Bedford Borough Council
Allocations and Designations DPD
Issues and Options Paper
INTRODUCTION AND CONTEXT
In 2007 the council signed the Nottingham Declaration on climate change reflecting
its commitment to reducing carbon emissions. It is also signed up to the 10:10
CORE STRATEGY AND RURAL ISSUES PLAN AND OTHER RELEVANT
Planning Policy Statement: Planning and Climate Change (Supplement to PPS1)
encourages planning authorities to set policies requiring a percentage of the energy
used in new development to come from decentralised, renewable or low-carbon
sources and encouraging sustainable buildings.
Amongst other matters, policy CP26 of the Core Strategy and Rural Issues Plan
seeks to minimise the consumption and use of energy from new buildings,
encourage sustainable construction and minimise the use of water. The Plan notes
that further policy will be developed as part of the Allocations and Designations Plan.
To support the preparation of the Allocations and Designations Plan, the council
commissioned consultants to assess the scope for more ambitious climate change
policy requirements. The results of this work are published in a background paper:
the Bedford Energy Potential Study, AECOM, 2010.
WHAT DID YOU SAY IN EARLIER CONSULTATIONS?
The Issues and Options paper consultation in 2008 noted that the scope of energyrelated
policies will be investigated in a background study and included in the
Allocations and Designations Plan. The study was not completed in time to be
included in the Draft Plan published for consultation in May 2010 which is why this
separate paper has been produced.
WHAT IS BEING PROPOSED?
Government guidance allows local authorities to require levels of building
sustainability in advance of those set nationally where local circumstances warrant.
These should be set in terms of national standards and cover various issues,
including water, waste and recycling, flood risk, pollution and security. Actions must
not only be taken to reduce the impacts of climate change by reducing carbon
emissions but also to adapt development to the effects of climate change and other
The Code for Sustainable Homes and Building Research Establishment
Environmental Assessment Method (BREEAM) consider the wider environmental
impact of a building and therefore can achieve more holistic results with regards to
delivering sustainable design and construction. Compliance with the required
standard can be easily demonstrated through achievement of certification. Both
systems are regularly updated to reflect changes in the industry and feedback from
developers and manufacturers. The methodology and quality assurance for the
achievement of the required rating is carried out by licensed assessors and the
Building Research Establishment. The methodology is publicly available and linked
to government approved software used to demonstrate Building Regulations
compliance. In order to demonstrate compliance, full pre-assessment certification
under the relevant scheme, accompanied by a signed letter of explanation from a
registered assessor would be required. Post-construction validation would also be
The Code for Sustainable Homes goes further than the current building regulations,
and is intended to help promote even higher standards of sustainable design. The
Code measures the sustainability of a new home against nine categories of
sustainable design, rating the 'whole home' as a complete package. The Code uses
a one to six star rating system to communicate the overall sustainability performance
of a new home against these nine categories. The Code sets minimum standards
for energy and water use at each level achieving carbon neutrality at level six. It is
recognised that zero carbon may be difficult to achieve on all sites and the
Government considers that flexibility could be introduced by allowing developers to
make payments to fund community energy projects. Domestic water consumption
in the East of England is currently about 130 – 160 litres per person per day.
Significant reductions can be achieved by installing low water use sanitary ware at
relatively little additional cost. However achieving the requirements of Code levels 5
and 6 is likely to require expensive grey water recycling systems.
The Government is committed to requiring all new homes to be zero carbon by 2016,
achieving this by staged reductions in carbon emissions requirements in the Building
Regulations. The most recent of these in October 2010, introduced a 25% reduction
in carbon emissions relative to the 2006 Building Regulations requirement. This
exceeds the minimum carbon reductions required at levels 1 – 3 of the Code for
Further information on sustainable design and construction can be found at
Code for Sustainable Homes
Code level Minimum percentage reduction
in dwelling emission rate over
target emission rate for CO2
Maximum indoor water
consumption in litres per person
1 - * 120
2 - * 120
3 - * 105
4 44 105
5 100 80
6 net zero carbon 80
Credits are additionally awarded for the following categories - materials, surface
water run-off, waste, pollution, heath and wellbeing, management, ecology.
* Building Regulations Part L 2010 introduced a 25% reduction in carbon emissions thus exceeding
the minimum requirement at lower levels of the Code
BREEAM rating Credits are awarded for the following categories
Energy, management, health and wellbeing, transport, water,
materials, waste, land use, pollution, ecology
OPTIONS FOR COMMENT
This option would expect new homes in the borough to achieve at least Code level 4.
The background paper notes that there is a significant increase in costs above this
level of the Code due to the need to restrict water use. Homes built with Homes and
Communities Agency funding are already expected to achieve Code level 4,
therefore the policy would ensure that all tenures will target the same standards.
The option would require non-domestic developments to achieve BREEAM “very
This option would expect new homes in the borough to achieve at least Code level 4,
but additionally to aim for carbon neutrality. This avoids the significant additional
costs associated with achieving higher levels of the Code while still achieving the
highest possible reduction in carbon emissions. It is recognised that it may not
always be feasible to achieve carbon neutrality on-site and so, in such cases,
developers would be required to contribute to a Carbon Offset Fund. This Fund
would be used by the council to facilitate off-site renewable energy schemes,
improvements to the existing housing stock to reduce carbon emissions and tree
planting, resulting in substantial benefits to the borough. The level of payment and
further guidance on achieving zero carbon would be set out in a supplementary
planning document. This option would require non-domestic developments to
achieve BREEAM “excellent” standard.
FOR ALL OPTIONS
A size threshold in terms of the number of dwellings or amount of non-residential
floorspace at which the policy applies would be set to ensure compliance with the
Core Strategy and Rural Issues Plan which states that the policy in the Allocations
and Designations Plan should relate to “local development or site specific
OTHER MAIN OPTIONS CONSIDERED
Rather than setting policies in this Plan, another option could be to rely on the
existing policy in the Core Strategy and Rural Issues Plan. This is not an acceptable
approach, as the Core Strategy and Rural Issues Plan itself refers to the need to set
more detailed policy in a later Plan and this approach is encouraged in national
An addendum to the sustainability appraisal of the Draft Plan has been produced for
this paper. For both Options CC1 and CC2 It shows the following effects on
sustainability of the options –
Mostly positive and major positive effects due to increased use of renewable energy
and construction of sustainable buildings. No negative effects.
1. Do you agree that using the Code for Sustainable Homes and
BREEAM is the best way to improve the sustainability of new
buildings? If not, what approach would you suggest?
2. Do you prefer:
a) Option CC1 (Code level 4 and BREEAM “very good”) – the
minimum improvement over existing requirements.
b) Option CC2 (Code level 4 plus zero carbon, Carbon Offset Fund
and BREEAM “excellent”) – the best improvement in terms of
cutting carbon emissions without increasing development costs
c) Some other alternative (please specify)?
Please explain your answer.
3. At what size thresholds should the policy apply?
a) 20 dwellings / 0.6 ha and 1000 sq m for non-domestic
b) 10 dwellings / 0.3 ha and 1000 sq m for non-domestic
c) 5 dwellings / 0.15 ha and 1000 sq m for non-domestic
d) Some other threshold (please specify).
Please explain your answer.
MONITORING AND DELIVERY
The council will monitor:
• New residential developments to ensure compliance with the Code for
Sustainable Homes by the use of planning conditions.
• New non-domestic developments to ensure compliance with the Building
Research Establishment Environmental Assessment Method (BREEAM) by the
use of planning conditions.
• If a policy threshold is set, the proportion of developments that do not have to
comply with the policy.
How to comment Comments can be returned by email, letter or fax as follows:
By post: Paul Rowland
Assistant Director Planning & Housing
Bedford Borough Council
By fax: 01234 325671
By email: firstname.lastname@example.org
Please note that all comments received will be made public.