Not just newbuild - see earlier comments

5.4 Can we legally set higher standards than the anticipated 2025 national one ? If so we should as national policy has often lagged behind the urgency required by the emergency.

5.7/5.8.5.9 SAP and SBEM may be out of date and relatively poor methodologies for calculating emissions - the draft DPD itself seems to imply the performance gap is not measured (5.9); and a Jan 22 WDC policy review states
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 This is not only due to out-of-date carbon factors used for different energy sources, but the entire methodology.
Whatever robust tools we do select as accurate here should be specific eg PHPP which others have adopted, not left open for developers' decision with the phrase 'such as'.
The LPA must also be permitted to update the list of acceptable tools within this DPD as technology and experience indicate

Finally, should we require further testing of achieved energy standards at 9 years (before new House quality guarantee expires) to ensure any performance slippages over the short-term life of the buildings are rectified for the long-term.

5.11 Why are standards limited to new buildings of over 1000sqm. What standards will smaller buildings be expected to meet?