is that the current supply chain out there in the market can be likened to the ‘wild west’. If deep retrofit is not done properly the health and wellbeing of occupants and indeed building fabric will suffer. The following is a list of appropriate standards: • PAS 2035 for domestic buildings • PAS 2038 for non-domestic buildings • EnerPHit Standards – this is retrofit using the Passivhaus Standard • Energiesprong – this would be useful for council homes and social housing. • AECB or LETI - Retrofit Standard for housing. Other initiatives to consider: • National Retrofit Hub - There is an initiative which has just received funding (January 2023) from Innovate UK to establish a National Retrofit Hub and regional/ local retrofit hubs emerging around the country (e.g. https://retrofit.coop/ in Manchester, https://cosyhomesoxfordshire.org/ . SWLP should look to establish a local partnership with the National Retrofit Hub to train the supply chain including procurers, designers and contractors. • Historic Buildings: There needs to be a clarification around definitions of 'Historic Buildings'. This implies listed buildings / conservation area status etc. Option C5b includes the wording 'Traditional Buildings', which may be a better term to use. This would then include all solid walled and timber framed buildings. Traditional Buildings require a riskbased approach as defined in guidance from Historic England and the Sustainable Traditional Buildings Alliance (STBA) • EnerPHit Standards – this is retrofit using the Passivhaus Standard – although an excellent standard it probably goes too far for most buildings, except for linear blocks (e.g. blocks of flats, either horizontal or vertical blocks). There seems to be a consensus starting to emerge around “heat-pump ready” as an acceptable first step on the retrofit journey. This means doing sufficient fabric improvement to allow a heat pump to work efficiently, and hence not to drive up energy costs when switching from gas to electric heating. There are still arguments about exactly how far the fabric improvements should go – should it be far enough that you can re-use the existing heating system, which will operate at lower temperatures and therefore put out less heat? Or do you not need to go that far and accept that you need to add in more radiators – you just do it based on the sizing of the heat pump. Either way, it needs to be done as part of a whole house retrofit plan, so that any changes don’t waste any measures that are installed i.e. they won’t need ripping out again later if any further improvements are planned. Anyway, that seems to be the general position that’s emerging from both LETI and the AECB. • Energiesprong – this would be useful for council homes and social housing – this is another excellent solution but probably also goes too far for most buildings. See above. The relation between the new AECB Standard and PAS is as follows: PAS is a process that requires you to take a whole house approach. The AECB standard (now two levels) sets actual performance targets. Operational Energy in kWh/m2/y – Lifetime Carbon kg/CO2e and kg/CO2/m2 Note – all the information in the SWLP being about % reduction is NOT the way forward. The solution is to use Energy Use Intensity as explained elsewhere in this document. Energy Performance Certificates. In assessing an existing building for a deep retrofit it is appreciated that currently for local authorities the only tool is the EPC. It should be carefully noted that the EPC is considered by experts to be not fit for purpose. The Climate Change Committee have set out the need to reform the domestic EPC rating metrics to support the delivery of Net Zero. A letter was sent to Lee Rowley MP, Parliamentary Under Secretary of State, Department for Levelling Up, Housing and Communities on the 2nd February 2023. Issue C6 Whole Life-Cycle carbon emission assessments Requiring whole life-cycle carbon assessments is most definitely the right thing to aspire to on the journey to net zero by 2050. However the paragraph outlining this on page 129 seems to have been written based on incorrect assumptions. Here is the paragraph: “Whole Life-Cycle Carbon emissions are those resulting from the material, construction and the use of a building over its entire life, including its demolition and disposal. A Whole Life-Cycle Carbon Assessment considers a building’s carbon impact on the environment and are most usefully undertaken once a building has been constructed but prior to occupation. In order to drive down emissions a policy approach would be necessary to establish appropriate targets to reduce emissions. “ The Whole Life Cycle calculations can and must be done during the design stage and look to reduce the carbon impact of both the construction process the materials used and future maintenance. The Whole Life-Cycle would include: • Design • Construction process • Construction materials • Regulated carbon in operation • Un-regulated carbon in operation. • Future retrofitting, repairs and maintenance Consider the definitions used by LETI: Net Zero (Whole Life Carbon): A 'Net Zero (Whole Life) Carbon' Asset is one where the sum total of all asset related GHG emissions, both operational and embodied over an asset's life cycle (Modules A1-A5, B1-B7 (plus B8 and B9 for Infrastructure only), C1-C4) are minimized, meet local carbon, energy and water targets and with residual 'offsets' equals zero. Net Zero Embodied Carbon: A 'Net Zero Embodied Carbon asset is one where the sum total of GHG emissions and removals over an asset's life cycle (Modules A1-A5, B1-B5 and C1-C4) are minimized, meets local carbon targets (e.g. kgCo2e/m2) and with additional offsets equals zero. Make no mistake – this is extremely complicated and time consuming and MUST not detract from making progress towards true net zero carbon for regulated and unregulated energy. This certainly requires a policy but implementation MUST be after the mandate for true net zero for regulated and unregulated carbon as part of the operation of the building. Requiring this now will just hold back the key issue of improving energy efficiency and reducing carbon emissions from the operation of a building. Reducing the carbon emissions by 100% for construction and materials WILL NOT HELP REDUCE energy costs for occupants. As yet there is no agreed method to calculate embodied energy and the following was published by UK Green Buildings Council (UKGBC) in January 2023: “The https://www.ukgbc.org/ukgbc-work/net-zero-whole-life-roadmap-for-the-built-environment/ sites measurement and targets for embodied carbon as one of the key priorities for decarbonising the built environment. Embodied carbon has also become increasingly important within wider political contexts with the suggestions of Part Z and Grade III listed status. UKGBC has opened applications to join the Task Group of Industry experts for Its project on embodied carbon. The project aims to build on the Net Zero Whole Life Carbon Roadmap and seek to provide clarity on measurement and reporting on embodied carbon, as well as how Embodied Carbon Assessments can link into scope 3 reporting.“ As the SWLP develops there will be national guidance available later in 2023.
selected
selected
selected
No answer given
No answer given
selected
selected
selected
No answer given
Zero Carbon Buildings Issue C4: New Buildings 67. The HBF supports the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to success is standardisation and avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers, suppliers and developers. The Councils do not need to set local energy efficiency standards in a Local Plan policy because of the higher levels of energy efficiency standards for new homes set out in the 2021 Part L Interim Uplift and proposals for the 2025 Future Homes Standard. Issue C6- Whole Life- Cycle carbon emission assessment 68. The HBF would question the justification and purpose of a policy that requires a whole life-cycle carbon emission assessment. It is not evident how a decision maker would be expected to react to development proposals using such a policy. Although the consultation questions suggest requiring the calculation of the whole life cycle carbon emissions and actions to reduce life cycle carbon emissions, it is not clear from the consultation how it will be determined what the appropriate level of emissions is, or what would be an appropriate level of emission reductions. 69. The HBF also has significant concerns in relation to this policy particularly in relation to the elements in relation to performance and monitoring. It is not clear what the Councils would do with the information in relation to performance information or the monitoring information once the development is completed and is a home. The HBF also considers that it is unlikely that any household would wish to share their personal energy usage information with the developer of the site or the Council, how they choose to live in their home once purchased is surely down to the individual household.
selected
selected
selected
No answer given
Review of Chapter 7. Foreword: The SWLP is for a 25-year period to 2050. One question we should be asking is: What will the people in 2049 be thinking of those who developed this Local Plan? Will they be pleased, or will they wonder at the poor ambitions and insight of those of today? The most important part of this section is 7.2 Zero Carbon Buildings. With currently circa 40% of CO2 from buildings (27% domestic and 13% non-domestic) the issue in terms of carbon reduction in relation to the climate emergency is of the utmost importance. Consider first the definitions included within the glossary of the consultation document. There are three definitions to consider which is quite confusing. The Net Zero Carbon definition in the Glossary is ambiguous and also not completely transparent. What is meant by “balancing carbon dioxide emissions by removal”? Is this allowing offsetting and if so, what offsetting is acceptable and what is not acceptable. The wording “….or simply eliminating carbon dioxide emissions altogether” is much clearer and unambiguous. As yet there is not a nationally agreed definition of net zero carbon. This is set to change with an initiative launched in 2022 the UK Net Zero Carbon Buildings Standard. This is being developed by the following organisations with the support of an advisory group of some 500 UK experts. The ambition is to have an agreed definition and a verification process by the summer of 2023. What is clear from the work of the advisory group is that it is almost impossible to get to net zero carbon using the tools currently within the building regulations namely SAP and SBEM. This fact is actually recognised by Warwick District Council. The following is an extract from a document included within the submission in 2022 for the Warwick DC Net Zero Carbon DPD. From the above it is clear that WDC are fully aware that the entire methodology of SAP and SBEM are not fit for purpose as compliance tools now and most especially for the requirements of true Net Zero Carbon It should be noted that there are experts who are of the opinion that the WDC Net Zero Carbon title for the DPD is both incorrect and misleading. In order to provide the direction of travel for a true net zero carbon definition the following might be useful: To understand what is required for true net zero carbon the direction of travel is to get away from % improvements and instead develop what is called an Energy Use Intensity (EUI) target. For housing this could be set at approximately 30 kWh/m2/yr. EUI will include all regulated and unregulated energy – i.e. All metered energy. For low rise housing ALL of the EUI will be met by on site renewables – i.e. PV panels. For apartments higher rise buildings and many non-domestic buildings, it is generally not possible to meet all of the EUI with on site renewables and so appropriate offsetting (not including trees) is allowed. More on offsetting later. In order to give an insight of how policy requirements will deliver true net zero carbon the following is an extract from the Cornwall Climate Emergency DPD Cornwall Council submitted the Climate Emergency DPD for independent examination in November 2021. The Planning Inspector has confirmed that the plan is sound subject to recommended modifications. The plan can now proceed to adoption on 21st February 2023 A similar ambitious document also confirmed as sound by the Planning Inspector is the Bath and Northeast Sommerset Local Plan (BNES) Similar ambitious Local Plans are being prepared by Greater Cambridge and Central Lincolnshire amongst others. All have developed a similar direction of travel towards true Net Zero Carbon. It should be noted that: Scotland mandates Passivhaus equivalent legislation A seismic change in building standards is underway in Scotland. All new build homes in Scotland will soon have to meet greater levels of energy efficiency after the Scottish Government agreed to progress legislation proposed by Scottish Labour MSP Alex Rowley. In December 2022 Scottish government ministers announced plans to make all new build housing meet a Scottish equivalent to the Passivhaus standard within the next two years. Work to develop the standard will commence early in 2023, seeking the laying of amending regulations in mid-December 2024. This is HUGE and a potentially game-changing move for building performance, comfort, very low energy bills, and climate action in Scotland! Its ripples will extend far beyond Scotland and is already attracting global attention. 7.2 Net Zero Carbon Buildings. The consultation document says “With effect from June 2022, changes to Building Regulations mean that all new homes must produce 30% less carbon dioxide emissions than previous standards. From 2025 all new homes will be required to produce 75- 80% less carbon dioxide emissions and will need to be ‘zero-carbon ready’ requiring no further energy efficiency retrofit work to enable homes to become zero-carbon as the electricity grid decarbonises. “ In reality it is almost impossible to get to true net zero carbon using % reduction through the 2021 Building Regulations. The guaranteed way to get to true net zero carbon is to have specific energy targets known as Energy Use Intensity (EUI) – in kWh/m2/y and match this with the generation of renewable energy - where possible on site. (e.g. for low rise housing). A definition for Energy Use Intensity should be added to the Glossary. Importantly there is no mention of the Performance Gap, nor is there a definition of this in the Glossary. This needs to be addressed. Page 125 – states “The National Design Code 2019 identifies the need for new developments to follow the energy hierarchy to: 1. Reduce the need for energy through passive measures, including form, orientation and fabric 2. Use energy efficient mechanical and electrical systems, including heat pumps, heat recovery and LED lights; and 3. Maximise renewable energy especially through decentralised sources, including on-site generation and community-led initiatives” However the National Design Code 2019 has been replaced by the National Model Design Code 2021, which does not have this wording. We suggest the local plan should include the following wording: 1. Reduce the need for energy to a target EUI for example 30kWh/m2/yr. for dwellings. Separate targets are needed for regulated and unregulated energy the sum of which amount to the EUI. 2.Use energy efficient mechanical and electrical systems, including heat pumps, heat recovery and LED lights; 3. Renewable energy on site to at least match the EUI. Decentralised sources are not relevant for true net zero carbon low rise dwellings. Figure 24 – The Energy Hierarchy is basically out of date BREEAM: There is no mention of the use of BREEAM in the text. The only mention is in the information relating to existing policy documents from Stratford and Warwick. BREEAM is also not included in the Glossary. Stratford use BREEAM ‘Good’ and Warwick use BREEAM ‘Very Good’. Regretfully both are totally inadequate. Indeed although BREEAM does provide sustainable benefits it will not on its own deliver true net zero carbon as demonstrated in the following extract from the Cornwall Climate Emergency DPD recently approved by the Inspector. The way forward / direction of travel to true net zero carbon is set out in the Foreword to section 7. Issue C4 New buildings The following statement on page 127 is absolutely correct, however the way forward proposed in section 7.2 will not deliver this ambition. Buildings are a major source of emissions for South Warwickshire and so the need to minimise those that are generated from new development is critical in achieving the climate emergency ambitions. The document should contain reference to the tools available for the design and construction of new buildings. Commercial buildings: • BREEAM • NABERS • Passivhaus Domestic Buildings: • Passivhaus • AECB • BEPIT (Building energy performance improvement toolkit) • Assured Performance Process (APP) Definitions for all of these tools should be included in the Glossary. I have not answered the questions containing in the consultation document as Chapter 7 needs to be completely revised. Take for answer Option C4.1b.set out as follows: Option C4.1b: Set a higher local standard beyond the building regulations requirements to achieve net zero carbon in all new developments. This would require all new development to achieve net zero carbon from adoption of the plan, expected in 2025. However, it would be at a cost as the development industry may not be ready to viably deliver this and as a consequence we may see less affordable housing built and maybe fewer other social and community benefit from development to offset the cost of achieving net zero carbon. Viability work would be needed to establish the impact of this approach. The cost of going to net zero carbon using for example the Passivhaus Certification or equivalent route (as set out by the Scottish Government) involves an additional capital cost of less than 10%. Some put the additional cost at between 6% and 8%. To keep the additional cost to be neutral, the amount could be taken off the cost of the land! The second point regarding the industry not being ready is nonsense. The sector has been aware of this for years most especially for housing with the Code for Sustainable Homes and the then ‘Zero Carbon new homes from 2016’ abandoned by the Conservative administration in 2015. The third point is that the sector does not want true net zero carbon buildings as they (designers, developers and contractors) will need to demonstrate this through building performance evaluation in use. Currently and within this document they can continue with ignoring the ‘performance gap’ Issue C5: Existing Building There is a huge challenge in getting all existing buildings to be true net zero carbon. The policy needs to recommend that all retrofit should be undertaken to a specific standard. The reason for this is that the current supply chain out there in the market can be likened to the ‘wild west’. If deep retrofit is not done properly the health and wellbeing of occupants and indeed building fabric will suffer. The following is a list of appropriate standards: • PAS 2035 for domestic buildings • PAS 2038 for non-domestic buildings • EnerPHit Standards – this is retrofit using the Passivhaus Standard • Energiesprong – this would be useful for council homes and social housing. • AECB or LETI - Retrofit Standard for housing. Other initiatives to consider: • National Retrofit Hub - There is an initiative which has just received funding (January 2023) from Innovate UK to establish a National Retrofit Hub and regional/ local retrofit hubs emerging around the country (e.g. https://retrofit.coop/ in Manchester, https://cosyhomesoxfordshire.org/ . SWLP should look to establish a local partnership with the National Retrofit Hub to train the supply chain including procurers, designers and contractors. • Historic Buildings: There needs to be a clarification around definitions of 'Historic Buildings'. This implies listed buildings / conservation area status etc. The 'better' term would be 'Traditional Buildings' - this then includes all solid walled / timber framed buildings. Traditional Buildings require a risk-based approach as defined in guidance from Historic England and the Sustainable Traditional Buildings Alliance (STBA) • EnerPHit Standards – this is retrofit using the Passivhaus Standard – although an excellent standard it probably goes too far for most buildings, except for linear blocks (e.g., blocks of flats, either horizontal or vertical blocks). There seems to be a consensus starting to emerge around “heat-pump ready” as an acceptable first step on the retrofit journey. This means doing sufficient fabric improvement to allow a heat pump to work efficiently, and hence not to drive up energy costs when switching from gas to electric heating. There are still arguments about exactly how far the fabric improvements should go – should it be far enough that you can re-use the existing heating system, which will operate at lower temperatures and therefore put out less heat? Or do you not need to go that far and accept that you need to add in more radiators – you just do it based on the sizing of the heat pump. Either way, it needs to be done as part of a whole house retrofit plan, so that any changes don’t waste any measures that are installed i.e. they won’t need ripping out again later if any further improvements are planned. Anyway, that seems to be the general position that’s emerging from both LETI and the AECB. • Energiesprong – this would be useful for council homes and social housing – this is another excellent solution but probably also goes too far for most buildings. See above The relation between the new AECB Standard and PAS is as follows: PAS is a process that requires you to take a whole house approach. The AECB standard (now two levels) sets actual performance targets. Operational Energy in kWh/m2/y – Lifetime Carbon kg/CO2e and kg/CO2/m2 Note – all the information in the SWLP being about % reduction is NOT the way forward. The solution is to use Energy Use Intensity as explained elsewhere in this document. Energy Performance Certificates. In assessing an existing building for a deep retrofit it is appreciated that currently for local authorities the only tool is the EPC. It should be carefully noted that the EPC is considered by experts to be not fit for purpose. The Climate Change Committee have set out the need to reform the domestic EPC rating metrics to support the delivery of Net Zero. The letter was sent to Lee Rowley MP, Parliamentary Under Secretary of State, Department for Levelling Up, Housing and Communities on the 2nd February 2023. Issue C6 Whole Life-Cycle carbon emission assessments page 129 Requiring whole life-cycle carbon assessments is most definitely the right thing to aspire to on the journey to net zero by 2050. This is extraordinarily ambitious and must be undertaken as part of the design stage. The paragraph outlining this on page 129 is bonkers. Here is the paragraph: Whole Life-Cycle Carbon emissions are those resulting from the material, construction and the use of a building over its entire life, including its demolition and disposal. A Whole Life-Cycle Carbon Assessment considers a building’s carbon impact on the environment and are most usefully undertaken once a building has been constructed but prior to occupation. In order to drive down emissions a policy approach would be necessary to establish appropriate targets to reduce emissions. Why do it once the building has been constructed? The Whole Life-Cycle would include: • Design • Construction process • Construction materials • Regulated carbon in operation • Un-regulated carbon in operation. • Future retrofitting, pairs and maintenance Most usefully, the exercise must be undertaken during the design stage and look to reduce the carbon impact of both the construction process the materials used and future maintenance. Consider the definitions used by LETI Make no mistake – this is extremely complicated and time consuming and MUST not detract from making progress towards true net zero carbon for regulated and unregulated energy. This certainly requires a policy, but implementation MUST be after the mandate for true net zero regulated in unregulated carbon as part of the operation of the building. Requiring this now will just hold back the key issue of improving energy efficiency and reducing carbon emissions from the operation of a building. Reducing the carbon emissions by 100% for construction and materials WILL NOT HELP REDUCE energy costs for occupants. As yet there is no agreed method to calculate embodied energy and the following was published by UKGBC earlier in January 2023. The Net Zero Whole Life Carbon Roadmap sites measurement and targets for embodied carbon as one of the key priorities for decarbonising the built environment. Embodied carbon has also become increasingly important within wider political contexts with the suggestions of Part Z and Grade III listed status. UKGBC has opened applications to join the Task Group of Industry experts for Its project on embodied carbon. The project aims to build on the Net Zero Whole Life Carbon Roadmap and seek to provide clarity on measurement and reporting on embodied carbon, as well as how Embodied Carbon Assessments can link into scope 3 reporting. As the SWLP develops there will be national guidance available later in 2023. 7.3 Climate responsive development design: page 129 The two opening paragraphs set the scene quite well and are seriously ambitious. What is clear is that the 4 existing policies from Stratford and Warwick that follow will not deliver the aspirations of what needs to be done NOW. The comments on BREEAM that are made earlier in this submission apply. BREEAM is good to have and will help deliver a better Climate response – however BREEAM Good and Very Good are inadequate and BREEAM MUST be included in the design to achieve the highest category available at the time of the final publication of the SWLP. To emphasise an earlier point - all current BREEAM categories will not deliver true net zero carbon.
selected
selected
selected
No answer given
Q-C4.1 45. Net zero carbon and construction standards for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-6.1 46. Achieving 100% reduction in embodied emissions for new developments is not an easy proposition for any developer or authority to establish. As is noted in the Issues and Options document, a number of the factors are outside the direct control of the developer, occupier and authority (e.g. decarbonisation of the national grid). As is also noted, there are significant cost considerations if this approach is adopted which will impact upon viability. The sorts of concerns do need to be taken into account if a viable and deliverable Local Plan is to be prepared. 47. If 100% reduction in embodied emissions is sought then there is a need for the wider technologies with the construction sector to fully adjust and it would be appropriate for a phased approach to be adopted if this type of policy is to be carried forward.
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire Should be aligned with the national approach. Q-C4.2: What scale of development should the requirements apply to? Should be aligned with the national approach. Q-C5: Please select all options which are appropriate for South Warwickshire Should be aligned with the national approach. Q-C6.1: Please select the option which is most appropriate for South Warwickshire Should be aligned with the national approach.
selected
selected
selected
No answer given
No answer given
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
selected
selected
selected
No answer given
Issue C4: New Buildings Any policy relating to minimising emissions generated from new development should reflect national standards or, preferably, be left to building regulation requirements (Option C4.1a). This would mean there is a consistent approach applied that reflects the sector, technical feasibility and viability considerations. If a Council-based policy is considered necessary, any policy must be sufficiently flexible to respond to particular site or project specific circumstances, allowing a case-by-case consideration. Issue C5 – Existing Buildings Hermes does not consider that it would be appropriate to include a policy that requires net zero carbon requirements for all building proposals that require planning permission – including conversions, changes of use, and householder residential applications (Option C5a). While this ambition would be desirable, this could affect the viability of developments. Option C5b would be preferable, encouraging the retrofit of climate change measures into existing buildings, within certain parameters.
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
selected
selected
selected
No answer given
The County Council is keen to work with the Local Plan Team to consider the impact of Climate Change and how we can head towards Net Zero Carbon.
selected
selected
selected
If the decision is made to proceed with a policy that seeks reductions in embodied emissions, then a phased approach should be adopted. However, it is difficult to advise where this threshold should be set without more information being provided regarding the potential implications of such a policy. The Councils should therefore look to test the various options and present this work as part of a preferred strategy which can be commented on in due course.
Q-C4.1: The Respondent considers it superfluous to include a policy requiring new development to comply with national building regulation requirements given that developers will need to comply with Building Regulations in any event. While the Councils’ aspirations to raise the standard of design and achieve net zero carbon is understood, and to some extent supported, achieving this will come at a significant cost to development which, given the time frames involved, is unlikely to be easily absorbed and therefore has the potential to put at risk the delivery of sites and, in turn, the timely delivery of market and affordable homes. Considering these concerns, Option 4.1a is considered to be most appropriate. If, however, the Councils are minded to set a higher local standard, then it is advised that realistic transitional arrangements are allowed for to enable the development industry time to respond. In the Respondent’s view, the timeframe indicated in Option C4.1c is the minimum that should be adopted. In imposing standards caution also needs to be shown to ensure that redundant technology is not prescribed and that developers can make an appropriate choice of systems at the time houses are being delivered. In addition, the Plan will have to be supported by evidence demonstrating that the viability both technical and financial has been taken into account. Q-C6.1: While the Councils’ aspiration to raise standards and seek greater reductions in embodied emissions is appreciated, the Respondent has significant concerns regarding the additional cost to the development industry, which cannot be easily absorbed.
selected
selected
selected
No answer given
Q-C4.1: Lockley Homes would select Question C4d. [none of these] Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as already considered in our Representations Statement (2023). The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021). Q-C5: Lockley Homes would select Question C5c. Whilst we support the principles behind the emerging policy approach and the need to incorporate climate change mitigation features within new buildings, incorporating these types of features can significantly increase the financial build costs for new build residential schemes, at a time when the house building construction industry is already experiencing an unprecedented rapid increase in both materials and labour costs. We would advise that a pre-cautionary policy approach is therefore taken by the LPA’s in relation to this issue given the severe adverse set of economic circumstances now facing the Local Plan area as already considered in our Representations Statement (2023). The Council’s proposed planning policy approach on these issues is far too onerous and will place a highly damaging financial burden on the house building development industry within South Warwickshire. The presence of an unprecedented severe 300-year-economic-recession-event now facing the South Warwickshire Region and wider United Kingdom economy, should now result in an urgent and major re-shaping of all Policies coming forward within the emerging SWLP and SAP Local Plan Reviews. In order to ensure that the Council’s Plan-making approach on these matters is sufficiently robust, and responds effectively to guidance reinforced within paragraphs 31 (policies need to be based on a platform of the most up-to-date and sufficiently robust evidence) and 82 (indent d) (policies should remain sufficiently flexible to rapidly changing economic circumstances) of the Revised NPPF (2021).
selected
selected
selected
No answer given
No answer given
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire We are generally supportive of Option C4.1c – a phased approach to net zero carbon -setting a future date by which all new development will need to achieve net zero standards. L&Q Estates are committed to responding to the climate crisis and are actively looking to deliver housing to standards above those set out in current building regulations in response to this challenge. Indeed, their most recent Corporate Strategy includes a commitment to setting an L&Q design standard in response to the emerging Future Homes Standard, as well as more broad investment in modern methods of construction. However, it is important to note that renewable and low carbon energy dwellings maynot always be practicable or viable in new developments. Therefore, we are supportive of Option C4.1c insofar as this option allows time for the cost of achieving these standards to come down, and may mean that more affordable housing and community benefits can be secured from development.
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficiency. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
selected
selected
selected
No answer given
Q-C4.1: Please select all options which are appropriate for South Warwickshire 5.1. If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified, and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal. Q-C6.1: Please select the option which is most appropriate for South Warwickshire 5.3. Whilst the value of Whole Life-Cycle Carbon assessments is recognized and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, properties will be owned by the purchaser and mortgagees. Any policy would need to be carefully worded such that it would not require the sharing of energy use, air quality and overheating risk data with a third party, where the developer no longer owns the dwelling as this could raise GPDR issues. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.
selected
selected
selected
No answer given
Q-C4.1: If a net zero carbon policy is to be employed by the Council it must be fully evidenced and justified and included in viability considerations. 5.2. The Building Regulations Part L 2021 Target for Fabric Efficiency would be applicable to all proposed dwellings and sets the Government’s standards for energy efficient. The Council does not need to set local efficiency standards to achieve the shared net zero goal Q-C6.1: Whilst the value of Whole Life-Cycle Carbon assessments is recognised and there is no in principle objection to the need for some forms of post construction, pre-occupation assessment, if a policy is to be pursued on this matter there are a number of key considerations: • Once sold, the purchasers and/or mortgagees will own the properties. It is unclear how units once occupied would be required to share information in respect of energy use, air quality and overheating risk data with a third party, where the developer no longer holds ownership and therefore does not have responsibility of maintaining the property. Enforcement of such a policy for future owners and occupiers could also fail the test of conditions on any subsequent planning permission. • The purpose of such information would also need to be clearly set out. It will not be possible to post factum make alterations to the constructed buildings, so what would be the benefit or purpose of such a significant amount of data collation? If the purpose is to inform and advise as to future construction methods, then this could be equally achieved by an informed and targeted research exercise by organisations such as the BRE in advising Governments and through amendments to Building Regulations.