2024/2025 will see wholesale changes to planning policy across the Southwest which will impact environmental strategies for all developments. But is the construction industry ready for these changes?
Bath and Northeast Somerset
Bath and Northeast Somerset threw down the gauntlet in Feb 2023 by introducing some of the most advanced low carbon planning policies in the country.
Policy SCR6 - Sustainable Construction Policy for New Build Residential Development
Space Heating <30kWh/m2/annum
Total Energy Demand <40kWh/m2/annum
On-Site Renewable Energy Generation to balance the Total Energy Usage
Policy SCR7 - Sustainable Construction Policy for New Build Non-Residential Buildings
Net zero for regulated operational carbon emissions
Policy SCR8 - Embodied Carbon
Embodied carbon assessments required for developments over 50 dwellings or 5000m2. Score of 900kgCO2e/m2 for substructure, superstructure and finishes must be achieved.
BaNES’ local plan update also saw the introduction of a carbon offset fund for projects which could not achieve net-zero on-site. The price of offsets is anticipated to be £373-378/tCO2 based on the BEIS Green Book values.
The remaining members of the West of England Combined Authority are currently updating their local plans to align and surpass the targets set out by BaNES.
Bristol
Bristol have just published their local plan update which will be formally adopted in Q1 2025.
Policy NZC2 - Net zero carbon development – operational carbon
Space Heating <15-20kWh/m2/annum
Total Energy Demand <35kWh/m2/annum
On-Site Renewable Energy Generation to balance the Total Energy Usage
Passivhaus Classic offered as an alternative way to achieve compliance.
Policy NZC3 -Embodied carbon, materials and waste
Embodied carbon assessments required for developments over 10 dwellings or 1000m2.
Upfront embodied carbon:
o Residential (4 storeys or fewer) - <400 kgCO2 e/m²
o Residential (5 storeys or greater) - <500 kgCO2 e/m²
o Major non-residential schemes - <600 kgCO2 e/m²
Whole life-cycle embodied carbon:
o Residential (4 storeys or fewer) - <625 kgCO2 e/m²
o Residential (5 storeys or greater) - <800 kgCO2 e/m²
o Major non-residential schemes - <970 kgCO2 e/m²
Bristol local plan update will also include a carbon offset fund priced at the same rate as BaNES.
South Gloucestershire
South Gloucestershire are currently consulting on their new local plan which should be adopted in 2025.
Policy PSP6 – Onsite renewable and low carbon energy
Net-zero in operation. Regulated or regulated and unregulated TBC.
Passivhaus Classic offered as an alternative way to achieve compliance.
South Gloucestershire local plan update will also include a carbon offset fund priced at the same rate as BaNES.
North Somerset
North Somerset are still consulting on their new local plan, but the latest consultation document closely replicates that of Bristol.
Policy DP6 – Net Zero Construction
Space Heating <15kWh/m2/annum
Total Energy Demand <35kWh/m2/annum
On-Site Renewable Energy Generation to balance the Total Energy Usage
Passivhaus Plus offered as an alternative way to achieve compliance.
Embodied carbon emission targets currently being reviewed.
Interestingly, whilst Passivhaus Classic is being used as an alternative route to compliance by Bristol and South Glos, Passivhaus Classic does not actually achieve net-zero. This means quality assurance through proof of airtightness and no thermal bridging is being prioritised over renewables.
The direction of travel is clear, but how achievable are these targets. Analysis undertaken by the University of Bath reviewing planning submissions against the latest BaNES targets found the following:
54% of eligible planning applications did not comply with the new operational energy policy, primarily due to a lack of awareness.
1/3 of applicants submitted incomplete energy model calculations, making them unreproducible and difficult to verify.
88% of those applications which failed to meet the energy standards were due to a lack of on-site renewable energy generation. Largely due to available roof space for PV.
Concerns were also raised around the cost of creating the necessary energy models to demonstrate compliance at planning stage. This applies particularly to small developments where these works will form a disproportionally large percentage of the overall construction cost.
Major developments will likely also incur additional costs due to the new offsetting requirements in BaNES and Bristol. Taking the RIBA Climate Challenge 2030 ‘business as usual’ model as a baseline the following offset costs could be assumed:
£94.50/m2 operational carbon (£7,465 for a 2-bed, £8,788 for a 3 bed) worst case scenario
£214.48/m2 embodied carbon (£16,943 for a 2-bed, £19,946 for a 3-bed)
These costs are significant and can add up quickly across a large development site. If you need any support reviewing your current or future developments against these standards feel free to get in touch for some advice.
gcp offer Passivhaus design, whole life carbon assessments, and energy strategy assessments which can help developers to navigate these new planning changes to make the most informed decisions.