Policy CC/NZ: Net zero carbon new buildings

DRAFT version for various committee meetings.

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What will this policy do?

This policy will set the levels of energy use that will be allowed for new development, how renewable energy should be used to meet that energy need, and how whole-life carbon emissions (emissions associated with constructing buildings), should be taken into account.

Proposed policy direction

That the policy set specific requirements regarding the energy needs of new buildings and how renewable energy should be used to generate that energy requirement.  For those developments unable to meet those requirements fully on-site, the use of a carbon offset mechanism, which would be used to invest in additional renewable energy generation, is proposed.  Consideration is also given to the carbon associated with the construction process and the materials used to construct new buildings, known as embodied carbon, as well as reducing the difference between designed performance and as built performance, known as the performance gap, using Assured Performance processes.    

The technical requirements proposed below have been informed by our Net Zero Carbon Study (2021). 

Net Zero Carbon Buildings – operational emissions 

1. Part A: All housing and non-domestic buildings should achieve a specific space heating demand as follows: 

  • All new dwellings should have a space heating demand of 15-20 kWh per meter squared per year 

  • All non-domestic buildings should achieve a space heating demand of 15-20 kWh per meter squared per year 

2. All heating should be provided through low carbon fuels (not fossil fuels). 

3. No new developments should be connected to the gas grid. 

4. Part B: Total Energy Use Intensity (EUI) targets are achieved as per building type (set out in kWh per m2 per year), as follows: 

  • All dwellings should achieve an EUI of no more than 35 kWh per m2 per year. 
  • Non domestic buildings should achieve the following EUI of no more than the following, where technically feasible, by building type: 
    • Offices: 55 kWh per m2 per year 

    • Schools: 65 kWh per m2 per year 

    • Multi-residential (e.g. student accommodation): 35 kWh per m2 per year 

    • Retail: 55 kWh per m2 per year 

    • Leisure: 100 kWh per m2 per year 

    • Research facility: 150 kWh per m2 per year 

    • Higher education teaching facilities: 55 kWh per m2 per year 

    • Light industrial uses: 110 kWh per m2 per year 

    • GP surgery: 55 kWh per m2 per year 

    • Hotel: 55 kWh per m2 per year 

5. Part C: Proposals should generate at least the same amount of renewable energy (preferably on-plot) as they demand over the course of a year.  This should include all energy use (regulated and unregulated), calculated using a methodology proven to accurately predict a building’s actual energy performance.   

6. Where a development of multiple buildings is concerned, the renewable energy generation requirement should be calculated and demonstrated across the whole development so that buildings that are able to exceed the requirements do so in order to compensate for any buildings onsite that cannot meet the requirements. 

7. Part D: Offsetting to only be used in certain circumstances (e.g. insufficient roof space to generate renewable energy) – money would only be used to invest in additional renewable energy generation to ensure net zero carbon buildings are delivered.  Where a proposal cannot meet the requirements in full, in addition to offsetting, the development must be futureproofed to enable future occupiers to easily retrofit or upgrade buildings and/or infrastructure in the future to enable achievement of net zero carbon development.  

8. All developments must demonstrate use of an assured performance method in order to ensure that the buildings’ operational energy performance reflects design intentions and addresses the performance gap. 

Net Zero Carbon Buildings – construction 

9. Residential developments of 150 homes or more and non-residential development of 1,000 m2 or more should calculate whole life carbon emissions through a nationally recognised Whole Life Carbon Assessment and demonstrate actions to reduce life-cycle carbon emissions.  This should include reducing emissions associated with construction plant.   

Why is this policy needed?

The UK has a legally binding requirement of net zero carbon by 2050. In June 2021, government adopted its sixth carbon budget, which forms part of the route map to achieve net zero carbon by 2050, 63% reduction in emissions from 2019 to 2035 (78% relative to 1990). 

Our Net Zero Carbon Study (2021) advises that new buildings need to be built to net zero carbon as soon as possible for Greater Cambridge to play its part in meeting the UK’s carbon budgets.   This will require rapid decarbonisation across all sectors of the UK economy, including the built environment.  Our evidence base makes it very clear that if we are to achieve net zero carbon by 2050, then new development will need to go further than the requirements set out in current and future Building Regulations. 

The proposed policy deals with all of the carbon associated with new buildings, both that associated with the energy needed for powering our homes and commercial buildings, as well as the carbon associated with the processes and materials used to construct those buildings, known as embodied carbon.   Policy CC/CE also gives consideration to what happens to materials at the end of a buildings life.  This is known as whole life carbon.  It also seeks to address the performance gap between designed performance and as built performance through the use of Assured Performance processes.  These are elements that are not fully covered in other regulations such as Building Regulations. 

In terms of the ability for local planning authorities to set policy requirements related to carbon associated with new buildings, legally, this is something that a Local Plan can do, a matter confirmed in January 2021, when government issued a response to its consultation on the Future Homes Standard.  As part of the consultation, government had asked whether it should ‘ban’ Local Plans from going beyond Building Regulations.  But having considered the responses received, it has decided not to and reconfirmed its position that Local Plans can set energy standards for new homes that go beyond Building Regulations. 

Given the high standards proposed, the sustainable show home policy which is currently part of the South Cambridgeshire Local Plan will no longer be required. The policy would also replace the current policy in Cambridge requiring achievement of BREEAM Excellent for all new non-residential development. The standards contained within the policy and other policies in the First Proposals are such that they will exceed current BREEAM requirements, although developers may still choose to utilise BREEAM certification to meet the assured performance aspects of the policy.  Also, it is not proposed to continue with the consequential improvements policy given the difficulties of implementing this policy via the planning system. 

What consultation have we done on this issue?

Feedback we received through the First Conversation included support sustainable and resilient design for new development including zero carbon, heat pumps, green roofs, green walls, grey water systems, solar panels. There was support for applying standards such as Support Passivhaus and BREEAM standards. We should offset carbon emissions from new development, and consider the impacts of embodied carbon. Others said our policies should be flexible to allow for innovations during the Plan period, or that we should not set higher energy performance policies than required nationally.

What alternatives did we consider?

No policy, leaving the delivery of net zero carbon to Building Regulations and the Future Homes/Buildings Standard - Not considered a reasonable alternative as it does not fulfil our statutory duty set out in the Climate Change Act and Planning Act and will not enable Greater Cambridge to achieve its carbon budget. 

This approach would also not deliver net zero carbon in line with the Paris Agreement 1.5°C trajectory. Building Regulations only considers regulated energy, whereas in order to achieve net zero carbon, all energy consumption from new buildings must be met by renewable energy. 

The Future Homes Standard only requires new homes to be ‘zero carbon ready’, leaving further carbon reduction to achieve net zero carbon to home owners, further adding to the retrofit burden and the 28 million homes in the UK already needing retrofit to achieve net zero carbon by 2050.  In addition, the issue of embodied carbon is not, at present, considered by any other regulatory framework, and there does not appear to be any plans for it to be considered through Building Regulations.  This leaves a significant policy gap in the delivery of net zero carbon by 2050. 

Existing policies in adopted 2018 Local Plans

South Cambridgeshire Local Plan 2018 

  • Policy CC/1: Mitigation and Adaptation to Climate Change 

  • Policy CC/3: Renewable and Low Carbon Energy in New Developments 

  • Policy CC/5 Sustainable Show Homes 

Cambridge Local Plan 2018

  • Policy 28: Carbon reduction, community energy networks, sustainable design and construction, and water use 

  • Policy 30: Energy-efficiency improvements in existing dwellings. 

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