Chief Executive’s Report on Draft Plan Consultation
Volume 2 – Summary of Submissions Received
• Consider ‘total carbon’ benchmarks based on occupancy for all housing units and buildings (private, public and/or rental/leased) • Councils should require (or promote) assessments that consider the environmental impact of new homes across their life cycle (using tools such as the Home Performance Index) as part of planning consent. • Planning authorities should introduce a sustainable accessibility index and a minimum benchmark for all homes and buildings, as a prerequisite for planning approval. • Adopt a no demolition policy and guidance to ensure that no unnecessary demotion is allowed either by developers or the local authority. • Ask applicants to make a case, by way of comparison, of the full Whole Life Carbon calculation, of the impacts of renovation against proposals for demolition and new build, as part of planning permission. • Use the BuildUpon2 Framework to track the delivery of the renovation of public sector stock, as part of the EU Renovation Wave. • Introduce an energy efficiency ‘training clause’ for upskilling attached to all renovation procurement contracts starting in the first year of new Development Plans17. • To set targets for the retrofitting of projects of public housing and to lay down an annual commitment for retrofit of all public building stock. PLANNING FOR CLIMATE MITIGATION & ADAPTATION • The quantum of permissions in DPs should be on zoned and serviced land on Infill/Windfall/brownfield sites within existing settlement boundaries, as a priority. • Take a 15-minute settlement approach, which is central to sustaining and maintaining vibrant residential communities. • ▪ Adopting the Ecosystem Services Approach (ESA)21 to acknowledge and protect the benefits that ecosystem services and biodiversity provide to society and require enhancement measures within all development. • ▪ Adopting the ‘Avoid Shift Improve’ approach to transport to limit in as far as possible lock -in to private car- based transport22. • ▪ Engaging in active land management and site activation measures, including the implementation of the vacant site levy on all vacant residential and regeneration sites. This will help to meet housing delivery objectives in underused sites and buildings. • ▪ Normalising sustainable transport modal shift via the provision of cycle network infrastructure and the promotion of carpooling/sharing, multiuse public vehicles, integrated cycle/walking/EV charging infrastructure. All road and bridge development or improvements to same, must incorporate cycle lane infrastructure as standard. • ▪ Normalisation of the concept of circularity in relation to waste management and include as standard, a chapter on Circularity in all Development Plans, providing for waste re-use as a concept from cradle-to cradle, which is the linchpin of decarbonisation. All references to ‘waste management’ within DPs should be replaced with the term ‘circular economy’ so there is a shift in understanding and emphasis moving from waste to circularit y. • ▪ Plans should highlight for the public, the significant role and the importance of green infrastructure for climate change adaptation and mitigation - from planting, to limiting conversion of gardens to driveways and large scale hard surface soil sealing in developments; to promoting the increased planting of native trees/community planting/gardens; and the need to protect, develop and manage existing ecological networks in urban and rural areas for their many varied and important ecosystem services. • Councils should require the evaluation and demonstration of the Whole Life Carbon emissions of buildings utilising Life Cycle Assessment (LCA) and Life Cycle Costing (LCC) under its Public Procurement rules. The recent EPA Green Public Procurement Guidance25 on office buildings can be used to require more environmental criteria is included in public procurement for all buildings, including for social housing contracts. • Councils should begin to review their own key metrics and begin to establish how to measure carbon for both domestic and public buildings utilising Life Cycle Assessment (LCA) and Life Cycle Costing (LCC) methodologies. • Councils should review the metrics by which they measure the performance of all public buildings under their ownership or leased, by examining both embodied carbon and carbon as represented by energy use (operational carbon). Development Management Standards • Planning authorities should, within one year of the adoption of new plans (from 2021), include new a development control standard to account for net zero, by attaching a condition to permission within specifically zoned sites or areas requiring carbon measurement. • Councils should require, as part of the Energy Statements, details of both operational and embodied carbon of commercial, residential, and public building stock. • Designated a percentage of development land or sites at net zero standard. • The Development Contributions Scheme may be used as a tool to influence the delivery of more carbon efficient housing stock. For homes above optimum sizes, Carbon Development Levies could apply. The revenue accruing
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