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Policy GESP3: Net-Zero Carbon Development

To ensure that developments within the Greater Exeter area contribute to meeting the overarching net-zero target set out in draft policy GESP2, applicants for all developments which propose the construction of new home(s) or non-residential floorspace or change of use will be required to submit to the local planning authority a carbon statement for approval and implementation. The carbon statement will demonstrate that proposals are designed, constructed and will perform to deliver net-zero carbon emissions, taking account of emissions from primary energy use and transport, broadly in compliance with the energy hierarchy.

In meeting the above requirement, proposals will demonstrate that they meet the sustainable and active transport targets which apply to the site and:

  1. Minimise energy demand across the development and avoid temperature discomfort through:
    1. Passive design, solar masterplanning and effective use of on-site landscaping and green infrastructure
    2. The “fabric first” approach to reduce energy demand and minimise carbon emissionsnecessary for the operation of the building
    3. Low carbon solutions where additional energy is required for building services such as heating, ventilation and air conditioning
  2. Maximise the proportion of energy from renewable or low carbon sources through:
    1. Ensuring that opportunities for on-site or nearby renewable energy generation or connection to a local decentralised energy scheme are exploited
    2. Ensuring that the ability to install future solar PV or vehicle-to-grid connections is not precluded
    3. Storage of on-site renewable energy generation
  3. Ensure in-use performance is as close as possible to designed intent through:
    1. Use of a recognised building quality regime and consistent approach to calculating both, the designed and in-use performance
    2. Ensuring that at least 10% of buildings on major developments deliver in-use energy performance and generation and carbon emissions data to home owners, occupiers, developers and the local planning authority for a period of 5 years, clearly identifying regulated and unregulated energy use and any performance gap. Where a performance gap is identified in the regulated use, appropriate remedial action will be required

Where it is not feasible or viable to deliver carbon reduction requirements on-site, methods such as offsetting elsewhere will be considered. This will need to be through a specific deliverable proposal or financial contributions to an accredited carbon offsetting fund.

Development proposals should calculate whole life-cycle carbon emissions through a nationally recognised Whole Life Cycle Carbon Assessment and demonstrate actions taken to reduce life-cycle carbon emissions.

5.8 Various proposed policies of the GESP and other development plans are designed to work together to reduce the carbon impact of new development in line with the draft vision and the net-zero target set out in draft policy GESP2. Draft policy GESP3 concentrates on development- specific requirements and seeks to ensure that proposals are designed, constructed and perform to deliver net-zero carbon emissions. To evidence this, the policy requires a “mock” Standard Assessment Procedure (SAP), Simplified Building Energy Model (SBEM) or Dynamic Simulation Model (DSM) test to be submitted as part of a Carbon Statement, and subsequently through the “real” SAP, SBEM or DSM test as the development passes through Building Control. To achieve net-zero carbon emissions, the draft policy proposes following an energy hierarchy of interventions, as set out below. The policy allows flexibility as to how that overarching target is met, but, through the energy hierarchy, advocates a “fabric first” approach before considering on-site renewable generation or off-site contributions. The hierarchy gives a sensible structure to the Carbon Statement required by the policy. The Greater Exeter councils will publish further guidance on the production of Carbon Statements in due course.


The Energy Hierarchy

5.9 Development location and sustainable transport investment is the most significant way to reduce carbon emissions from new development. By ensuring easy access to jobs and basic services/facilities by active travel and high quality public transport links, the need to travel by private car can be reduced. We propose this should be reflected in the GESP spatial development strategy and the location of its allocations for major development. Digital connectivity is also key to reducing the need to travel by enabling home working and access to online services. The draft policies in this chapter deal with this element of the hierarchy. Carbon emissions arising from travel associated with development will be minimised by applying the policies in the Movement and Communication chapter including draft policy GESP23: Sustainable travel in new developments and draft policy GESP24: Travel planning. Any residual carbon emissions from transport will then be taken into account in the submitted Carbon Statement and the delivery of net zero carbon emissions. The remaining elements of the hierarchy are set out below.

Priority 1

  • Use masterplanning to minimise energy demand through passive design.
  • Effective use of landscaping and green/blue infrastructure.
  • Adopt a ‘fabric first’ approach.
  • Development should be designed to be climate resilient.

Priority 2

  • On-site renewable energy generation should reduce unavoidable carbon emissions associated with any residual energy use.
  • Enable electric vehicles to discharge to the grid (vehicle to grid) and help meet the power needs of the building.
  • Off-site measures are a potential option for developments where on-site measures are not practical/viable.
  • Carbon offsetting could be used to fund a large scale energy efficiency programme in existing buildings, large scale renewable energy installations, community energy projects and heat network expansions for instance.

Priority 3

  • Use a recognised building quality regime and monitor in-use data to ensure the in-use performance of buildings is as close as possible to the way they were expected to perform
  • Performance monitoring and evaluation will need to ensure that the sample data is representative of the development as a whole.
  • Where a performance gap is identified corrective action should be taken.

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