Councillors considered a note which briefed the Board on the draft Climate Change, Sustainable Design, Construction and Energy Supplementary Planning Document (SPD) appended to the note and invited its comments on the draft document for consideration by officers as part of the related consultation process. The note described the background, scope and role of the SPD and set out the process and next steps.
The Policy Officer – Planning Policy gave a presentation to introduce and explain the SPD. The presentation covered Development Plan Documents (DPDs), the difference between DPDs and SPDs, Local Plan: Strategy and Sites 2015-2034 policies addressed by this SPD, and the aims of this SPD together with an outline of the Sustainable Design and Construction Guide forming part of it.
The SPD was closely aligned to Local Plan Policies and covered Policy D2: Climate Change, Sustainable Design, Construction and Energy; Policy D1: Place shaping (paragraphs 2 and 10); and Policy P4: Flooding, flood risk and groundwater protection zones (paragraph 5).
Policy D2 consisted of sections relating to climate change adaptation, energy, and design and construction. It featured principles set out in energy and waste hierarchies whilst requiring submissions in respect of sustainable design and construction / climate change adaptation, and of low carbon energy / carbon emissions in relation to major and non-major developments.
Policy D1 required all new development to perform positively against ‘Building for Life’ guidance whilst meeting industry standards for new design, limited coverage of energy efficiency and efficient use of natural resources to maximise passive solar gain.
Prioritisation for sustainable drainage systems (SuDS) relating to surface water management and mitigation of heavy rainfall events were required under Policy P4.
The aims of the SPD were to encourage compliance with policy, ensure an improved decision-making process and achieve better development outcomes. There were six sections of the SPD which were an introduction, summary of policy, overview of information that must be submitted in support of planning applications, energy statements (major development), sustainability statements (major development) and requirements for non-major developments.
The Sustainable Design and Construction Guide aligned content with policy, provided guidance on best design and construction practice, and was based on guidance from reputable bodies and internal practitioners. The Guide covered an energy hierarchy; site layout; landscaping and urban form; building design; water efficiency; climate change adaptation; measures that enabled sustainable lifestyles; resources, materials and waste; and building for life.
The following points arose from related questions, comments and discussion:
· In terms of abbreviations in the SPD, it was clarified that SAP was an acronym for the Standard Assessment Procedure which was the methodology used by the Government to assess and compare the energy and environmental performance of dwellings and SBEM was an abbreviation for the Simplified Building Energy Model which was a tool developed to provide an analysis of a building's energy consumption. Developers were required to provide the latter to meet the Building Regulations. The relevant industries were familiar with both acronyms.
· It was suggested that wood chip fired combined heat and power (CHP) systems may no longer be an environmentally acceptable power source owing to the carbon dioxide impact of felling mature trees and burning wood and the shortage of wood chip nationally necessitating import from abroad. The use of photovoltaic solar roof tiles / panels was suggested as an alternative.
· In terms of developers’ submission requirements, officers would refer to Policy D2 to ascertain whether the requirements had been met, and if not, the necessary information would be sought. The requirements for smaller developments, of ten homes or fewer, was less stringent.
· In addition to being a consultee in respect of all future SPDs, councillors expressed a wish for the Board to receive the related statements of public consultation responses to give it an opportunity to comment on those and the final draft document prior to their submission to the Executive.
· 30 responses had been received in respect of the SPD public consultation which was an average amount for this type of technical document. The responses, many of which were from industry, were valuable and had been published on the Council’s website on 1 June 2020.
· As it was felt that the majority of references in the SPD were to new development, it was suggested that some guidance concerning conversion of existing premises, such as the conversion of offices and retail units to homes, should be included.
· Although the impact of Coronavirus could bring about societal changes with future implications for planning policies, the intention was that current policies would be adhered to until the evidence base and / or Government guidance changed.
· It was suggested that the introduction of a reward scheme may encourage developers to comply with all requirements and standards.
· The SPD needed to specify that developments should provide space for charging electric vehicles and accommodating car clubs.
· Conditions could be imposed on planning permissions to ensure that developments met the energy efficiency requirements specified in the related planning applications and policies could allow post construction inspections as a means of establishing whether developments had achieved compliance with energy requirements. However, inspections and follow up enforcement action to secure compliance were resource intensive and not pursued by many councils. Research released by the Government found that new buildings were generally failing to meet the energy and carbon standards set out in Building Regulations once built (the ‘performance gap’). Some research suggested that new buildings as built may perform up to 60% worse than as designed, and it was anticipated that the Government would be introducing a new compliance approach in Building Regulations. The Board felt that the Executive should be made aware of the need to make resources available for officers to undertake the necessary enforcement work in this area.
As summarised by the Chairman, the main views expressed by the Board as its consultation response for officers to consider as part of the related SPD consultation process, which would be fed back to the Executive for consideration, were as follows:
· References to energy sources in the SPD should be broadened to include types of low carbon networks other than CHP to maintain flexibility as alternative and more effective low carbon technologies became available for use.
· Requirements for energy efficiency and carbon emission in respect of property conversions in addition to new build should be included in the SPD.
· The SPD should specify that new developments should make provision for electric vehicle charging and car clubs.
· The Board should receive statements of public consultation responses in respect of future SPDs prior to their submission to the Executive.
· Resources should be made available for the post construction inspection and enforcement of energy efficiency standards, including small developments of ten or fewer properties.