Q-S7.1: Please provide any comments you have on the emissions estimation modelling for the five growth options

The emissions analysis is high level and shows relatively little difference between the alternatives. In a context where we should be carbon-zero by 2050 it should be afforded relatively little weight. Assuming mitigation could be put in-place under each of the options then other considerations should have greater weight.

The Parish Council does not have the emissions estimation modelling expertise to respond

Has your emissions modelling incorporated the potential impact of pumping wastewater long distances to the nearest wastewater treatment works of appropriate size and capacity to take a large new population from new settlements surrounding rail corridors?

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 (WDC). The following is an extract from a document included within the submission in 2022 for the WDC 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 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 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 North East 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. 7.1 Large Scale renewable energy generation and battery storage. The opening two paragraphs set the scene well. However there is no mention of the need to urgently upgrade the capacity of the grid to accommodate the move to heat pumps and the increased requirement for EV charging at home.

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 decarboniser. “ 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: