CC/NZ: Net zero carbon new buildings

Policy needs to come into being as soon as possible - otherwise new carbon emitting developments will be built in the meantime.

Support

The plan for net zero housing does not pay sufficient attention to embedded carbon emissions. The draft talks of a need to 'demonstrate actions to reduce life-cycle carbon emissions.'. But this requirement is not strong enough. It needs to stipulate how much emissions should be reduced and over what timescale. Also, inadequate attention has been given to restoring old buildings rather than building new. As the attached report shows reusing empty homes could make an initial saving of 35 tonnes of carbon dioxide (CO2) per property by removing the need for the energy locked into new build materials and construction

This is essential.

Agree in principle. However, the policy direction is towards taking into account the whole-life carbon emissions which are defined as emissions associated with constructing buildings. This needs to be expanded to include the carbon emissions associated with decontamination and demolition of existing buildings on the site, such as at the current Cambridge Waste Water Treatment Plant and the eventual demolition of the new building, ensuring that low carbon materials are used in construction and avoiding those with high carbon expenditure in their manufacture, e.g. cement.. This should include the carbon expenditure of Heavy Commercial Vehicles (HCVs) used to transport demolished building materials and the disposal of such materials with their embodied carbon.

Carbon expenditure, emissions and embedded carbon to decommission fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon expenditure associated with fulfillment of S/NEC Policy

We support this policy. The policy should recognize the savings in embodied carbon to be made by repurposing existing buildings rather than building new – planning policy should facilitate appropriate change of use.
Page 11 – Oxford Cambs Regional Arc – this seems woolly. Why can we not adopt a more prescriptive approach like that set out in the London Plan which already goes beyond Part L of the building regulations. It is commendable to work with government to enhance building regulations, but shouldn’t the Oxford-Cambridge arc be leading the way on this? This would encourage greater micro-generation, for example.
Page 11 – we will encourage Arc Partners to exceed minimum standards. This should be firmer – stipulate, don’t encourage to avoid a race to lowest cost.
Page 12 – is BREEAM the best measure?
Page 15 –should this be more prescriptive in terms of how much emissions from construction plant should be reduced by? Maybe something here and something around Air Quality could encourage electric plant.
Page 19 – could the last resort offsetting option be somehow more onerous financially?

“Operational emissions” (7) is too lax. Developers may be able to exploit this to evade the net zero requirement. “Future-proofing” is not enough – carbon emissions have to be reduced over the next few years to have the necessary impact.
“Net Zero Carbon Buildings – Construction” is very disappointingly brief and unspecific – there should be clearer targets.

(Education) A change to the Building Regulations which came into force on 1 January 2019 means that all new buildings owned and occupied by public authorities must be ‘Nearly Zero Energy Buildings’, and policies and specifications of all buildings reflect this. To achieve compliance, the Council’s preferred policy is a combination of different mechanisms including achieving at least 6 BREEAM energy performance “Ene01” credits, designing buildings to achieve an EPC rating of A or better and/or installing on-site renewable energy generation sized to meet a significant proportion (>80%) of the building’s expected energy use. Policy CC/NZ is less flexible with specific targets set for non-domestic buildings, including schools.
Delivering schools which are ‘Nearly Zero Carbon’ buildings has increased the capital cost of construction by 10%. With further, and more specific targets, such as those above, and notwithstanding advances in technology, additional cost is likely to be incurred. The Council would therefore require associated policies to make clear the expectation on developers meeting such costs through section 106 agreements.

The Wildlife Trust strongly supports the inclusion of this policy and the proposed policy direction.

Draft policy CC/NZ sets a high threshold of 150 homes for calculating whole life carbon emissions. Support should also be expressed for developments of <150 dwellings where this information is provided voluntarily.

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

The current wording of the text to ‘Net Zero Carbon Buildings – operational emissions’ is considered to be too technical and not clear and will be difficult to work in practice. This is contrary to paragraph 16 (d) of the NPPF that requires Plans to contain policies that are clearly written and unambiguous.

The current wording of the text to ‘Net Zero Carbon Buildings – operational emissions’ is considered to be too technical and not clear and will be difficult to work in practice. This is contrary to paragraph 16 (d) of the NPPF that requires Plans to contain policies that are clearly written and unambiguous.

Draft Policy CC/NZ sets a high threshold of 150 homes for calculating whole life carbon emissions. Support should also be expressed for developments of <150 dwellings where this information is provided voluntarily.

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

Huntingdonshire District Council support the proposed policy CC/NZ.
The incorporation of extra climate adaptation and resilience features into new developments could boost the acceptance amongst developers of these approaches and improve market demand for them, hence potentially boosting their viability for application across Huntingdonshire.

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.

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.

NECAAP sustainability is misleading - should factor in carbon expenditure to decommission fully operational WWTP, including decontamination and factor in carbon cost of rebuilding plant on Green Belt just one mile away. This should include transfer tunnels, HGV traffic, carbon cost of materials, many of which will be imported. Concrete one of the highest carbon intense materials. Importance of the Climate Change Committee’s advice to Government for last 3 years is to focus on construction as a source of carbon- both local materials and huge amount of imported building materials.

I’m very pleased to see that this policy is going beyond the minimum current requirements. The energy usage requirements are low and will be a challenge to developers, but are necessary. Well done.
I note that reference is made to “methodology proven to accurately predict a building’s actual energy performance” and “a nationally recognised Whole Life Carbon Assessment”. I hope that these will be sufficiently developed by the initiation of this Plan. Will there be defined ways of ensuring that developers comply with these requirements?

CC/NZ – Carbon expenditure, emissions, and embedded carbon to decommission a fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon cost of fulfilling S/NEC Policy
CC/CS – decommissioning and building a new Waste Water Treatment Plant on prime agricultural land as a means to fulfil S/NEC Policy is in contrary to CC/CS

Supported – Note:
Carbon expenditure, emissions and embedded carbon to decommission fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon expenditure associated with fulfillment of S/NEC Policy

We strongly support the proposed policy

We suggest that it would make more sense for the space heating requirement to state “All new dwellings should have a space heating demand of less than 20 kWh per meter squared per year”, rather than the current proposal of “15-20 kWh per meter squared per year”.

Support that no new developments should be connected to the gas grid and all heating should be provided through low carbon fuels. Also support dwellings should generate their own energy, it would be good to see solar panels mandated on all future developments.

It should be a mandate that EV charge points are installed for all new housing and commercial developments, reducing the reliance of ICE cars.

CC/NZ: Net zero carbon new buildings

4.8. This policy sets out an ambitious approach to address carbon emissions through the sustainable design of new buildings, reducing energy demand in the first instance through a ‘fabric first’ approach, before selecting low carbon, fossil fuel free building systems and then employing renewable technologies to offset residual emissions to zero. The policy also incorporates an approach to tackle embodied emissions in construction materials and processes by consideration of whole life carbon analysis to ensure that low impact construction methods are deployed.
4.9. In order to meet these policy objectives, for the site at North Cambourne MGH will utilise the energy hierarchy approach to first reduce the demand for heating through efficient design of the building fabric. In addition MGH will adopt measures consistent with those set out in the UK Government’s Future Homes Standard consultation , intended to provide new homes ready for the 2050 net zero carbon economy. This ‘fabric first’ approach has the added benefit of ensuring energy bills will be kept to a minimum for new occupants.
4.10. The site will not be connected to the gas grid and will instead employ all-electric building systems, providing heating, cooling (where needed) and hot water through the use of heat pump systems. These will avoid the need to retrofit or upgrade building systems in future.
4.11. Where suitably co-located, waste heat from non-domestic uses can be used to heat homes. Opportunities for heat sharing between domestic and non-domestic uses will be explored in more detail as the scheme design is progressed.
4.12. A systematic approach to renewable technology selection will be undertaken to understand the feasibility of various technologies in delivering the maximum level of renewable energy generation through onsite means, aiming to achieve net zero carbon emissions without offsetting where possible. Site-wide emissions will be established for all building uses, aiming to provide net zero across the site as a whole, with buildings with surplus savings offsetting those where net zero is harder to achieve.
4.13. Offsite measures, such as carbon offsetting, will only be used as a last resort in situations where it is impractical to generate sufficient renewable energy from onsite systems.
4.14. Whole life carbon assessment will also be undertaken to establish the lifecycle performance of proposed embodied and operational energy efficiency measures, in line with current RICS best practice guidance. The whole life carbon analysis will account for the ongoing decarbonisation of the UK electricity network, with the UK Government recently announcing that it is aiming for net zero carbon electricity from 2035.

It seems hard to believe that the developments can generate enough renewable energy to meet their needs at the required standards. For residential buildings alone, at a conservative average of 50m2 per home, 49,000 homes using 35kWhr/year will need 85 Gigawatt hours per year of new generation capacity paid for within the homes price. This is well beyond the capabilities of developers to construct, for example. wind turbine farms.
If the assumption is that it will be via photovoltaics this too seems unlikely. An average home of 50m2 would need 1750 kWhr/year. At typical solar efficiencies this would require 17m2 of solar panels, which is all of the South-facing roof capacity, for every single house.
Does the plan have confidence that developers can design and afford net zero energy homes within the required standards, or does it expect that nearly every development will need “offsetting” measures? What absolute standard is the plan going to apply to for offsetting, or what are the “futureproofing” approaches?

Carbon expenditure, emissions, and embedded carbon to decommission a fully operational waste water treatment plant and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon cost of fulfilling S/NEC Policy

The policy should be encouraging a fabric first approach to heating homes. All homes should be passivhaus standard. The additional costs of meeting this standard should not be considered standalone. By this I mean that not only should the costs of building the house to this standard be considered. Assuming the house is heated using electricity the incremental costs required to increase electricity generation and distribution capacity should be considered. In winter it is very unlikely that the electricity requirements can be met on site (e.g. solar). Off-shore wind, nuclear and other means of production will be required to generate the electricity which will entail substantial additional distribution infrastructure.
The cost of this additional generation and distribution infrastructure must be factored when considering the cost-benefit of a building’s insultation requirements.

With reference to point number 9 - I would like to see this policy in effect for ALL new housing developments to avoid an unwanted preference for housing developments of between 100-150 houses. Policy should be stricter, in order to meet our global climate change mitigation objectives.

Strongly agree that all new development should be reliant on renewable energy. Particularly support clear targets for energy usage for each building type, and with very limited exceptions for when renewable energy can be sourced off site. Concern that there is no reference to consideration of existing buildings (which may be demolished) to be replaced by new buildings, should this not be in the policy consideration?

Countryside support the inclusion of a policy to control energy usage, utilise renewable energy sources and account for whole-life carbon emissions in new developments. Such a policy will be an important tool in ensuring energy efficient developments are delivered and that objectives regarding the mitigation of climate change impacts can be realised.

Whilst the policy should set clear and evidenced based requirements it should also provide flexibility to include for site-specific circumstances and changing standards, legislation and technology. This can ensure that the most suitable approach can be taken for each site at the point in time that it comes forward, supporting delivery but also climate change objectives. The policy should also recognise the important contribution that a ‘fabric first’ approach to the design of new buildings can make to achieving energy efficiency.

Countryside has recently committed to becoming a net zero company by 2030 and have released a report ‘Pathfinder: Marking out the route to Net Zero’3 which sets out the principles that Countryside will follow to respond to the global call to arms for climate action. Land to the west of Cambridge Road, Melbourn will benefit from Countryside’s action plan set out in the Pathfinder report to deliver its commitments. To achieve their targets Countryside are examining their construction and manufacturing operations and also the design of their homes and development. Measures include improving fabric efficiency, installing renewable energy and recovery systems, switching from diesel to hydrotreated vegetable oil for on-site plant machinery, using suppliers with similar climate change targets, increasing tree planting and reducing embodied carbon by using timber frame homes. Such measures can be incorporated into the proposals at the site to satisfy the direction of this policy.

3 https://www.countrysideproperties.com/sites/default/files/2021-11/Pathfinder%20-%20Marking%20out%20the%20route%20to%20net%20zero.pdf

Positive: I like that the responsibility to produce net zero homes sits with the developer. It is always cheaper (in money, materials and emissions) to produce a net zero home than to retrofit it. I like that there is a clear threshold for energy intensity of the building and a requirement of installing renwable energy to meet that demand.
Could do more: It doesn’t specify required space to accommodate energy storage, nor electric car charging facilities, especially for the new dwellings located in villages. Is there a scope for district heating/cooling instead of individual homes or individual buildings?