The department welcomes the councils’ ambitions to deliver net zero carbon buildings. In November 2021 we published a new Output Specification (OS21), outlining how all our school buildings will be net zero carbon in operation. It is unclear at present whether the Local Plan policy will require whole-life net zero carbon (a considerably higher bar than net zero in operation) or only consideration/calculation of embodied carbon.

OS21 is broadly aligned with the proposed net zero requirements and other climate change policies, exceeding the requirements in several areas. There will need to be further detail and clarity on some of the requirements. We request flexibility on the assessment methodologies that may be used to demonstrate whole-life carbon and the energy performance gap. To ensure that development is not unnecessarily burdened or delayed, we also recommend flexibility on the application of the requirements so that measures which exceed requirements in some areas may be balanced against marginal under-provision in others, to demonstrate overall compliance. Requiring absolute adherence to each criterion without any holistic consideration of the merits of development would undermine sound professional and balanced judgement.