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ID sylw: 108827

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land-Land east of Stratford-on-Avon

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.
Written Ministerial Statement (WMS) – December 13th - Local Energy Efficiency Standards Update – In December 2023 the Government released a WMS { Written statements - Written questions, answers and statements - UK Parliament} which sets out clarity on the development and application of local energy efficiency standards in the context of advancing national policy. The WMS notes that the introduction of Part L 2021 supersedes the 2015 WMS which set guidance for Local Authorities to not set energy efficiency standards beyond Code for Sustainable Homes Level 4. The WMS goes onto note that the 2025 Future Homes Standard (FHS) will mean, ‘that homes built to that standard will be net zero ready and should need no significant work to ensure that they have zero carbon emissions as the grid continue to decarbonise. Compared to varied local standards, these nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes’.
The WMS states, ‘the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale.’
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 requirements { Local plan examination library: examination documents}. 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.
Regulated and unregulated energy - It is noted that the draft Policy relates to both regulated and unregulated energy. While we support the delivery of low carbon development it is considered any targets should be restricted to regulated energy only. Developers only have the ability to influence the regulated energy demand through design and specification of materials and systems and renewable energy technologies. However, the unregulated energy consumption, (often referred to as ‘plug in load’) of development is ultimately the function of the residents or occupiers use of the building, which cannot be influenced by the developer and therefore setting a targets for energy, energy generation and energy offsetting which include unregulated energy is not appropriate.
For example, post 2025 one of the greatest demands for unregulated energy in new homes will be to charge an electric vehicle. It unreasonable to assume that a developer should effectively meet the cost of mitigating energy and carbon from charging an electric vehicle. Similarly non-residential building uses, including commercial uses can include significant process loads, e.g. refrigeration, it is again unreasonable to assume that a developer should effectively meet the cost of mitigating energy and carbon from these uses. The responsibility of unregulated energy use and emissions therefore should sit with the building residents and occupiers.
The Governments Future Homes and Buildings Standard Consultation states in reference to setting energy intensity targets, ‘We consider that metrics which include unregulated loads are not a suitable because designers and housebuilders have little or no control over these end uses of energy.’
In addition as noted above the examination of the Bristol Local Plan has revised Policy NZC2 to relate to regulated emissions only.
In this context it is recommended that the Policy only considers requirements which relate to regulated emissions only in line with the principles set out in the 2023 WMS and the recent examination and modifications to the Bristol
Local Plan Review.
Air tightness and ventilation – The Policy states new developments are expected to achieve higher airtightness beyond the FHS, as well as consider mechanical ventilation with heat recovery.
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’.
The FHS aims to strike a balance of cost effective improvements, noting further improvements to fabric are not a cost effective intervention to reduce carbon emissions.
Further reductions in air tightness would necessitate the use of mechanical ventilation which has a cost implication for development beyond current and proposed future Building Regulations. Any requirements for improved air tightness and use of mechanical ventilation would need to be appropriate evidenced and considered as part of the viability assessment.
Renewable Energy Generation – The Policy sets out an expectation for residential development to include Solar PV capacity of 3kWp – 4kWp, optimising roof orientation and pitch for Solar PV where possible.
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.
In addition the technical constraints to delivery requirements for onsite energy generation need to be considered in line with the 2023 WMS noted above. Setting an energy based requirement does not align with the requirements of the WMS. Any onsite generation requirements need to be considered as part of an overarching approach to reducing carbon emissions.
Form Factor – While delivering efficient building form and the form factor of development can help reduce energy demand and therefore carbon emissions, this also needs to be considered in conjunction with the design of buildings and wider development. As with the energy generation requirements placing limits on building form may lead to unintended design implications, minimising opportunities for design which may be reflective of the local character of opportunities presented by development.

It is noted that the 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.
Cool and Green roofs – The draft Policy also requires residential development to include the consideration of green roofs and walls. We would note that while green roofs and walls can have multi benefits, reducing the surface run off whilst having a positive impact on biodiversity, they have a significant implication in terms of design and cost and are not suitable for residential development where residents are responsible for their ongoing maintenance. Green roofs and walls are likely to be applicable to non-residential development only and we would recommend this is removed from this Part A of this Policy.
Recommendation – 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.