Object

Representation ID: 15245

Received: 14/12/2020

Respondent: Stoford Developments

Agent: Delta Planning

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Acknowledges the plan has a crucial role to play in securing mitigation against and adapting to climate change. Fully in support of the aims and objectives of Policy P9 and the general requirement that proposals for major development be accompanied by a Climate Change Assessment as set out under Paragraph 7 of the Policy.
However, some of the site level requirements within paragraph 3 should be less specific to ensure a holistic approach to sustainable design is taken. In particular concerned by mandatory BREEAM Excellent accreditation and a 15% renewable/low carbon energy source requirement as may not present best sustainability outcomes. Also securing BREEAM Excellent on green field sites can be extremely difficult under the new 2018 BREEAM standards. Other approaches can be just as effective in reducing carbon emissions, and could be set out in the Climate Change Assessment already contained in the policy.
As site promoters of UK2 for example we would approach building design to minimise operational carbon emissions based on a three-step approach of • Step 1 - Passive Design Measures, including
i. high levels of air-tightness and insulation to reduce potential heat loss.
ii. rooflights to cover 15% of the warehouse roof area in order to maximise the use of daylight, while optimal orientation takes into account the path of the sun and the prevailing winds.
iii. Where possible offices are designed on a narrow floorplate with dual aspect glazing to take advantage of natural daylight and allow for effective passive ventilation.
iv. Provision of solar shading to ensure thermal comfort and avoid solar gain.
• Step 2 – Efficient Systems. Where energy use is required this can be specified and installed using the most energy efficient plant systems available. This can include intelligent lighting with low-energy LED fittings, daylight linking and presence-detecting controls. High-efficiency, low-NOX boilers with thermostatically controlled radiators to provide heating to offices, and the sub-metering of buildings to help users track and manage their energy consumption.
• Step 3 – Low or Zero Carbon Technologies. Once the operational energy use in the building has been minimised we then design and install low-or zero-carbon technologies to meet customer’s specific operational needs and, as a result, further reduce operational carbon emissions.

In addition to the above, we can undertake ‘cradle to rave’ Carbon Life Cycle Assessments based on the requirements of BS EN 15978 which show the significance of the embodied carbon emissions associated with the construction process which typically accounts for as much as 70% of lifetime carbon emissions of a warehouse, based on a 30-year assessment period. In this way we can therefore reduce embodied emissions through efficient design, the use of low carbon materials and the focused reduction of construction waste including diverting waste from landfill.

Therefore suggest that a more bespoke approach is taken to consider each site on its merits through the requirement to provide a bespoke Climate Change Assessment.
The policy should be clear as regard to which BREEAM standard it relates to (i.e. BREEAM new Construction 2018’ standard) and that these should be referenced as targets given there is no way to guarantee the outcome of an assessment
It is not realistic to expect minor development to undertake BREEAM Assessments