16. Change the framing of this topic from ‘Energy Efficiency’ to ‘Energy Demand Reduction’.

Efficient energy-use is important in reducing carbon emissions. But it is only one part of a much bigger question about the overall demand for energy created by any given building. The feature of any building that is most difficult to change is its location - and yet this has one of the greatest impacts on its energy demand because of transport requirements it may have (and the disproportionate carbon emissions generated by private car use).

In addition, the building process itself makes substantial energy demands, through the manufacture and transport of materials and the machinery required to build (a significant proportion of any building’s total carbon emissions). And then its ongoing use - particularly in heating it - demands energy, which can be reduced through efficient design and supply. Therefore, considering the energy efficiency of a building in isolation fails to address the broader problem which is total energy demand.

 

17. The Energy Hierarchy should consider location the primary factor for new developments, not just the individual standards of buildings themselves.

The Energy Hierarchy would better reflect climate emissions if location - and the transport requirements produced by location - were top of the hierarchy. Note, this doesn’t need to lead to default urbanisation, but preventing it does require rural and semi-rural locations to have better public transport infrastructure and local services provision.

 

18. All new build and refurbishment should include mainly or only low carbon and local materials to reduce the embedded carbon during the build process.

This is something that would also benefit from being reflected in the Local Industrial Strategy.

 

19. The DPD needs to link building standards to the actual build process for new build and refurbishments. The “as built” standard must meet planning conditions standards, particularly on air tightness, insulation & the installation of suitable heating systems and their controls.

We suggest that local stakeholders are more involved in the process of decision-making on how to quickly get to net-zero carbon for all new buildings. In particular, on how to prioritise low CO2e and local materials for builds. In the absence of effective Building Control, stakeholder buy-in is especially important.

 

20. Conservation Areas and Listed Buildings issues must be addressed on how to improve the building fabric and energy systems to move these buildings more rapidly to low carbon.

 

21. All new buildings need to be zero carbon in operation.

A clear and progressive weighting of energy and carbon reduction approaches, from demand reduction all the way down to offsetting, would, for example, allow on-site generation capacity to receive 50% of the carbon credit of demand reduction measures, while carbon offsetting measures would only receive 25%. This would incentivise builders and developers to adopt progressive approaches, and would be straightforward for the planning regime to implement.

 

22. The new Cornwall Design Guides would be improved with more information and guidance on low carbon and local materials to reduce the carbon cost of new build and refurbishment.