Policy NZC2(A) Making

Again a sensible and vital proposal, particularly that the building performance on completion has been tested. Otherwise it won't be effective.

Sets out a requirement for new development to achieve a 75% carbon reduction above Part L 2013, bringing forward the requirements of the full Future Homes Standard (FHS) due to be implemented in 2025. In Section 2 of the DPD the Council notes that the Government has indeed retained the legislation in the Planning and Energy Act 2008 which allows Local Authorities to set standards beyond the requirements of the Building Regulations. It is noted that this Policy will apply to full or reserved matters applications.
However, the FHS consultation response goes on to set out that the Planning for the Future white paper sets out options for a simpler planning process, aiming for setting standards nationally. It also states, ‘as we move to higher levels of energy efficiency standards for new homes with the 2021 Part L uplift and Future Homes Standard, it is less likely that local authorities will need to set local energy efficiency standards in order to achieve our shared net zero goal.’
The FHS consultation response also provides detail on the Roadmap to the FHS confirming that the interim target will be implemented from June 2022, followed by technical work and consultation on the full FHS in Spring 2023 before implementation in 2025.
A significant reason for the proposed timeline to the full FHS is related to the need to upskill and develop the supply chain to deliver the FHS, noting in particular the importance of expertise in using heat pumps and how large a step forward the full standard is compared to the current regulations. The consultation response states, ‘We believe the timeline set out in this document delivers our net zero commitments, while providing industry with the time it needs to develop the supply chains and skills that will be necessary to deliver the Future Homes Standard and accounting for market factors.’ While the policy can bring forward the full FHS requirement it is likely the supply chain and skills will not yet be available to deliver this effectively and could lead to sub-standard development, or delay development impacting on the Council’s housing delivery plans.
In addition as noted in the response to Section 1, aligning this policy with the FHS timeframe will give the sector time to upskill and build the supply chain necessary to deliver this standard, as well as reducing costs to make these requirements more viable.
In this context we believe that the Council should stick with the Government’s proposed timeline for the FHS, noting that the Government believes that this timeframe will help meet the UK’s zero carbon target. If the DPD is published ahead of the FSH timeframe, there should be a transition period to ensure the DPD is not ahead of the requirements of national policy.

Please see attached.