Policy CC5 - Embodied Carbon

Support

Representation ID: 4624

Received: 04/12/2023

Respondent: Forestry Commision

We do note your Policy CC5 regarding embodied carbon and the choice, use and sourcing of materials and consider that you may wish to consider mentioning the benefits of using locally grown timber in construction.

The 25 Year Environment Plan aims to support ‘Grown in Britain’ to increase the amount of home grown timber used in England in construction, creating a conveyor belt of locked-in carbon in homes and buildings”.

The use of timber in construction to replace concrete, steel and brick can be a major contributor to creating a truly green economy, currently the UK imports around 80% of the wood it consumes annually, we are the second biggest timber importer in the world. Using home grown timber would be of benefit in reducing the carbon cost of buildings in terms of materials, construction and transport etc.

Increasing levels of woodland management by increasing demand for locally grown timber can help improve the habitat condition of neglected woodlands, and also allow owners to address tree disease problems and increase resilience to climate change.

Support

Representation ID: 4754

Received: 13/12/2023

Respondent: Mr Andrew Lunn

Support, cost should not be the justification of demolition, they need to show that this is the best and greenest way forward. Even if cost is higher keeping present structures must be the way forward where at all possible.

Support

Representation ID: 5038

Received: 02/01/2024

Respondent: Julie Gray

I fully support this policy and look forward to seeing it in action as there have been NO attempts to reuse the buildings on the officers mess and No justification given as reasons not to.

Support

Representation ID: 5067

Received: 02/01/2024

Respondent: Mary Cade

The 'practical and viable' wording should be removed from this policy.
Locally grown timber and locally quarried stone will both have lower embodied Carbon, and stone has the advantage that it can be reused again and again (ref CC1). www.leti.uk (a Community Interest Company) provides expert advice on embodied Carbon.
Proposals for demolition should be in line with policy CC1.

Object

Representation ID: 5409

Received: 04/01/2024

Respondent: North Luffenham Parish Council

Para 1. How will Planning Officers Assess, Interpret and enforce this?

Object

Representation ID: 5525

Received: 05/01/2024

Respondent: Tim Allen

The policy could go further in proving specific and positive guidance in respect of the way that under-utilised, or unused heritage assets could be re-purposed. This is especially important, as these buildings have both a heritage importance, but also themselves embody significant carbon in their structures.

Support

Representation ID: 5842

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

As it is a new concept for many developers and homeowners it would be best to include some examples of how the wastage of embodied carbon can be reduced. The phrase “where practical and viable” is unnecessary as the phrase “take opportunities to reduce” is also included.
Examples could include:
• Preference for lime mortar or cement-lime mortars, rather than cement mortars to conserve bricks and stone and enable reuse for construction.
• Preference for hedges as green infrastructure rather than wooden fences or stone walls.
• Timber framing of the whole building structure rather than steel or concrete blockwork
The justification for demolition should be required in the Energy Statement.

Targets should aim for a 40% reduction in embodied carbon or to 500kgCO2/m2 for housing; 600kgCO2/m2 for commercial buildings and schools.

Support

Representation ID: 6047

Received: 07/01/2024

Respondent: Mr Roderick Morgan

The presumption in favour of repair and reuse of a building is not strongly stated enough - currently it is 'easier' to demolish and rebuild than it should be, because this is how it has been for decades - even GDP is biased towards greater consumption and waste in development. There needs to be a very a very high bar based on serious feasibility challenges, not just a financial justification, however slight.

Support

Representation ID: 6286

Received: 07/01/2024

Respondent: Mr Chris Read

I think I support this - but I don't really know enough about it - there's no "don't know" button.

Object

Representation ID: 6557

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Comments made on behalf of the Defence Infrastructure Organisation (DIO) as part of a full written response to Rutland Council. Representations should be read in context and not in isolation.

Emerging Policy CC5 currently requires proposals to provide a “full justification for the demolition” of a building but does not provide guidance on what the Council expects applicants to submit. It would be useful for the Council to outline the minimum level of information expected in this Policy and/or indicate whether an SPD would be prepared on this issue and adopted in line with the Plan to support this matter.

Object

Representation ID: 7173

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Whilst the re-consultation on the Future Homes Standard does not include embodied carbon the government has set out in this consultation that it intends to consult in due course on its approach to measuring and reducing embodied carbon in new buildings.

Persimmon Homes are of the view that policies should come through national standards set through Building Regulations and as such Persimmon Homes are of the view that this policy is not justified and should be removed from the plan.

Support

Representation ID: 7225

Received: 07/01/2024

Respondent: Mr Harold Dermott

Whilst the carbon costs of operating the building are addressed elsewhere in this Chapter, ignoring the embedded carbon is to ignore the major part of the problem.

It will, however, require major changes to the way buildings are constructed in the UK, with more precision control of construction, quite possibly by large sections of buildings being factory built where processes to control quality and specification are easy to achieve, rather than using
historic materials with high embodied carbon content built on site in highly variable weather conditions and using construction techniques which do not always result in consistently high quality products.

Support

Representation ID: 7281

Received: 08/01/2024

Respondent: Manor Oak Homes

Agent: Mr Andy Moffat

The proposed approach which does not set out prescriptive standards is supported.

Object

Representation ID: 7345

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

This policy is not clear how ‘favouring’ a building would be assessed or what this might mean in practice. Additionally, the policy does not acknowledge that repairing, refurbishing, re-using and re-purposing a building will not always result in less carbon use. It would be helpful if the policy could explain a methodology to assess the total embodied carbon consumption to consider whether this approach would actually use less carbon.

Object

Representation ID: 7539

Received: 08/01/2024

Respondent: House Builders Federation

HBF are unclear how a developer would show compliance with this policy, and whether the Council has the skills and expertise to undertake or critique embodied carbon assessments, especially as be qualified to make judgements on accepting or rejecting carbon assessments as the baseline and measures therein have not been established. HBF therefore view this policy as unnecessary, and it should be deleted.

Object

Representation ID: 7669

Received: 08/01/2024

Respondent: South Luffenham Parish Council

More prevalent to a barn conversion, where the existing structure is retained.

Support

Representation ID: 7731

Received: 08/01/2024

Respondent: Anglian Water

Anglian Water welcomes the policy CC5 on Embodied Carbon. We suggest that the first part of the policy should be in utilising embodied (capital) carbon in existing infrastructure to select the most sustainable locations for and quantum of growth. This may be best placed in the Spatial Strategy policies and should be referenced in the supporting text for CC5. As operational carbon is reduced through decarbonisation of the grid and transport electrification the embodied carbon in new construction and that saved by using existing infrastructure will be increasingly important on the path to net zero. Anglian Water is able to provide tCO2e figures for each of the spatial options which the Council wants to consider.

Object

Representation ID: 7772

Received: 08/01/2024

Respondent: McCarthy Stone

Agent: The Planning Bureau Limited

We would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). The introduction of an embodied carbon policy must not be so inflexible that it deems sites unviable and any future policy needs to ensure this to make sure it is consistent with NPPF/PPG and can be justified by the Council.
We note that the Rutland County Council Whole Plan Viability Assessment, August 2023, HDH (Viability Assessment) does not appear to include a cost for the embodied carbon policy. This is concerning as embodied carbon will have a cost that should be accounted for within any Viability Assessment.

Additionally, new development will often be far more sustainable in many circumstances including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site and more able to meet the council’s zero carbon aspirations. The Council also need to verify that embodied carbon figures are available to developers from suppliers through an Environmental Product Declaration as in our experience this is not yet readily available from the majority of suppliers.

Recommendation:
Ensure the policy is properly assessed within the Viability Assessment and that the requirement is realistic with data and evidence readily available to the development industry.

Support

Representation ID: 7786

Received: 08/01/2024

Respondent: Edith Weston Parish Council

We support policies that reduce carbon use, water efficiency and micro energy generation.

Support

Representation ID: 7822

Received: 07/01/2024

Respondent: CPRE Rutland

This is an important and welcome inclusion.

Support

Representation ID: 7875

Received: 08/01/2024

Respondent: Ryhall Parish Council

CC5 Embodied Carbon - Support

Support

Representation ID: 8016

Received: 08/01/2024

Respondent: Mr PJRS Hill and Pikerace Limited

Agent: Silver Fox Developments

We support the objectives if this policy.