Draft Sustainable Construction Supplementary Planning Document

1 Introduction

Context

East Suffolk Council's commitment to mitigating and adapting to climate change

1.1  East Suffolk Council has two Local Plans, the Suffolk Coastal Local Plan (2020) and Waveney Local Plan (2019). East Suffolk Council has a Strategic Plan (2020-2024) and one of the key themes of the Strategic Plan is ‘Caring for the Environment’. This includes minimising waste throughout the district, using renewable energy and using the Council’s influence to protect the natural environment to create a cleaner, quieter and healthier environment.

1.2 The vision for the Suffolk Coastal Local Plan area includes “healthy economy, healthy population and healthy environment” with a plan that will address climate change “issues relating to flood risk, coastal erosion and wider coastal management and adaptation, as well as ensuring that human impact is reduced and mitigated accordingly.” The vision for the Waveney Local Plan area includes a “stronger, more diverse economy benefiting from the growth of offshore renewable energy” with climate change emissions reducing as “people choose more sustainable methods to commute to work and for leisure purposes due to the district’s settlements becoming more self-sufficient” and more properties benefiting from flood protection and adapting to coastal change.

1.3 The two Local Plans have planned for sustainable growth that addresses the need for new homes and employment. The two Local Plans contain planning policies that support sustainable development, sustainable construction and contribute towards the mitigation of climate change and reduction in energy use. The two Local Plans also form part of the Council’s wider corporate ambition to mitigate the effects of climate change that are embedded in the strategic plan.

1.4 East Suffolk Council recognises we are in a climate emergency and is committed to supporting sustainable development, doing more to reduce its own carbon emissions, and to encourage and encourage communities to help fight climate change[1] .

1.5 East Suffolk Council unanimously voted on 24th July 2019 to declare a recognition of the climate emergency[2] . The Motion also pledged to set up a Cross Party Task Force and the Environmental Task Group was subsequently established in October 2019. The Group aims to investigate ways to cut East Suffolk Council’s greenhouse gas emissions, and reports on progress on this and other environmental initiatives to Cabinet on a quarterly basis. East Suffolk Council has pledged to work with Suffolk County Council and other partners across the county and region towards the making the county of Suffolk carbon neutral by 2030 (as set out in the Suffolk Climate Emergency Plan[3] ), to work with Government to deliver its 25 year Environmental Plan, and to also work with Government to increase the powers and resource available to local authorities in order to make the 2030 target easier to achieve[4] .

1.6 There is evidence that the gradual impacts of climate change are already being experienced in Suffolk. Suffolk can expect to experience increased summer droughts with crops requiring more irrigation, increased rainfall causing surface water flooding that disrupts travel, and increased storm events including tidal surges and coastal erosion. Climate change, particularly the impacts of flooding and coastal erosion pose a serious risk of damage to residential and non-residential properties and the operation of businesses.

1.7 It is well documented that climate change - particularly extreme temperatures and weather events - will affect the health of people, animals and aquatic and plant life. The impact may in some cases be as catastrophic to the built environment too. Floods and droughts will impact on habitats and availability of food for animals and ground conditions. Saltwater inundation from coasts and estuaries can also damage farmland. Floods, drought and saltwater inundation can seriously damage the important green (e.g. woodlands) and blue (e.g. rivers) infrastructure that human health, wellbeing and ways of life depend on.

1.8 Further information on climate change in Suffolk is available on the Green Suffolk website[5] .

What is Sustainable Construction?

1.9 ‘Sustainable construction’ is a part of ‘sustainable development’. ‘Sustainable development’ includes three overarching objectives as identified in the NPPF: development that is environmentally, economically and socially sustainable. Though all three objectives are of importance in achieving sustainable development, the Sustainable Construction policies of the Local Plans focus on delivering a more environmentally sustainable built environment for the district.

1.10 Reflecting the sustainable construction policies in the Local Plans, in this document, the term ‘sustainable construction’ therefore focuses largely on environmental sustainability, through construction methods, materials and technologies that provide developments which:

  • reduce demand and use of finite resources and which result in lower carbon emissions or are ‘zero carbon’.
  • avoid or reduce unnecessary harm to the natural environment and wildlife and which supports people’s good health and wellbeing; and
  • adapt the built environment to the impact of climate change through design.

1.11 ‘Sustainable construction’ in this document also means buildings that, through the quality of their design, are built to last a long time, including buildings that are flexible and adaptable.

Sustainable Construction in East Suffolk

1.12 Reducing contributions to climate change and mitigating the impact on the environment are strategic priorities in both the Suffolk Coastal Local Plan[6]  and Waveney Local Plan[7] . Whilst the planning system has a limited impact on existing buildings, a significant amount of new development is planned to come forward over the plan periods, including non-residential development, and therefore reducing the environmental impact of this development is important.

1.13 East Suffolk Council’s Strategic Plan 2020-2024[8]  aims to deliver the highest quality of life for everyone who lives, works and visits East Suffolk. It sets the Council’s corporate objectives of: growing our economy, enabling our communities, remaining financially sustainable, delivering digital transformation, and caring for our environment. The priorities set out under the ‘Caring for our Environment’ section include: to lead by example in shrinking our carbon footprint; increase our biodiversity sites; minimise waste; increase recycling and reuse of materials; invest in and support renewable energy; protect our natural environment; and educate and influence our communities to help us achieve a healthier environment for people and wildlife. The Council has also adopted a Housing Enabling Strategy[9]  in which sustainable housebuilding is a key strategy.

1.14 The Council is seeking to improve its own buildings and ensure new build housing stock contributes to the Council’s carbon neutral aims. The Council is also exploring new ways to encourage and invest in the use of renewable energy through the Council’s own consumption and support to residents and businesses.

1.15 An Environmental Guidance Note[10]  has been produced to offer clear, concise information on a range of key environmental issues relating to the building industry, assisting those seeking to mitigate the contribution of construction to climate change and its impact on the environment by offering support and advice. It was endorsed by the Council in November 2020. In addition, a Sustainable Business Toolkit[11]  was published in 2019 to help businesses reduce their environmental impact.

1.16 As part of the Suffolk Climate Change Partnership[12] , East Suffolk is helping businesses and residents to reduce their energy bills through free advice and improvement grants. The Suffolk Climate Change Partnership has published the Climate Emergency Plan for Suffolk, setting out how the public sector will work together with other stakeholders to support and guide our residents, communities and businesses to make the changes required to best set Suffolk on the path for carbon neutrality across its domestic, industrial, transport and energy sectors by 2030.

East Suffolk Council's Environmental Task Group

1.17 The Environmental Task Group was established as a cross party task group in October 2019 with the purpose of analysing the policies East Suffolk Council inherited from its predecessor’s Suffolk Coastal and Waveney district councils, to ensure policies are fit for purpose and identify areas for improvement. The Task Group is committed to ensuring that the environment informs all the Council’s decisions, choices, and policies.

1.18 The Environmental Task Group[13] meets quarterly and reports to Cabinet. Details of the work and membership of the Environmental Task Group are available to view on the website.

Greenprint Forum

1.19 The East Suffolk Greenprint Forum[14]  is a voluntary network facilitated by the Council which works to progress environmental issues in East Suffolk, open to anyone who wishes to join. Anyone, from the community, business, or public sectors, and individuals, can join for free and be involved in informing and learning from the group. The Greenprint Forum’s vision is of an East Suffolk where significant progress is made by 2030 towards each of its nine goals: includes improving and supporting active travel, eco-friendly development, energy generating homes, environmentally beneficial employment, putting nature first, pollution free environment, quality food and the upcycling culture. With particular regard to its goal of Eco-Friendly Development, the Greenprint Forum’s vision is for development that is designed to limit environmental harm, meets changing needs of occupants, copes with changes to the climate and feels part of the wider natural environment.

Purpose of the Sustainable Construction SPD

1.20 This Sustainable Construction Supplementary Planning Document (SPD) provides guidance to assist in the interpretation and implementation of planning policies contained in the Council’s two Local Plans; the Suffolk Coastal Local Plan, adopted in September 2020, and the Waveney Local Plan, adopted in March 2019.

1.21 This guidance includes information about how sustainable construction methods and materials used in new development can reduce the construction and operational impact on our environment, wildlife, climate change and health and wellbeing. It also provides guidance on how the operating efficiency of existing buildings can be improved through retrofitting. This document therefore focuses on providing guidance on increasing energy efficiency, water efficiency, the use of sustainable materials, renewable and low carbon energy generation, reducing waste and carbon emissions, nature-based solutions for sustainable drainage systems, designing for future challenges, and designing homes and workplaces that support good health.

1.22 The Sustainable Construction SPD will not set building standards. The energy efficiency of all new and renovated buildings for residential and non-residential use is covered by Building Regulations and all developers must build and renovate to current Building Regulation standards. The setting of Building Regulations is not within the control of the Council. Local Planning Authorities can, however, through planning policy in Local Plans, set energy performance standards for new housing that are higher than Building Regulations, but only up to the equivalent of Level 4 of the, now withdrawn, Code for Sustainable Homes (approximately 20% above current Building Regulations), as has been undertaken in the Suffolk Coastal Local Plan.

1.23 This SPD replaces the following Supplementary Planning Document and guidance:

  • Renewable Energy and Sustainable Construction (2013) (this relates to the former Waveney area)

1.24 This SPD includes best practice guidance on providing an adequate and complete evidence base for meeting the policy criteria of the key sustainable construction policies of the two Local Plans. As an SPD this document is a material consideration when determining planning applications. The SPD covers the whole of the administrative area of East Suffolk except that part lying within the Broads Authority Executive Area.

Preparation of the SPD

1.25 An initial consultation was held from 15th March to 26th April 2021 on the proposed scope and content of the Supplementary Planning Document. The consultation proposed the Sustainable Construction SPD would provide guidance on a range of topics including energy efficiency, renewable energy, water conservation, sustainable transport and use of materials, to support the implementation of the Local Plan policies. The consultation document sought views on the proposal through a questionnaire with 12 questions. We received 26 comments from 16 respondents. The comments received during the consultation have informed the content of this Draft Sustainable Construction SPD.

1.26 The draft SPD is supported by a Strategic Environmental Assessment, Habitats Regulations Assessment and an Equality Impact Assessment screening opinion.

National Climate Policy

1.27 The UK Government has been working to address climate change through a range of actions, some of the key strategies of which are listed below:

  • Climate Change Act (2008)
  • Signee of UN Paris Climate Change Agreement (2016)
  • Intergovernmental Panel on Climate Change Report (2018)
  • 25 Year Environment Plan (2018)
  • National Planning Policy Framework (2021)
  • Parliamentary Declaration of Climate Emergency (2019)
  • Energy White Paper: Powering our Net Zero Future (2020)[15]
  • The Ten Point Plan for a Green Industrial Revolution (2020)
  • The Future Homes Standard (expected 2022)

1.28 The Government aims to lead the way in tacking climate change globally with plans to reduce greenhouse gas emissions by 2030 by 68% compared to 1990 levels and achieving net zero by 2050[16] . Details on how to achieve the targets are set out The Ten Point Plan for a Green Industrial Revolution[17] . The plan focuses on £12 billion of government investment to create and support jobs in the following areas:

  1. advancing offshore wind
  2. driving the growth of low carbon hydrogen
  3. delivering new and advanced nuclear power
  4. accelerating the shift to zero emission vehicles
  5. green public transport, cycling and walking
  6. ‘jet zero’ and green ships
  7. greener buildings
  8. investing in carbon capture, usage and storage
  9. protecting our natural environment
  10. green finance and innovation”[18]

1.29 The planned development of greener buildings includes a target to install 600,000 heat pumps by 2028 and for homes built to the new Future Home Standard to be ‘zero carbon ready’ with 75-80% lower CO2 emission than current Building Regulation standards.

Planning Policy

1.30 The East Suffolk Council - Suffolk Coastal Local Plan and East Suffolk Council - Waveney Local Plan as well as ‘made’ Neighbourhood Plans and the Minerals and Waste Local Plan produced by Suffolk County Council, form the development plan for the district. The Suffolk Coastal Local Plan and Waveney Local Plan both highlight the importance of climate change issues in their vision and strategic priorities for their respective local plan areas. Each Local Plan has a chapter dedicated to Climate Change with planning policies that support and promote the uptake of decentralised renewable or low-carbon energy to assist in transitioning to a low carbon future.

1.31 The Local Plans contain several key planning policies to deliver sustainably constructed and well-designed buildings that minimise their impact on the environment. Neighbourhood Plans may also contain policies relating to sustainable construction.

1.32 The guidance in this SPD is also complementary to the Government's National Planning Policy Framework (NPPF) (2021) and Planning Practice Guidance to which the Council must have regard, as a material consideration, in reaching decisions on planning applications. Of particular significance are sections 2 and 14 of the NPPF. Section 2 of the NPPF is dedicated to achieving sustainable development and states that “the purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs (para.7).” Plans must be prepared with the objective of achieving sustainable development (para.16). Section 14 of the NPPF is focused on meeting the challenge of climate change, flooding and coastal change. The NPPF requires the planning system to support the transition to a low carbon future in a changing climate through a range a of measures (para.152). These include contributing to reductions in greenhouse gas emissions, reuse of existing resources and support for renewable and low carbon energy.

Local Planning Policy East Suffolk, Waveney Local Plan Local Planning Policy Suffolk Coastal Local Plan

Key Sustainable Construction Local Plan policy requirements

1.33 Suffolk Coastal Local Plan policy SCLP9.1 Low Carbon & Renewable Energy and Waveney Local Plan policy WLP8.27 Renewable and Low Carbon Energy are very similar policies that support new energy generation schemes. They both support Neighbourhood Plans in identifying suitable areas for renewable and low carbon energy development. The policies also support renewable and low carbon energy schemes in the Local Plan areas, with the exception of wind, subject to requirements such as no significant adverse impacts on the amenities of residential properties and businesses and technology being removed once decommissioned.

1.34 Suffolk Coastal Local Plan policy SCLP9.2 Sustainable Construction and Waveney Local Plan WLP8.28 Sustainable Construction seek through different approaches to mitigate the impact of construction on climate change through a comprehensive sustainable construction approach that includes higher water and energy efficiency standards.

1.35 Policy SCLP9.2 requires developments of more than 10 dwellings to achieve higher energy efficiency standards that result in a 20% reduction in CO2 emissions below the Target CO2 Emission Rate (TER) set out in the 2013 Building Regulations. The standard is derived from the energy requirements of Level 4 of the now withdrawn Code for Sustainable Homes. The TER is defined by Building Regulations as the minimum energy performance requirement for a new dwelling and relates to CO2 emissions from the provision of space heating, hot water, mechanical ventilation and lighting. The Suffolk Coastal Local Plan states the requirement for the submission of an interim compliance report prior to development commencement, and a final compliance report must be submitted upon development completion for residential development.

1.36 Policy WLP8.28 requires new developments of 10 or more dwellings and commercial developments of 1,000sqm or more floorspace to submit a sustainability statement. The areas to be addressed in the statement include improved efficiency of heating, cooling and lighting, maximising daylight and passive solar gains, and renewable and low carbon energy generation. Policy WLP8.28 was developed and adopted prior to the Planning Practice Guidance permitting planning policy to set energy performance standards higher than building regulations, up to the equivalent of Level 4 of the Code for Sustainable Homes.

1.37 Policy SCLP9.2 and WLP8.28 require some developments to use the British Research Establishment Environmental Assessment Method (BREEAM) to achieve higher performing buildings. Policy SCLP9.2 requires all new non-residential developments of 1,000sqm or more, and policy WLP8.28 requires all new office and school developments of 1,000sqm or more to achieve the BREEAM ‘Very Good’ standard or equivalent.

1.38 Table 1 below sets out key specific policy requirements of the Local Plans. However, there are other elements of the Local Plan policies that relate to sustainable construction, and these are also addressed in the topic based guidance chapters.

Table 1:  Summary of key climate change requirements for applications in the Suffolk Coastal Local Plan

Topic 

Requirement 

Evidence Required 

Further advice 

Water efficiency & management  

 

SCLP9.2 

All new residential developments should achieve 110 litre/person/day. 

Confirm water efficiency standard in a Water Statement (can be incorporated into an Energy Statement, Sustainability Statement or Sustainable Drainage Strategy) 

Chapter 2 

SCLP9.7 

All developments to demonstrate water can be made available to support the development. 

All new developments expected to incorporate water efficiency and re-use measures. 

Confirm water availability and use of water efficiency and re-use measures in a Water Statement (can be incorporated into an Energy Statement, Sustainability Statement or Sustainable Drainage Strategy) 

Chapter 2 

Sustainable Drainage Systems 

SCLP9.6 

Developments of 10 dwellings or more, or non-residential development with 1,000sqm+, or site of 1 hectare or more required to utilise sustainable drainage systems. 

Sustainable Drainage Strategy 

Chapter 2

Energy efficiency and carbon reduction 

SCLP9.2 

All new residential developments of more than 10 to achieve a 20% reduction in CO2 emissions below Target CO2 Emission Rate (TER) in Building Regulations. 

Energy Statement by Energy Compliance Specialist or equivalent 

Chapter 3  

Construction Standards 

SCLP9.2 

All new non-residential development of 1,000sqm + to achieve BREEAM "Very Good" standard or equivalent. 

BREEAM Post construction stage certification (secured through planning condition). 

Chapter 3 and 10

Sustainable Design 

SCLP9.2 

Proposals should achieve efficiency of heating, cooling and lighting of buildings by maximising daylight and passive solar gain through building orientation. 

Energy Statement  

Chapter 6 

Table 2: Summary of climate change requirements for applications in the Waveney Local Plan

Topic 

Requirement 

Evidence Required 

Further advice 

Water efficiency & management  

WLP8.28 

All new residential developments should achieve 110 litre/person/day. 

Confirm water efficiency standard in a Water Statement (can be incorporated into an Energy Statement, Sustainability Statement or Sustainable Drainage Strategy) 

Chapter 2 

Sustainable Drainage Systems 

WLP8.24 

Developments should use sustainable drainage systems to drain surface water. 

No surface water connections to foul systems and connections 

Sustainable Drainage Strategy 

 Chapter 2 

Construction Standards 

WLP8.28 

All new office and school developments of 1,000sqm+ are required to achieve BREEAM 'Very Good' standard. 

BREEAM Post construction stage certification (secured through planning condition). 

Chapter 3 and 10

Sustainable Design 

WLP8.28 

Residential developments of 10 or more and commercial schemes of 1,000sqm or more should demonstrate sustainability. 

Sustainability Statement. 

Chapter 3 

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