18/08/2020

FAO Mike Dunphy strategicplanning@bromsgroveandredditch.gov.uk

Dear Mr Dunphy,

Bromsgrove District Local Plan Review

The National Planning Practice Guidance (the Guidance), that requires English local planning authorities to review their respective adopted Local Plans within five years of adoption, identifies several factors to consider when determining whether a plan should be updated, one of which is whether any new social, environmental or economic priorities may have arisen.

The UK is legally bound by the Climate Change Act to reduce emissions 80% by 2050. However on 12 June 2019, the Government laid the draft Climate Change Act 2008 (2050 Target Amendment) Order 2019 to amend the Climate Change Act 2008 by introducing a target for at least a 100% reduction of greenhouse gas emissions (compared to 1990 levels) in the UK by 2050. The Order came into force on 27 June 2019.

The Government has announced a HM Treasury Net Zero Review. This includes a priority to ensure a fair balance of contributions from all those who will benefit, including considering how to reduce costs for low income households. A final report is expected in Autumn 2020.

In July 2019, shortly after the Climate Change Act was passed, Bromsgrove District Council declared a climate emergency. It commits the Council to review the Plan to ensure that climate change is a strategic priority for planning and new development, and to introduce Supplementary Planning Documents where necessary to provide greater clarity and ambition on planning for renewable energy generation and storage, housing energy efficiency, green infrastructure, sustainable drainage and low-carbon transport solutions. The climate emergency cuts across all aspects of the Plan and therefore updates are required to take account of recent changes to national legislation and local strategic priorities. Currently the Plan does not include, for example, specific policies that would require new development to be zero carbon. Significant engagement and cooperation with partner authorities and organisations (e.g. blue light services, utility providers, etc.) is also an absolute necessity to meet the challenging net zero carbon target.

The Committee on Climate Change’s Net Zero report details the independent advisor’s recommendations to the Government on what is necessary to deliver net zero emissions in the UK by 2050. The report recommends that achieving this target will require the full decarbonisation of buildings by 2050. As part of this, buildings will require significant improvements in energy efficiency as a precursor to low carbon heat (including ensuring that no new homes are connected to the gas grid from 2025). The homes we build now will exist in 2050, and as such should be fit for the future and not require costly and unnecessary retrofit.

18.08.20

In response to this, the Council’s Climate Emergency declaration must identify the need to drive towards zero carbon buildings in new developments by as early a date as possible; to ensure energy use is reduced and minimised; and to ensure that heat and power consumed in the district is decarbonised as much and as quickly as possible.

Domestic emissions are primarily associated with space heating and cooling, hot water, cooking and electricity use. The choices taken in the construction of new homes with regards to building design, fabric and services have a significant impact on their energy use and associated emissions. During construction, new dwellings must comply with Building Regulations, which set a minimum threshold standard. Currently, it is within the gift of local authorities to set planning policy requirements that exceed Building Regulations; our current Local Plan has no policies that require this, meaning that forthcoming developments can without fear of retribution be built to exacerbate our district’s climate emergency. This need not be the case:

There are options available to uplift overall carbon reduction of new dwellings beyond simply their energy performance, for example through effective masterplanning and building orientation, renewable energy generation and connection to heat networks. By way of an example, the emerging London Plan includes a net zero target and a requirement for 35% on-site reduction; the recently adopted Plan:MK (Milton Keynes) includes a policy requiring the equivalent of a 39% reduction, and the emerging Oxford Local Plan is looking set to require a 40% reduction from adoption, rising to a 50% reduction from 2026 and zero carbon from 2030.

New developments must be future proofed for a net-zero future now to avoid the need for costly retrofit, suitability and fuel poverty issues being stored up for years to come.

At October 2019, 265 out of 408 (65%) of UK councils had declared a climate emergency with 61% of those declared seeking carbon neutrality by 2030. This clearly demonstrates a vast expectation to set and achieve improvements above existing building regulations

It has been clearly demonstrated that it is economically and technically viable for developers to meet the requirements of the London Plan and Plan:MK. Additionally, Bath and North East Somerset, Bristol, North Somerset, and South Gloucestershire Councils are also considering similarly high standards. Their shared evidence base demonstrates that it is possible to achieve net zero regulated carbon emissions from a combination of energy efficiency (10% improvement beyond Building Regulations) on-site renewable energy and allowable solutions for an additional capital cost of between 5-7% for homes and non-domestic buildings.

It is essential that buildings that are being built today should include responses to the changing climate that they will experience over their expected lifespan. Failure to do so will lead to future costly retrofit, which will be in addition to the retrofitting that is already required to improve existing stock. It may also lead to significant public health concerns arising from overheating and/or lead to unintended higher energy use and carbon emissions from use of avoidable cooling services such as air conditioning.

We would be grateful for an overview of how the Local Plan Review will address our climate emergency and how policy will be used to decarbonise buildings and new development.

Yours faithfully,

Ronnie Cheape
Councillor, Bentley Pauncefoot Parish Council