Thank you to the 187 of you who added your names to the petition we wrote to Don Foster on 30th May 2014 to ask him to support the amendment to the Deregulation Bill which would allow B&NES council to continue to specify higher sustainability standards for new house building in Bath. We also wrote a letter of support to Paul Crossley, leader of B&NES council and David Martin, councillor and the council’s climate change champion.
Don Foster replied almost immediately with a slightly cagey response which stated although he was supported of higher sustainability standards in new homes, and that in his previous and current ministerial roles he was continuing to push for these higher standards, the coalition government was seeking to remove a “myriad of local government standards” and that as a minister he couldn’t directly support our cause.
Since the petition, as part of the Queens Speech on Wednesday 4th June 2014 details of the proposed 2016 Zero Carbon Housing standard have been announced. The standard will be included in the Infrastructure Bill which should be signed off before the next election. A summary of the standard is attached to the bottom of this post, essentially it would deliver Code for Sustainable Homes level 4 housing with an additional carbon offset (Allowable Solutions). We will analyse how far off ‘Zero Carbon’ this proposed standard is in a subsequent post on the Transition Bath website.
Unfortunately the Infrastructure Bill appears to nullify the amendment in the Deregulation Bill, which is contingent on the Secretary of State laying his plans before parliament, which the Infrastructure Bill appears to do. We have now written to the 4 Labour MPs who are supporting the amendment to ask them to change the wording so it allows some transitional arrangements until the ‘Zero Carbon Standard’ as proposed by the Infrastructure Bill comes into force.
We have not had a response from the council to date, and we have no knowledge of the negotiations which might be taking place between the council and the Planning Inspector over the wording of the Core Strategy?
The petition to Don Foster and the letter to the council are provided below. We will try to keep you posted and if you have any questions or comments you can contact us at firstname.lastname@example.org.
Petition to Don Foster
As you are probably aware the Deregulation Bill 2013/2014 is currently passing through Parliament. Transition Bath and B&NES council would like to see all new homes in Bath constructed to standards of energy conservation higher than those required by minimum building regulations. An amendment tabled to the Deregulation Bill on April 2nd would continue to allow B&NES council to specify higher standards until the government makes clear its 2016 Zero Carbon Homes strategy. We are asking you to support this amendment as we are concerned that if it is rejected most of the 12,700 homes to be built in Bath over the next 15 years will cost more to run, be less comfortable and waste more carbon.
Our reasons for supporting this amendment and more sustainable housing are:
- Current land values for greenfield sites in Bath have averaged £2.5million/hectare recently, 100 times the agricultural value; building to higher standards would only reduce this by 7% to £2.35million/hectare which will have no impact on the volume of land being made available for housing – one of the government’s main arguments for removing council’s abilities to specify higher standards. Our research shows that homes built to higher standards would not cost more and would be easier to sell
- Housing built to higher standards would reduce energy costs by between 40% and 80% over current building regulations, reduce carbon emissions by 55% and in total might reduce the carbon emissions of the 12,700 homes to be built by up to 27,000 tonnes per year. These homes would be more resilient to future energy price shocks and reduce fuel poverty.
- In a recent Bath survey more than 98% of respondents supported B&NES’s council’s position on requiring more sustainably constructed homes contrary to the coalition government’s position in the Deregulation Bill
- Although we support the proposed 2016 Zero Carbon Building standard we are concerned it will be delivered late (2019 or later) and in a watered down form – using under-funded Allowable Solution carbon offsets, by which time the planning permissions for the majority of the 12,700 would be approved to lower standards
- Transition Bath’s volunteers donate their time to support other residents in reducing their energy costs through projects like Bath Green Homes and our Thermal Imaging Project. It would be a significant step backwards for us if the amendment were defeated and the majority of the 12,700 homes to be built in Bath were built were to minimum standards, requiring us to visit these homes in future to provide advice.
Please can we rely on your support for the amendment to the Deregulation Bill thus allowing B&NES council to continue to specify higher sustainability standards? We would be very happy to meet with you if you need any clarification of any of the points made.
On behalf of Transition Bath Energy Group and supported by a petition of 185 residents of Bath:
<list of signatures>
Letter of support to Paul Crossley, Leader of B&NES Council and David Martin, member champion for climate change
As you know Transition Bath and B&NES council would like to see all new homes in Bath constructed to standards of energy conservation higher than those required by minimum building regulations. These would be more comfortable, have lower energy consumption and waste less carbon.
The Government through the Housing Standards Review and the Deregulation Bill are trying to make it impossible for Local Authorities to specify higher standards and instead rely solely on minimum building regulations. There is however an amendment tabled to the Deregulation Bill on April 2nd which would allow councils to specify higher standards until the Government makes more concrete announcements on its Zero Carbon Housing Standards. In support of this amendment Transition Bath has raised a petition (attached) to Don Foster to ask him to support the amendment. The Bill is currently awaiting day two of its reporting stage at which time the amendment will be discussed. We think this may happen soon after June 4th when parliament returns and it will not be clear until then whether the amendment will pass.
We would therefore like to raise a number of points to contribute to your current Core Strategy negotiations with Simon Emerson, the Planning Inspector:
- We think that Mr Emerson would exceed his remit if he were to strike out the council’s Code for Sustainable Homes (CfSH) requirements before the amendment is voted on;
- We were shocked that Mr Emerson on April 9th, during the Core Strategy Sustainable Construction Hearing was unaware of the amendment;
- Given that the Deregulation Bill has not been passed we believe there is only one of two choices that can possibly be made:
- Delay the Core Strategy release until after day two of the reporting stage of the bill when there will be some clarity on the final wording of the Bill or
- Provide some flexible wording which would allow the council to specify the Code for Sustainable Homes (CfSH) level 5 should the amendment be passed, while staying within Government regulations.
- Code for Sustainable Homes level 5 is compelling and viable in Bath largely because of the high house prices. Our research suggests that with recent land sales – averaging £2.5million/hectare, specifying CfSH 5, would reduce land prices by £175,000/hectare to £2.325million/hectare. This is still 100 times the agricultural value, and not low enough to stop land coming forward and hence house building taking place. This is explained in more detail here.
Overall the impact of not being able to impose CfSH 5 is significant, up to the equivalent of 27,000 tonnes of carbon per year – or 10 large wind turbines. Individual homes will see a 55% reduction in carbon and up to an 80% reduction in energy bills if built to CfSH 5 rather than minimum Building Regulations.
In supporting the Council in its negotiations with Mr Emerson, we believe that if the Deregulation Bill amendment is passed the best possible wording within the Core Strategy would be that B&NES requires CfSH 5 where viable, until “the Secretary of State has laid a Zero-Carbon Housing Strategy before both Houses of Parliament” as required by the amendment.
Can we suggest you forward this letter of support to your fellow councillors and to your executive officers in the Planning and Sustainability Departments who are currently negotiating with Simon Emerson. It may also be to the Council’s advantage to discuss this issue with both Don Foster and his potential replacement Steve Bradley – as it will have an impact on Bath for many years to come.
In a recent Bath survey more than 98% of respondents supported B&NES’s council’s position on requiring more sustainably constructed homes, contrary to the coalition government’s position in the Deregulation Bill – we hope this helps support your case.
With kind regards,
on behalf of Transition Bath Energy Group
and supported by a petition of 185 residents of Bath:
<list of signatures>
Summary of Infrastructure Bill (Zero Carbon Homes)
“The government is committed to implementing a zero carbon standard for new homes from 2016. But it is not always technically feasible or cost effective for house builders to mitigate all emissions on-site.
The government would set a minimum energy performance standard through the building regulations. The remainder of the zero carbon target can be met through cost effective off-site carbon abatement measures – known as ‘allowable solutions’. These provide an optional, cost-effective and flexible means for house builders to meet the zero carbon homes standard, as an alternative to increased on-site energy efficiency measures or renewable energy (such as solar panels). Small sites, which are most commonly developed by small scale house builders, will be exempt. The definition of a small site will be consulted on shortly, and set out in regulation.
The Zero Carbon Home standard will be set at Level 5 of the Code for Sustainable Homes, but the legislation will allow developers to build to Level 4 as long as they offset through the allowable solutions scheme to achieve Code 5.
Energy efficiency requirements for homes are set in the Building Regulations 2010 and are made under powers in the Building Act 1984. But there are insufficient powers in the Building Act to introduce off-site allowable solutions, so the government will now bring forward enabling powers for this.“