Good design is a key aspect of sustainable development and construction. It is indivisible from good planning and should contribute positively towards making places better for people. David Alexander examines good practice guidance on sustainable design and construction as recommended in the National Planning Policy Framework (NPPF) (March 2012).
In August 2012, the Cross Sector Group on Sustainable Design and Construction, made up of 19 professional and voluntary organisations covering planning, construction, the environment and academia, produced good practice guidance to assist plan-making and development management in the achievement of sustainable development. The guidance was produced for local planning authorities in England, together with landowners, developers, businesses, town and parish councils, community and environmental groups.
The guidance is arguably NOT statutory, but is expected to be accorded appropriate weight. A key strength is the fact that it has been designed to support the recently agreed policy in the NPPF and other relevant government statutes and guidance. Although it remains uncertain how many local authorities will make positive use of the guidance, it should prevent a proliferation of local sustainability standards and assessments that could both confuse and conflict.
While the guidance is comprehensive, it cannot cover all planning policy issues with a bearing on sustainable design and construction. Material on flood risk is covered in the Technical Guidance to the NPPF, while related cross-sector guides on climate change (Town and Country Planning Association (TCPA)), green infrastructure (The Landscape Institute) and biodiversity (TCPA) provide more detail on planning policies and implementation.
Sustainable development is the most effective way of linking the challenges of climate change, resource use, economic prosperity and social well-being. It cannot be achieved without sustainable buildings and this guidance demonstrates how the planning system can encourage sustainable design and construction. It complements the guidance note Planning for Climate Change, published by the Planning and Climate Change Coalition in April 2012, with a statutory reduction in carbon dioxide levels of 80% below 1990 levels by 2050, 34% by 2020.
One half of UK carbon emissions come from the energy used in constructing, occupying and operating buildings. Sustainable design and construction seeks to:
minimise the use of resources, including energy and water
ensure that the built environment mitigates and is resilient to the impact of climate change
protect and enhance biodiversity and green infrastructure
provide buildings and spaces that are pleasant and healthy for occupiers and users
ensure the sustainable sourcing of materials, and minimise waste.
Sustainable design and construction is of major importance to the UK economy, principally through the Green Deal and investment and support in insulation and construction jobs. While sustainable design and construction of new buildings cannot make development acceptable if a site is unsustainable, the NPPF states that local planning authorities “should not refuse planning permission for buildings or infrastructure which promote high levels of sustainability”. The majority of buildings for the immediate future are already built and a primary aim is to encourage their owners to make them more energy efficient through Housing Strategies and the Code for Sustainable Homes.
Planning and its relation to Building Regulations
Local and neighbourhood plans set the context for new development; the main locations for development and the key criteria against which development proposals will be considered. The NPPF clarifies that local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions and actively support energy efficiency improvements to existing buildings. The Building Regulations set minimum standards for important issues such as energy efficiency, water consumption, and structural soundness. The Code for Sustainable Homes, adopted by Government and with independent assessment and accreditation, encourages a voluntary progression beyond minimum standards and drives innovation and change in the construction industry. Commencing in 2007, the Code measures the sustainability of a home against design categories, rating the “whole home” as a complete package. The design categories include energy/CO2; water; materials; surface water run-off; waste; pollution; health and well-being; management; and ecology. The Code uses a rating system, with 1 being the entry level above the level of the Building Regulations, and 6 being the highest level and reflecting exemplar zero carbon development in sustainability terms. At present, code level 3 has been adopted as “best practice” standard and all social housing needs to meet this as a minimum.
When proposing local requirements for sustainable buildings, planning authorities must demonstrate with robust evidence the circumstances that warrant this, focusing on local or site specific opportunities and constraints. Policies on sustainable design and construction should be set out in development plan documents to ensure full consultation with local communities and other stakeholders, as well as examination by the Planning Inspectorate. Sustainable design and construction play a key role in helping to avoid increased vulnerability to the range of impacts arising from climate change.
Local planning authorities wishing to incorporate sustainable construction policies within their local plans need to base them on evidence specific to where they apply. For example, large urban areas may place more emphasis on ensuring that development is well-adapted to cope with the “heat island” effect than predominantly rural authorities. Areas of water stress may stipulate more exacting standards for water use than where supplies remain plentiful.
Policy requirements on sustainable construction should be proportionate to the type of development and not unreasonably threaten its viability, which otherwise accords with local plan policy. Development viability can vary substantially over time and space. For example, the extra cost of building to Code 3 level fell by approximately three quarters in the three years to August 2011. The strong emphasis on the importance of specific local evidence and assessment is an indication that tailor-made policies are more appropriate.
Practice case examples
In West Berkshire Council, Policy CS16 covers sustainable construction and energy efficiency in both residential and non-residential development. Major development should achieve minimum reductions in total CO2 emissions from renewable energy or low/zero-carbon energy generation on site or in the locality of the development, so long as a direct physical connection is used, unless it can be demonstrated that such provision is not technically or economically viable. The percentage reductions should be based on emissions after energy efficiency measures from the Code for Sustainable Homes, BREEAM or equivalent method have been applied:
10% reduction in CO2 emissions for residential development, rising to 20% from 2014 and zero carbon from 2016
10% reduction in CO2 emissions for non-residential development, rising to 20% from 2014 and zero carbon from 2019.
The Planning Inspectorate reported the following in July 2012.
The NPPF requires local authorities (paras 94/5) to adopt proactive strategies to mitigate and adapt to climate change. These should be consistent with the Government’s zero-carbon policy and adopt national standards.
The NPPF (para 21) does not require investment to be overburdened by the combined requirements of planning policy expectations.
The requirements in CS16 refer to nationally described standards and are consistent with zero-carbon policy. The energy efficiency levels are currently to be achieved by further tightening the Building Regulations to 2016. The additional cost burden of the policy is unlikely to be substantial.
The Environment Agency expressed strong support for the policy because of the need to limit domestic water use in this area of water stress. Although Code levels 3/4 introduce tighter water restrictions than currently required by the Building Regulations, on balance CS16 is sound as submitted.
In the case of the Ashford Borough Council Sustainable Design and Construction SPD (supplementary planning document), the main purpose is to provide guidance on measures and opportunities available to developers and householders to integrate sustainability into their development. The SPD has been provided to help applicants respond positively to the Core Strategy policies. In the case of Policy CS10 Sustainable Design and Construction, all major developments (10 or more dwelling units on residential sites of 0.5 hectares or more in an area; any scheme of at least 1000 square metres gross external floor space or any development on a site 1 hectare or more in areas for non-residential developments) must incorporate sustainable design features to reduce the consumption of natural resources and help deliver zero-carbon growth. Developments are expected to:
achieve stated standards with a strong emphasis on energy, water and materials
reduce carbon dioxide emissions through on-site sustainable energy technologies at the agreed percentages
be carbon neutral through a combination of A+B, with any shortfall met by financial contributions to enable residual carbon emissions to be offset elsewhere in the borough.
Several useful consultation responses were received.
Natural England welcomed the SPD, particularly for the attention paid to including landscapes and habitats within sustainable development of sites and their context.
A local chartered surveyor considered SPDs only added to recession by providing more legislation and further obstacles to development. In reply, the local authority felt that SPDs benefited development as they helped new buildings withstand the impact of climate change as well as making development resource efficient.
The same chartered surveyor felt that the NPPF discouraged the underpinning of local plans with SPDs, unless they promoted sustainable development and added no extra financial burdens to the development process. In reply, the local authority felt the SPD allowed a more precise implementation and guidance of the policy and reduced the burden on developers by only holding house builders accountable for those carbon dioxide emissions that are covered by the Building Regulations.
A retrofit levy on developers would be an alternative to the Code for Sustainable Homes which could add £30,000 to the cost of each new home to be zero carbon by 2016.The local authority considered the Code set nationally recognised, quality assured and monitored schemes. Policy CS10 is a part of the continuing need to put pressure on the development industry to ensure buildings optimise resource use.
There is concern amongst the development industry that good practice guidance does little to alleviate the legislative burden and stimulate growth, especially for new housing. However, a guidance note, SPD or core policy on sustainable design and construction helps prevent singular, inconsistent interpretations. It is important to define what is required from developers and thereby deliver a local authority’s aspirations for sustainable design and construction at a time of climate change, gloomy global forecasts for food production and rising population levels.
Last reviewed 23 January 2013