{"id":156,"date":"2019-08-18T14:29:42","date_gmt":"2019-08-18T13:29:42","guid":{"rendered":"http:\/\/bishopsstortfordclimategroup.org\/?page_id=156"},"modified":"2020-01-10T18:42:57","modified_gmt":"2020-01-10T18:42:57","slug":"gilston-garden-town","status":"publish","type":"page","link":"https:\/\/bishopsstortfordclimategroup.org\/index.php\/gilston-garden-town\/","title":{"rendered":"Gilston Garden Town"},"content":{"rendered":"\n

Our response to the outline planning application 3\/19\/1045\/OUT <\/h3>\n\n\n\n
\"\"<\/figure>\n\n\n\n

“We consider the Council needs to refuse outline planning permission to Places for People in relation to their outline plans for the Gilston Estate as it does not meet EHDC\u2019s recent climate change motion: to do everything within the authority\u2019s power to reduce its impact on the climate and moreover do everything we can in supporting the whole of East Herts District to become carbon neutral by 2030. <\/p>\n\n\n\n

We have demonstrated to the Council that they can and should\nrequire developers to deliver developments which in use are from the outset net\nzero carbon. The detail of this is set out in the draft Supplementary Planning Document\nwhich we have provided to Councillors and the Head of Planning. <\/p>\n\n\n\n

In this application for Gilston, the developer has included\nan Environment Statement which in chapter 20 suggests that on a whole life cost\nbasis the development\u2019s carbon emissions in use and the carbon emissions\nembodied in the buildings on the site would be \u201ccarbon neutral\u201d after 51 years\ndue to the carbon sink across the development and the rest of the site. The\nwhole life approach to carbon emissions assessment in the Environmental\nStatement (ES) is an interesting development, going beyond the approach we have\nproposed in the SPD. But we consider it to be flawed, as set out in the\nAppendix below.  Even on its own terms we\nassume the developer is arguing that it will have achieved carbon neutrality in\n2071 \u2013 certainly not by EHDC\u2019s target date of 2030! <\/p>\n\n\n\n

In direct comparison with the net carbon zero approach we\nadvocate, the outline planning application proposes to achieve 19% less CO2\nemissions than the baseline level that would be achieved by full compliance\nwith the Building Regulations, equivalent to meeting the carbon emission\nrequirements of the abandoned Code for Sustainable Homes Level 4 rating. The\nEnvironment Statement calculates that this equates to residual emissions of some\n9,459 tonnes of CO2 per year. This is the cost of not taking further action to\nreduce the buildings\u2019 emissions to zero. <\/p>\n\n\n\n

The embodied carbon emissions in the development are the\ncarbon emissions associated with the building materials and methods used in construction.\nIn the Environment Strategy the academic author notes that the building industry\nhas committed to reduce embodied carbon, as measured by carbon intensity of the\nbuildings, by 48% by 2030. She identifies many opportunities for this in Table\n20.13. The Gilston developer is committed in its Sustainable Development\nStrategy to  \u201cwork towards eliminating\navoidable waste in construction and design, and support moves towards a\ncircular economy\u201d but this does not include a measurable commitment to reducing\nthe carbon intensity of the buildings for the site.  <\/p>\n\n\n\n

The developer\u2019s water efficiency proposals are not\nambitious, set at 110 litres\/person\/day, despite noting the importance of this\nin an area of water stress. Water use is not only important to avoid adding too\nmuch more stress to the aquifer, but also because of the energy used in the\nwater processing and distribution system. The now archived Code for Sustainable\nHomes considered it possible to design homes to achieve 105 or even 80\nlitres\/person\/day. Southern Water, Waterwise and the Environment Agency support\na target of 100 litres per person per day by 2040. Although this is not a\nrequirement, the failure to aim for this shows little commitment to\nsustainability. <\/p>\n\n\n\n

The outline planning application envisages achieving its\ntarget of 19% less CO2 than the baseline, by building homes to high energy\nefficiency standards and using solar PV or solar water heating. It envisages\neach home having a gas boiler for space heating, because the energy efficiency\nexpectations are not sufficient to rule out the need for heating. This\ncontrasts with Passiv Haus standards which reduce heating requirements to such\na level that gas heating systems are not required. <\/p>\n\n\n\n

The energy strategy rules out district heating on grounds\nthat the amount of heating required across the site is insufficient to make it\ncommercial. It is not clear whether this analysis is based solely on domestic\nheat requirements and whether it has factored in other heat\/cooling\nrequirements from commercial buildings which could alter the calculations. It\nis also not clear whether it considered the potential for the heat system to be\nused by existing buildings\/businesses in the adjacent area and whether it could\ndraw on heat from existing industrial or renewable sources nearby. The District\nHeating assessment appears to have been based on gas combined heat and power\nand savings calculated over 20 years, with relatively low grid factors in the\ncalculation. It appears not to have taken into account the Government HNIP\nfunding for heat networks which is now available (and wasn\u2019t available in\n2016\/7 when we believe the heat networks analysis was undertaken). The HNIP\nfunding is designed to increase the viability of heat networks to achieve the\nIRR\/hurdle rate to make them viable. <\/p>\n\n\n\n

The timing for the build out of Gilston Estate is over 20\nyears to around 2040 and its future proofing approach is that the developer\npromises to use its reasonable endeavours to adopt new best practice as it\nemerges. The Government has made a commitment that from 2025 at the latest, no\nnew homes should be connected to the gas grid. The planning documents for\nGilston note that the energy requirements in the Building Regulations are currently\nunder review and suggest that the proposed energy strategy is designed to be\nflexible, allowing the developers to use their \u201creasonable endeavours\u201d to\nconsider and introduce alternative technology for later phases.  EHDC should future proof its current planning\napprovals by not building in new extensions of the gas grid in advance of gas\nno longer being allowed \u2013 this would save developers\u2019 costs; and should ensure\nit is not only relying on the developers\u2019 \u201creasonable endeavours\u201d to use the best\navailable technology.\u201d
<\/p>\n\n\n\n

Technical comments on\nthe Environmental Statement, volume 1, chapter 20<\/strong><\/h3>\n\n\n\n

Summary<\/p>\n\n\n\n

The whole life approach to carbon emissions assessment in\nthe Environmental Statement (ES) is an interesting development and, in\nprinciple, appears a good way to proceed. But the Environment Statement does\nnot give full transparency to the calculations involved, includes implausible\nand unsubstantiated numbers and does not give proper consideration to the\nopportunity cost of losing the sink capability from the land in alternative use\nto agriculture.<\/p>\n\n\n\n

20.1.5\/20.3<\/p>\n\n\n\n

The whole life approach to carbon emissions assessment in\nthe Environmental Statement (ES) is an interesting development and, in\nprinciple, appears a good way to proceed. It is stated that this assessment\napproach has been used for other major regeneration schemes within the UK but is\nonly currently undergoing verification at the Carbon Trust. So, we assume that\nas of now it has no external validation.<\/p>\n\n\n\n

20.3.15<\/p>\n\n\n\n

Carbon sink<\/p>\n\n\n\n

There is a fundamental issue with the distinction here\nbetween a carbon sink and carbon sequestration. The quoted paper Edmonson\n(2014) discusses soil organic content (SOC) at the time of measurement and does\nnot make any suggestion that the SOC figures can be scaled to increase with\ntime. There is no mention of a study period of 25 years. Furthermore, it seems\nreasonable to assume that the SOC for the many woodland areas within the\nGilston development area would have reached close to a steady-state condition\nas they are described as Ancient Semi-Natural Woodland (ASNW) in the comments\non this application submitted by the Woodland Trust. This steady-state\ncondition for woodland carbon sequestration is illustrated in the Natural\nEngland (2012) report Figure 1, cited as ES reference 33. The scaling of SOC\nfor 60 years mentioned in 20.3.15 therefore appears invalid for many of the\nexisting landscapes.<\/p>\n\n\n\n

Carbon sequestration<\/p>\n\n\n\n

This is treated as a separate process from the carbon sink,\nbut it is unclear where the sequestered carbon finally becomes captured. If the\nsequestered carbon is not stored within the carbon sink then it is unclear\nwhether it remains captured or is subsequently released. It seems reasonable to\nassume that the rate of increase of carbon in the carbon sink cannot be greater\nthan the rate at which it is sequestered from the atmosphere through\nphotosynthesis.<\/p>\n\n\n\n

20.3.32<\/p>\n\n\n\n

The ES proposes an embodied carbon intensity of 781 kg CO\u00ad2<\/sub>\/m2<\/sup>\nfor 50% of the floor area and 405 kg CO\u00ad2<\/sub>\/m2<\/sup> for the\nremaining 50%. The first figure appears reasonable and matches with the data\nquoted in the 2018 Taylor Wimpey Sustainability report[1]<\/a>,\nalthough the Taylor Wimpey figures already include a proportion of timber-frame\nbuild. <\/p>\n\n\n\n

The second figure for timber-frame buildings of 405 kg CO\u00ad2<\/sub>\/m2<\/sup>\nhas been taken from ES reference 30[2]<\/a>\nand applies to a \u2018novel low energy house\u2019. This is a research proposal, and so\nit is unclear how this relates to timber-frame building designs of real-life\ndevelopments. The paper[3]<\/a>\nclaims that the novel construction method achieves a 34% reduction relative to\nconventional buildings, rather than the 48% (405 vs. 781) implied by the ES. A\nkey difference is that the figure of 405 kg CO\u00ad2<\/sub>\/m2<\/sup> in\nthe research paper does not include scope 3 emissions. <\/p>\n\n\n\n

The ES has therefore not provided plausible evidence that\nthe reduced figure of 405 kg CO\u00ad2<\/sub>\/m2<\/sup>is valid,\nor that it is achievable within the timescales proposed. There is certainly no\ncommitment within the outline planning application to deliver it.<\/p>\n\n\n\n

20.3.42<\/p>\n\n\n\n

Appendix 20.2 is cited as quoting numbers of dwellings for\nuse in the carbon assessment. This appears to be the lower table on page 129 of\nthe ES volume 3 file[4]<\/a>.\nThe table provides numbers of each type of dwelling, but the meaning of further\ncolumns labelled \u2018Dwelling\u2019, \u2018Quantum\u2019 and TER and DER is unclear. These values\nhave no units and there is no explanation as to the method used to combine\nthese figures to derive the total TER used later in the ES. <\/p>\n\n\n\n

20.3.44<\/p>\n\n\n\n

The requirement for a 48% reduction in carbon emissions due\nto construction by 2030 is claimed to be met by the adoption of timber-frame\nbuild, using the lower figure of 405 kg CO\u00ad2<\/sub>\/m2<\/sup> as\ndiscussed above. This would imply that 100% of the construction by 2030 can\nachieve this lower figure. However, the Taylor Wimpey 2018 Sustainability\nreport claims that currently only 10% of buildings use timber-frame and they\nwould \u2018aim for 20% by 2020\u2019. It therefore seems improbable that 100% the target\nwould be met by 2030. Notably, the Housing Statement provided with the\napplication makes no mention that 50% of the buildings would have a novel\ntimber-frame construction.<\/p>\n\n\n\n

20.4.3<\/p>\n\n\n\n

This section quantifies the existing carbon sink of the site\nin Table 20-9. The table includes soil carbon \u2018metrics\u2019 which have no units and\nno reference. The ES does include reference 31 which provides, for example,\nsoil carbon for arable land of 120 tC\/ha. It is unclear how this could be\nconverted to derive the \u2018metric\u2019 for arable land of 26.69. In order to\ncalculate the total carbon sink in the third column, it would also be necessary\nto know the area of each land-use type. This is listed on p129 of Appendix\n20.2, but again, there is no explanation of how the total carbon sink for each\nland-use type is calculated. <\/p>\n\n\n\n

20.4.4<\/p>\n\n\n\n

This section calculates the annual carbon sequestration.\nAgain, the values in Table 20-10 have no reference, and there are no figures\nprovided for the sequestration per unit area, or the emissions associated with\nthe arable cultivation. <\/p>\n\n\n\n

A key point here is that the total annual sequestration is\nsignificantly reduced by the large negative factor included for arable land.\nThis allows for the carbon emissions associated with arable cultivation.\nHowever, these emissions are not avoided by the development taking place and\nwould be displaced elsewhere. Without this deduction, the annual sequestration\nfor the existing site would be greater than that shown for the development in\nTable 20-14.<\/p>\n\n\n\n

20.4.6<\/p>\n\n\n\n

This section makes an unjustified claim that the\nagricultural practices of the existing site would not change over the next 60\nyears. However it is completely plausible that cultivation practices will\nchange as the need to preserve soil carbon content becomes more widely recognised,\npossibly by adopting new practices such as agro-forestry. The need for\nsignificantly increased areas of tree-planting has now been identified by the\nCommittee on Climate Change[5]<\/a>.     In response to the UN IPCC report published\non 8 August 2019 the NFU has stated its aspiration for UK farming to become\ncarbon neutral by 2040.<\/p>\n\n\n\n

20.6.10<\/p>\n\n\n\n

Figures are quoted here for residential and non-residential\nbuildings, but there is no explanation as to how these figures are used in the\nfollowing calculations.<\/p>\n\n\n\n

20.6.11<\/p>\n\n\n\n

The units here appear incorrect, based on Appendix 20.2m\nwhere the savings from PV installations are 8500 dwellings x 166 kgCO2<\/sub>\/dwelling\/year,\ngiving a total of 1,411,255 kgCO2<\/sub> \/year.<\/p>\n\n\n\n

The basis for the figure of 166 kgCO2<\/sub>\/dwelling\/year\nin Appendix 20.2 p127 is also not stated. Clearly some dwellings are apartments\nand so have no dedicated roof area so the use of this pro-rata figure for the\nPV carbon savings is opaque. A more appropriate method would be to provide the\nsavings from PV per square meter, and then to provide the roof area and number\nof dwellings to which it can be applied. As it stands, the quoted figure per\ndwelling provides no further clarity than is given by an un-substantiated total\nfigure and the total number of dwellings. <\/p>\n\n\n\n

PV panels typically have a design lifetime of 25 years. The\napplication should therefore commit to maintaining the electricity production\nfrom the PV for the life of the development to ensure that the claimed savings\ncan be achieved in practice. This would require further investment of new\npanels and it cannot be assumed that house owners will do that investment. If\nthey did it would add to the embodied carbon figure for the development.<\/p>\n\n\n\n

The carbon savings from \u2018Fabric First\u2019 design also appear to\nhave incorrect units (presumably this should be 1,602,000 kgCO2<\/sub>\n\/year to give the total of 3,013,599 kgCO2<\/sub> \/year as in Table 20-16).\nAgain, there is no explanation of the basis for this additional carbon saving.<\/p>\n\n\n\n

20.6.12<\/p>\n\n\n\n

No justification is provided for the quoted saving of 30\nkgCO2<\/sub>\/dwelling\/year from the developer\u2019s commitment to reduce water\nuse from 125 litres\/person\/day to 110 litres\/person\/day. It is not clear that\nthis would not already be built into the 19% figure for carbon reduction\ncompared to the building regulations. <\/p>\n\n\n\n

20.6.13<\/p>\n\n\n\n

Again, no justification is provided for the further carbon\nsaving.<\/p>\n\n\n\n

20.6.14<\/p>\n\n\n\n

ES reference 32 to Waterwise links only to a website and\ndoes not appear to provide the quoted figure of 2.2 kgCO2<\/sub>\/dwelling.\nHowever, the Energy Saving Trust[6]<\/a>\nrecommend a figure of 0.75 kg\/m3<\/sup>, which would correspond to 95.8\nkgCO2<\/sub>\/dwelling\/year if the dwelling uses 350 litres per day, a\nfigure much higher than appears in the ES.<\/p>\n\n\n\n

20.6.15<\/p>\n\n\n\n

The quoted total carbon saving for water use of 1,241,000\nkgCO2<\/sub>\/year is not substantiated by any calculations. If there are\n8500 dwellings, that would be a saving of 146 kgCO2<\/sub>\/dwelling\/year, a\nfigure much higher than the proposed savings of 30 kgCO2<\/sub>\/dwelling\/year\nin sections 20.6.12 and 20.6.13.<\/p>\n\n\n\n

20.6.18<\/p>\n\n\n\n

This section presents the carbon sequestration of the\nproposed development. The rates for the existing land-use types, such as the\nwoodland, appear to be scaled in proportion to the area that would remain. As\nbefore, there is a negative sequestration for the arable land due to the carbon\nemissions associated with farming. However, the ES does not appear to apply a\nconsistent approach for parks or gardens as there is no mention of carbon\nemissions associated with landscape maintenance.<\/p>\n\n\n\n

20.6.24<\/p>\n\n\n\n

This quotes a total TER of 15,617,402 kgCO2<\/sub>\/year\nfor the development. There is no justification provided for this figure, and it\nis unclear how it could be derived from the TER and DER figures listed in\nAppendix 20.2 on p127.<\/p>\n\n\n\n

20.6.26<\/p>\n\n\n\n

Contrary to the comments in this paragraph, Appendix 20.2\ndoes not provide any justification for the figures in Table 20-17. The areas\nare listed for the Stort crossings on p129 but no detail is provided for the\nembodied carbon.<\/p>\n\n\n\n

20.6.29<\/p>\n\n\n\n

The figures for the carbon sink of the proposed development\nare summarised in Table 20-18 and listed in further detail in Appendix 20.2\np129-p130. As with the figures for the existing development, a \u2018metric\u2019 is\nlisted for each land-use type but with no units or explanation to show how this\ncan be multiplied by the appropriate area to reach the 25-year total. <\/p>\n\n\n\n

The \u2018metrics\u2019 are the same as those used for the existing\ndevelopment. However, the figures provided by Edmonson (2014) for closed\nsurfaces (e.g. roads and the built area) do not confirm that these areas will\nact as a carbon sink. The paper states \u201cAs yet it is unclear whether the OC\nstocks in soils beneath impervious surfaces are essentially passive, and\ntherefore a reflection of the OC present at the time of capping, or whether\nthere is active turnover of OC in the soils\u201d. The examples quoted in the paper\nare described as \u201cpatches of patio, garden path or residential driveway\u201d where\nroot growth is likely to occur from adjacent green-space. The paper does not\nconclude that carbon is actively captured underneath wide areas of paved or\ngrey infrastructure. <\/p>\n\n\n\n

The carbon sink value for the natural green space is shown\nin Appendix 20.2 as 80,105,111 kgCO2<\/sub> after 25 years. This is\nimplausibly high in comparison with the existing ASNW woodland which has a\nsimilar carbon sink value of 87,851,988 kgCO2<\/sub> after 25 years,\nespecially as the natural green space is said to have only 20% woodland cover.\nThe carbon sequestration rate for the natural green space is listed in Table\n20-14 as 110,762 kgCO2<\/sub>\/year, giving only 2,769,050 kgCO2<\/sub>\nafter 25 years so it is unclear how the high carbon sink value has been\ncreated.<\/p>\n\n\n\n

20.6.34<\/p>\n\n\n\n

The ES claims that carbon neutrality can be achieved after\n51 years. There are no calculations provided to substantiate this, and the\nactual carbon balance would appear to be significantly worse.<\/p>\n\n\n\n

Taking the figures provided at face value, there is an\nembodied carbon cost of 535,671,221 kgCO2<\/sub> and a total operational\ncarbon cost over the 60-year period of 937,044,120 kgCO2<\/sub>. This\noperational carbon cost is offset by savings listed in Table 20-20 to reduce it\nto 567,526,620 kgCO2<\/sub>. The total embodied plus net operational carbon\nis therefore 535,671,221 + 567,526,620 = 1,103,197,841 kgCO2<\/sub>. <\/p>\n\n\n\n

The ES sets out a difference in carbon sinks between the\nsite developed and the site as currently used for agriculture and woodland\nclaiming that the developed site achieves a net increase in carbon storage of 59,023,830\nkgCO2<\/sub>. There appears to be no possibility of this balancing with the\nincrease in embodied and operational carbon from the development and so it is\nunclear how carbon neutrality could be achieved at any time period.
<\/p>\n\n\n\n

\n\n\n\n

[1]<\/a> https:\/\/www.taylorwimpey.co.uk\/-\/media\/Head%20Office\/IR%20Comms%20images\/2019\/SR%202018\/Taylor%20Wimpey%20Sustainability%20Report%202018%20WR.pdf<\/a>\n<\/p>\n\n\n\n

[2]<\/a> https:\/\/ec.europa.eu\/environment\/integration\/research\/newsalert\/pdf\/38si9_en.pdf<\/a><\/p>\n\n\n\n

[3]<\/a> https:\/\/doi.org\/10.1016\/j.enbuild.2010.09.005<\/a>\n<\/p>\n\n\n\n

[4]<\/a> https:\/\/publicaccess.eastherts.gov.uk\/online-applications\/files\/A004E30F8B1217A97C1224DED1A704ED\/pdf\/3_19_1045_OUT-99E_ES_VOL_III__76_OF_76__LIGHT_AND_CLIMATE_CHANGE-1384787.pdf<\/a> <\/p>\n\n\n\n

[5]<\/a> https:\/\/www.theccc.org.uk\/2019\/07\/10\/uk-credibility-on-climate-change-rests-on-government-action-over-next-18-months\/<\/a><\/p>\n\n\n\n

[6]<\/a> https:\/\/www.waterwise.org.uk\/wp-content\/uploads\/2018\/02\/Energy-Saving-Trust-2009_Quantifying-the-Energy-and-Carbon-Effects-of-Water-Saving_Full-Technical-Report.pdf<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

Our response to the outline planning application 3\/19\/1045\/OUT “We consider the Council needs to refuse outline planning permission to Places for People in relation to their outline plans for the Gilston Estate as it does not meet EHDC\u2019s recent climate change motion: to do everything within the authority\u2019s power to reduce its impact on the…<\/p>\n

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