
NM21: ENERGY EFFICIENCY / Addressing the Performance Gap
Proposed Policy NM21: Energy Efficiency / Addressing the Performance Gap
- All planning permissions granted for new and refurbished buildings should demonstrate that they have been tested to ensure the buildings will perform as predicted and will include a planning condition to require the provision of a Post Occupancy Evaluation Report to the Local Planning Authority within a specified period, unless exempted by Clause B. Where the Report identifies poor energy performance and makes recommendations for reasonable corrective action, the applicant must demonstrate that those actions have been implemented before the condition will be discharged.
- All Buildings proposed to be certified to a Passivhaus or equivalent standard with a space heating demand of less than 15KWh/m2/year will not be subject to the provisions of Clause A.
- All development should be ‘zero carbon ready’ by design to minimise the amount of energy needed to heat and cool buildings through landform, layout, building orientation, massing and landscaping. Consideration should be given to resource efficiency at the outset and whether existing buildings can be re-used as part of the scheme to capture their embodied carbon.
- All planning applications for major development are also required to be accompanied by a Whole Life-Cycle Carbon Emission Assessment, using a recognised methodology, to demonstrate actions taken to reduce embodied carbon resulting from the construction and use of the building over its entire life.
- Climate Change Statement will be submitted to demonstrate compliance with the policy (except for householder applications). The statement will include a passive design capacity assessment to demonstrate how opportunities to reduce the energy use intensity (EUI) of buildings over the plan period have been maximised in accordance with the energy hierarchy. Designers shall evaluate the operational energy use using realistic information on the intended use, occupancy and operation of the building to minimise any performance gap.
Supporting Text
The policy is in five parts, the combination of which is intended to deliver a step change in the energy performance of all new developments in New Milton and, in doing so, encourage and incentivise the use of the Passivhaus or equivalent standard of building design. The policy has been informed by the Ringwood Neighbourhood Plan Policy R11 which has recently been successful at examination.
There is a growing evidence base to suggest that buildings do not perform as well as anticipated at design stage. Findings demonstrate that actual energy consumption in buildings will usually be twice as much as predicted. This passes on expensive running and retrofitting costs to future occupants. Clause A of the policy therefore requires that every building in a consented development scheme of any size is subject to Post-Occupancy Evaluation (POE) including actual metered energy use, and to submit the report to the local planning authority. It will be implemented by attaching a planning condition, which will only be discharged once the report has been submitted and any recommended actions to rectify any performance gap with the design stage assessment are carried out by the developer. There is no current adopted development plan policy which seeks to deal with the performance gap. In the absence of supplementary guidance from NFDC on POE, guidance has been included in Appendix D. Passivhaus certified schemes will not fail in this way and they are therefore exempted from this policy requirement. PassivHaus is the most common and rigorous design approach, although the build cost is slightly higher than normal, the ongoing energy cost to occupiers is a fraction of the cost now (so avoiding fuel poverty).
To further incentivise the use of Passivhaus, or equivalent standard, Clause B of the policy acknowledges that there may sometimes be a trade-off between its objectives and local design policy. Although meeting these objectives ought not to compromise a scheme fitting in with the character of a local area, on occasions this may be the case. It therefore allows for some degree of flexibility in meeting local design guidance, especially in terms of prevalent building orientation and density.
Clause C of the policy requires developers to ensure they address the Government’s climate change targets and energy performance at the very initial stages of design. ‘Zero Carbon Ready’ by design means making spatial decisions on layout and orientation of buildings at the outset to maximise the passive design benefits (‘free heat’) of a site and avoids leaving this to technical choices and assessment at the Building Regulation stage, by which time the opportunity may have been lost. Applicants are directed to the Net-Zero Carbon Toolkit created by Cotswold District Council and two partner councils, WODC and Forest of Dean District Council. The toolkit is available as a resource for private and public sector organisations to use and adopt
Proposals seeking to apply the Passivhaus Planning Package (PHPP) must be able to demonstrate that the Passivhaus standard can be achieved. Prior to commencement a ‘pre-construction compliance check’ completed by a Passivhaus Designer accredited by the Passive House Institute (PHI) will be required and secured by condition. Upon completion a Quality Approved Passivhaus certificate for each building will be required prior to occupation, again secured by condition.
Clause D requires all development proposals that are not householder applications to be accompanied by a Whole Life-Cycle Carbon Emissions Assessment, RICS methodology is preferred (link).The assessment will enable the design team to understand and respond to the lifetime consequences of their design decisions and to design for adaptability, longevity and disassembly; contributing to resource efficiency (Clause A) and contributing to the ‘circular economy’. This requirement will be added to the NFDC/NFNPA Council Validation Checklist for outline and full planning applications applying to proposals in the Neighbourhood Plan area until such a time that there is a district-wide requirement.
Clause E requires the Climate Change Statement for applications already required to be submitted, to cover the following:
- an assessment of the proposal to minimise regulated and unregulated emissions, the embodied emissions and the emissions associated with maintenance, repair and replacement of the new building(s), as well as its dismantling, demolition and eventual material disposal.
- a calculation of the energy and carbon emissions covered by the Future Homes Standard and Building Regulations and, separately, the energy demand and carbon emissions from any other part of the development that are not covered by the Future Homes Standard or Building Regulations.
- the proposal to reduce carbon emissions beyond the Future Homes Standard and Building Regulations through the energy efficient design of the site, buildings and services
- the proposal to further reduce carbon emissions through the use of zero or low emission decentralised energy where feasible.
- the proposal to further reduce carbon emissions by maximising opportunities to produce and use renewable energy on-site, utilising storage technologies where appropriate.
- the proposal for a demand-side response, specifically through installation of smart meters, minimising peak energy demand and promoting short-term energy storage.
- an analysis of the expected cost to occupants associated with the proposed energy strategy.
Every new build or redevelopment project in the Neighbourhood Plan area provides an opportunity to make a difference and a contribution towards meeting our climate change targets for 2050 and support the commitment made by NMTC to addressing the climate emergency. This new information requirement need not be an unreasonable expectation of even the smallest schemes for new buildings.