BASE HEADER

Other

ID sylw: 108828

Derbyniwyd: 07/03/2025

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

Asiant : Savills

Bellway supports the need to measure and reduce the embodied carbon of development. However, the requirements of this policy will require further consideration to ensure that they are feasible and viable. The proposed targets provided from LETI and RIBA provide a mixture of targets which relate to both the upfront embodied carbon of development (stages A1-A5), as well as the whole life carbon of development (Stages A1-D4), they do not provide a consistent set of targets or consideration. We would also note that these targets are limited to a small number of potential building types and do not necessarily provide sufficient breadth of uses to be able to apply to all development. We would recommend that embodied carbon considerations focus on upfront embodied carbon as further downstream emissions cannot be controlled by the developer.
The LETI embodied carbon targets noted are delivered from the LETI 2020 Design Guide 2030 targets. While the Plan is at an early stage these targets go well beyond best practice and consideration needs to be given as to whether these are feasible and viable.
At this stage the Plan’s evidence base provides no details on the consideration of embodied carbon, or potential costs of achieving the targets set out. Recent evidence prepared to support the South Oxfordshire District Council Local Plan indicates a potential cost of c.£11k to c.£24k per plot beyond Part L 2021 to achieve the LETI targets {ITV04 Joint Local Plan Viability Report (Publication Version)}.This Policy therefore potentially carries a significant cost which will need to be considered as part of next stages of Plan development.
We would note that while embodied carbon is not currently considered by the Building Regulations, the FHS and FBS December 2023 consultation the Government stated, ‘The government intends to consult on our approach to measuring and reducing embodied carbon in new buildings in due course’. It is likely that the Government will set future national targets for embodied carbon through amendments to the Building Regulations. In the context of the Government’s December 2023 consultation we would anticipate that a future set of national embodied carbon targets would supersede local requirements.
We would recommend that the approach set out in the Warwick Net Zero DPD { Net Zero Carbon DPD-Adopted May 2024 - Download - Warwick District Council} and supporting SPD {6 Net Zero Carbon SPD-May 2024 - Download - Warwick District Council} .is followed, this requires the consideration and reduction of upfront embodied carbon, without setting a specific target at this stage. The application of specific targets needs to be fully considered as part of the Plan evidence base and viability assessment.