Development Management Development Plan (DPD)

Comment

Representation ID: 901

Received: 20/08/2010

Respondent: DPP

Development Management Document (Issues and Options)
DPP Sustainability would like to offer a submission in respect of Section 4, 'Issue DM4 - Low
Carbon Development and Efficient Use of Resources' relating to energy usage throughout the region.
From the outset we would like to commend Southend-on-Sea Borough Council on the emphasis that is placed on sustainable energy objectives in the draft guidelines. We would like to expand on this by answering the questions proposed in the document as outlined below.

Comment

Representation ID: 902

Received: 20/08/2010

Respondent: DPP

16. Do you agree with the suggested option?
The suggested option is comprehensive in its coverage taking the energy hierarchy as its basis whereby efficiency is promoted as the starting point. However it has a bias towards the reduction of energy rather than carbon reduction methods and as such is not in line with the national sustainable policy objectives. In addition, it is felt that a greater importance and weight should be
given to this section within the guidelines. This will provide a much clearer and coherent sustainable energy policy throughout the region as a whole and ensure that prospective developments in Southend are as energy efficient as possible.
The achievement of the Code for Sustainable Homes and BREEAM Excellent are feasible in general circumstances. However, where exceptions occur and are explained, meaning these targets cannot be achieved, must not be allowed to prejudice the submission. Guidance on the requirements and stages to meet these requirements will also be necessary.

Comment

Representation ID: 903

Received: 20/08/2010

Respondent: DPP

17. Do you consider the alternative options to be more appropriate? If so, please state why. No, the practicality of leaving the policy to rely on national policy and building regulations alone will mean that development across the region is open to challenge in the areas of carbon and energy reduction. Likewise insisting that development in the region exceed national requirements leaves the council open to challenge, slows the development cycle down, and encourages developers to look for alternative less onerous sites to develop. It is our opinion that the key to
ensuring carbon and energy reduction across the region is consistency and rigorous follow through of the local policy which should be clear and enforceable.

Comment

Representation ID: 904

Received: 20/08/2010

Respondent: DPP

18. Is the Council's approach necessary given the emerging Government policy?
Yes, the removal of the Regional Spatial Strategies (RSS's) and with them the targets for renewable and low carbon energy reduction has shown the government intention to devolve the authority for such things to the local level. Therefore it is essential that the council have a clear and detailed policy that allows development to continue at a healthy pace.

Comment

Representation ID: 905

Received: 20/08/2010

Respondent: DPP

19. Should the Council seek to implement zero carbon developments before the Government's changes to the building regulations in 2016?
No, the building community should be allowed to formulate the best way to meet the target by being given a suitably appropriate timeframe. When the zero carbon target was announced the timeline was set to be challenging for developers. Bringing forwards this date will only reduce the likelihood that a coherent development scheme that can meet the criteria will be constructed within the region.

Comment

Representation ID: 906

Received: 20/08/2010

Respondent: DPP

20. Are there any areas of Southend-on-Sea where higher low carbon standards should be sought?
Southend-on-Sea should ensure that new developments within their own region enhance the potential for carbon reduction, providing a clear sign that the improvements in carbon reduction are possible. In addition the council should encourage the improvements in building refurbishments.

Comment

Representation ID: 907

Received: 20/08/2010

Respondent: DPP

21. Should the Council seek to facilitate the delivery of decentralised energy networks within the specific areas within the borough?
Decentralised energy comes with costly infrastructure which can be a negative barrier for inclusion within developments. By facilitating the delivery of such systems the council can ensure inclusion within the region. It is suggested that the council carry out a resource assessment of the region
and identify areas where decentralised energy can be best introduced, bearing in mind key criteria for optimum performance.

Comment

Representation ID: 908

Received: 20/08/2010

Respondent: DPP

Recommendations
Having regard for the issues discussed above we recommend that a robust and multifaceted policy is adopted to ensure a consistent approach is promoted during the assessment of new development proposals. Therefore it is our opinion that Issue DM4 - Low Carbon Development and Efficient Use of Resources should focus on:
* Carbon reduction methods in conjunction with renewable energy for new
developments. A policy requirement for prospective developments (that are above
1,000m² for single or mixed use developments, or for residential developments that are above 10 units) to illustrate a reduction in carbon emissions by 25% is recommended. This is generally deemed to be achievable in development terms without incurring additional costs, and promotes a multi-faceted approach to energy efficiency. Carbon reduction methods could be achieved through reduced energy consumption, increased use of energy efficient and low carbon technologies (e.g. CHP) and also renewable technologies, as in the detailed energy hierarchy within the existing policy context. This is in line with
European and national objectives and polices, and represents the most effective way of meeting regional emission targets by combing a variety of sustainable development methodologies.

Comment

Representation ID: 909

Received: 20/08/2010

Respondent: DPP

We suggest that the Energy Statement's submitted to Southend-on-Sea Borough
Council as part of a planning application pack outlines how the 25% carbon reduction target can or cannot be met. The Energy Statement should provide details of the measures which have been incorporated into the design and fit out of the building (which will result in the reduction of emissions and energy consumption) and also the efforts which have been made to source the building's energy requirements from renewable sources.

Comment

Representation ID: 910

Received: 20/08/2010

Respondent: DPP

Concluding Comments
DPP Sustainability have extensive experience in the area of sustainable energy methods;

Whilst we welcome the fact that the Southend-on-Sea are in favour of promoting sustainable energy methods, we are of the opinion that the text contained in the draft
guidelines lacks clear guidance and does not adequately address the issue of climate change, which should be treated with greater importance and weight;

In order to have a valuable effect on sustainable energy policies, a multifaceted approach should be promoted in line with national and European policy. This is best achieved through a requirement to illustrate that a 25% reduction in carbon emissions has been incorporated into development proposals;

Energy Statements should be promoted as accompanying documents in planning application pack to clearly illustrate to Southend-on-Sea Borough Council how and if the 25% reduction in carbon emissions has been met.