The expected Future Homes Standard will set out the requirements with a clear timetable for implementation to lower standards in achieving Net Zero by 2050. The transition to the standard within Part L will set out a 31% reduction on CO2 emissions comparative to the current Building Regulations up to 2025, then a requirement of 75% lower emissions than the current energy efficiency requirements.
Whilst Persimmon Homes are in support of the need to move to better energy efficiency, it is not appropriate for this to be achieved through Local Planning Policy. A standardised approach through nationally set Building Regulations would be the most effective way of achieving net zero by 2050 to avoid additional policies and assessment which could impede the planning process, causing confusion and more cost. Furthermore, Persimmon Homes would question how developments would be assessed against this policy through a planning application process and what consultee would be involved in ensuring that plans meet the policy. Considering this, it is again more evidence that the nationally set Building Regulations that are assessed by Building Control is the most appropriate mechanism to avoid delays, cost and confusion through the process.
In addition to this, it is noted that the proposed policy states local authorities can set policy requirements for carbon reduction. However paragraph 6-012 of the PPG states in new housing this is only up to level 4 of the Code for Sustainable Homes (equivalent to a 20% improvement on the 2013 Building Regulations), so the policy is therefore not consistent with national policy.
With regards to Part C, the policy should have regards to the site specific deliverability with acknowledgements that this may not be achievable. There is no acknowledgement to decarbonisation of the national grid within the policy also.
With regards to Part D, it should be ensured that it is achievable to obtain the requirements of Part C on all sites prior to offsetting.
Further clarification is needed on the requirements of the Whole Life Carbon Assessment and it should be ensured any resulting recommendations are included in viability.
In conclusion, the most appropriate method of achieving net zero carbon in new buildings would be through nationally set building regulations.