Carbon Footprint

there are typos in this section.
"In reduce embodied carbon development..."
"Figure 4 - Reducing embodies carbon"

On behalf of Bloor Homes Ltd, please consider this representation in response to the consultation on
the North Herts Council draft Sustainability SPD.

Broadly, Bloor Homes supports the SPD and welcomes the document as supporting guidance to supplement the relevant adopted Local Plan policies and National policies, and the text in the Introduction section sets the scope and status of the SPD out clearly and is supported.

Regarding how the SPD could be used and applied, for Major Residential developments we recommend that Option B Self-Assessment checklist is the most appropriate option as the applicant will have all the
necessary technical information to complete the checklist and can signpost where amongst the application documents the supporting information can be found and checked.

In Section 2 Objectives within the Carbon Footprint section on page 19, there are a couple of instances of definitive requirements where ‘should’ and ‘will require’ are used, which are not considered appropriate, given the acknowledgement in Section 1 that the SPD cannot go beyond adopted policy or impose unnecessary financial burdens on development. These requirements should be amended to use language used elsewhere in the section, such as ‘encouraged’.

Similarly, later in Section 2 under ‘Land use & wildlife’ on page 23, the phrase ‘Proposals should avoid habitat loss’ is used which is again too definitive and on many allocated sites some degree of habitat loss is unavoidable (e.g. farmland is a habitat for certain species whose loss cannot be avoided when developing a site). The phrase would be more appropriately worded as ‘seek to avoid’.

A minor point, but in the Checklist table on page 28 and again in the checklist on page 80, ‘Complimentary’ should be replaced by ‘Complementary’ in relation to the 12m habitat buffers.

Thereafter, the Technical and General Guidance presented in Section 3 is supported and provides a
useful overview.

In relation to the Checklists presented in the Appendices, and in particular at Appendix A in relation to
Major Residential Application, we have a few comments for consideration as follows.

Firstly we suggest that consideration is given to allowing schemes to achieve the higher Silver and Gold standards where a limited number of criteria are not feasible or viable on particular schemes at the discretion of officers. This is similar to the approach taken in certification schemes such as the Code for Sustainable Homes or BREEAM whereby it is not necessarily mandatory to achieve all the
requirements to achieve an overall level or grade. This suggestion is to allow for schemes where sustainability measures have been proactively provided across most criteria, but for site-specific reasons not all of them can be achieved, but the application can nonetheless achieve a higher level.

Secondly, in some instances the criteria are perhaps too vague or imprecise to provide the clarity that Applicants or Officers may require. For example, ’20% renewable energy’ does not indicate the benchmark; ‘significant proportion of reclaimed materials’ does not indicate a percentage or range. It is suggested that some of these criteria are made clearer or more precise.

We trust that this representation and the suggestions herein are useful in informing revisions to the draft
and look forward to reviewing the final version.

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