Net Zero Carbon Development Plan Document - Regulation 19

Covered in previous Comment

4.2.1 needs to be reworded as zero carbon on new builds will not be achieved or sustained - see comments under 1.3 and 4.1 above.

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5.7/5.8.5.9 SAP and SBEM may be out of date and relatively poor methodologies for calculating emissions - the draft DPD itself seems to imply the performance gap is not measured (5.9); and a Jan 22 WDC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 This is not only due to out-of-date carbon factors used for different energy sources, but the entire methodology.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?

DPD should require solar panels as default on all developments to reflect the latest technology which enables successful installation even on oblique roofs. The clear WDC objective should be to encourage installation on all roofs.

WDC should apply higher standards than the anticipated 2025 National future Homes Standard if legal? Can this be done where the trade-off costs v carbon emission reduction is reasonable (whole life cost analysis)?

The DPD should explicitly allow the LPA to vary such standards as technology and experience evolve

All plans (new and retro) to include reskilling/upskilling of existing workers in clean/green and apprenticeship funds.

The potential 'feasibility' or 'viability' loophole should be removed or at least drastically redrafted to reflect NPPF policy and guidelines (para 2 of draft policy). These clearly indicate that lack of profitability on a scheme will primarily require adjustment to land purchase value not to the delivery of key Plan policies - of which this DPD will be a top priority for the foreseeable future. And that any issues of viability must be raised at or before a planning application is submitted.

Is gas ruled out by 7.3? Can it be made less ambiguous (see fuller comment in 4.1)

Option to upgrade completed building efficiency may be possible and preferable to a carbon offset payment; this should be made clear in the policy.

If it is necessary to include offsetting (which we do not favour) it must pass a stringent technical alternative test and NOT be permitted simply as an easier or cheaper option.

If a 9-year performance reassessment is required as suggested elsewhere, the same option - upgrade to original standard or costly carbon offset - should also be in the policy.

Will WDC set an example by committing not to seek carbon offset solutions to efficiency challenges?

Why is a whole-life calculation required only for 50+ dwellings and 5000sqm+ other buildings and not for all developments.

9.3 Be more specific on which test or tests should be applied - not 'such as'; but leave it open to the LPA to change the list of acceptable tests as technology and experience require (Same comment as on 5.9 above).

WDC preference for refurbishment and repurposing of buildings to minimise adding to embodied carbon should be made explicit and apply to most developments of all sizes.

Could a carbon offset charge be made on the additional embodied carbon required for every demolition/newbuild project on a sliding scale related to how closely the new building(s) are designed to achieving zero carbon?

Support this outline policy but more specific guidance/policy adjustments are needed for example to enable -
- use of non-traditional materials in conservation areas eg windows
- installation of double glazing on all pre-1914 buildings, both in and outside Conservation areas, with minimal visual harm.
- installation of solar panels/heat pumps on these buildings - but only to supplement the benefits of modern double glazing which should be a policy priority.

Explicit priority to be given to schemes which alleviate energy poverty in all tenures - can this be incentivised in some ways?

The potential 'feasibility' or 'viability' loophole should be removed or at least drastically redrafted to reflect NPPF policy and guidelines (para 2 of draft policy). These clearly indicate that lack of profitability on a scheme will primarily require adjustment to land purchase value not to the delivery of key Plan policies - of which this DPD will be a top priority for the foreseeable future. And that any issues of viability must be raised at or before a planning application is submitted. Same comment as in 7 above.

This policy needs at least redrafting - 11.2 perhaps removing - to minimise attempts to use it as a loophole to overcome NPPF guidance and the top local priority given to tackling the climate emergency.

Needs to toughen and supersede former policies