Object

Net Zero Carbon Development Plan

Representation ID: 72149

Received: 13/09/2021

Respondent: Barwood Land

Agent: Turley

Representation Summary:

While Policy NZC1 states development should be net zero, it does not clearly present the definition of net zero, nor what is meant by being, ‘net zero carbon at the point of determination of planning permission’ as referenced in Policy NZC2(D). These supporting policy requirements do not clearly set out how development is to reduce emissions before offsetting. Given the issues of viability in Section 1 we believe that this Policy is amended to align with the requirements and timings of the Future Homes Standard and national guidance which is aiming to deliver Net Zero Ready housing over time.

Full text:

The policy states new development should achieve net zero carbon emissions through reducing energy demand, incorporating zero or low carbon energy sources, and offsetting residual operational emissions to net zero.
While Policy NZC1 states development should be net zero, it does not clearly present the definition of net zero, nor what is meant by being, ‘net zero carbon at the point of determination of planning permission’ as referenced in Policy NZC2(D).
To meet the overarching policy requirement the following sub-policies are proposed:
• Policy NZC2(A) requires development to achieve a 75% carbon reduction above Part L 2013, this relates to the regulated emissions of new development only.
• Policy NZC2(B) sets out a requirement for development to consider zero and low carbon sources of energy. It is noted that the supporting text for this policy states this clause requires an Energy Statement to be prepared setting out how the residual energy demand of development should be met, however this is not what the Policy as it currently stands requires.
• Policy NZC2(C)) sets out the use of ‘net zero ready’ technology in the event fossil fuels are used onsite.
• Policy NZC2(D) states that where development cannot demonstrate that it is net zero carbon at the point of determination of a planning permission, is required to address residual carbon emissions via payment to the Council’s fund or approved alternative.
These policy requirements do not clearly define net zero, or how these policies require development to reduce emissions before offsetting. While we note that net zero is the likely intent of the policies it is not currently clear what definition of net zero the Council is using, nor does the policies definitively set out what the onsite building level requirement is.
Given the issues of viability in Section 1 we believe that this Policy is amended to align with the requirements and timings of the Future Homes Standard (FHS) and national guidance which is aiming to deliver Net Zero Ready housing over time.