Draft Development Contributions SPD - September 2022
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Draft Development Contributions SPD - September 2022
1 INTRODUCTION
Representation ID: 10251
Received: 01/11/2022
Respondent: Mr Roger Lovegrove
I call on the council to specifically call for no mains gas to be enabled in the large new estates in this SPD. The Council have declared a climate emergency, gas prices have risen significantly, alternative heating methods are available and building to Passivhaus or LETI standards makes gas unnecessary.
Stating categorically that gas will not be enabled provides a powerful lever which will force developers to take insulation and draught proofing seriously and force modernisation of common practices.
Hiding behind out of date Building Regulations is no longer acceptable. As little as 3 kilowatts of heating energy is required if these more modern standards (eg Passivhaus or LETI (London Energy Transformation Initiative)) are adopted but developers can achieve a nominal ‘zero carbon’ specification while still requiring 10 to 15 kilowatt gas boilers.
It is supposed to be government policy by 2025 for new builds but there is no reason why a no gas policy cannot be adopted sooner.
The extra cost of achieving Passivhaus or LETI standards is in the region of £8k to £14k (according to LETI in 2019) but this price differential must be significantly reduced as energy prices have risen.
I have trawled through, and word searched the latest version of the SPD and can find no mention of ‘gas’ or ‘central heating’. Ditto the ‘Herts Renewable & Low Carbon Energy Technical Study’ which is referenced in the SPD (Section 8.10) and is now 12 years out of date. I conclude that although the ‘Study’ calls for Zero carbon by 2016 on new builds the exact meaning of zero carbon is ill defined.
There is the danger that on builds authorised before 2025 gas boilers will still be required and ultimately will need expensive retrofits to heat pumps etc in 2035 when gas is totally banned for domestic heating.
The associated document, ‘Strategic Environmental Assessment Screening Determination Statement for North Hertfordshire District Council Developer Contributions Supplementary Planning Document, states in Table 1 C: The SPD is highly relevant in terms of promoting sustainable development as it seeks to ensure the effective and consistent implementation of developer contributions policy. Surely this opens the door to justifying the banning of gas in the larger estates?
The SPD calls for high speed data highways in these new estates. On the same basis mains gas could be forbidden.
There is now no excuse for not banning gas in new builds – please get it written into the SPD!
I call on the council to specifically call for no mains gas to be enabled in the large new estates in this SPD. The Council have declared a climate emergency, gas prices have risen significantly, alternative heating methods are available and building to Passivhaus or LETI standards makes gas unnecessary.
Stating categorically that gas will not be enabled provides a powerful lever which will force developers to take insulation and draught proofing seriously and force modernisation of common practices.
Hiding behind out of date Building Regulations is no longer acceptable. As little as 3 kilowatts of heating energy is required if these more modern standards (eg Passivhaus or LETI (London Energy Transformation Initiative)) are adopted but developers can achieve a nominal ‘zero carbon’ specification while still requiring 10 to 15 kilowatt gas boilers.
It is supposed to be government policy by 2025 for new builds but there is no reason why a no gas policy cannot be adopted sooner.
The extra cost of achieving Passivhaus or LETI standards is in the region of £8k to £14k (according to LETI in 2019) but this price differential must be significantly reduced as energy prices have risen.
I have trawled through, and word searched the latest version of the SPD and can find no mention of ‘gas’ or ‘central heating’. Ditto the ‘Herts Renewable & Low Carbon Energy Technical Study’ which is referenced in the SPD (Section 8.10) and is now 12 years out of date. I conclude that although the ‘Study’ calls for Zero carbon by 2016 on new builds the exact meaning of zero carbon is ill defined.
There is the danger that on builds authorised before 2025 gas boilers will still be required and ultimately will need expensive retrofits to heat pumps etc in 2035 when gas is totally banned for domestic heating.
The associated document, ‘Strategic Environmental Assessment Screening Determination Statement for North Hertfordshire District Council Developer Contributions Supplementary Planning Document, states in Table 1 C: The SPD is highly relevant in terms of promoting sustainable development as it seeks to ensure the effective and consistent implementation of developer contributions policy. Surely this opens the door to justifying the banning of gas in the larger estates?
The SPD calls for high speed data highways in these new estates. On the same basis mains gas could be forbidden.
There is now no excuse for not banning gas in new builds – please get it written into the SPD!
