Comments on the DPNF Policies Draft of 15 january 2016 MWP

First of all perhaps I should briefly state my credentials. I am an architect with 25 years experience of working in the field of environmentally sustainable design. I was part of the core team that designed the Eden Project and also created an environmental management system that resulted in Grimshaw Architects being the first architectural firm in Europe to achieve certification to the International Standard ISO14001 for environmental management systems. As a consultant I have worked with a number of other firms helping them to achieve the same certification. I was one of the founder members of the UK Green Building Council (a cross-industry group with 400 members including large organisations such as Arup, Camden Council and The Crown Estate) and have been involved in many of their policy discussions.

Policy ES4(a): The wording suggests that developers can choose to simply comply with Part L (which is a lower standard than the Code for Sustainable Homes level 5). I suggest removing the wording “where these go beyond the Building Regulations Part L”

Policy ES4(b): The wording “wherever proportionate to the size of the new extension and consistent with Conservation Area guidance” is unclear to me. The policy also (according to my reading of it) excludes Listed Buildings (and buildings in Conservation Areas?) which I regard as unambitious. It is also in conflict with Borough Policy Section 3: “Historic buildings can and should address sustainability”andNationalPlanning Policy Statement 5,Section HE1.1. There are plenty of opportunities for upgrading listed buildings sensitively and often these are the buildings most in need of upgrading so I recommend that these should be included rather than excluded. I would be happy to provide further explanation of the kind of measures that can be implemented to upgrade historic buildings. Also, I recommend changing the wording in the first sentence from “extra internal insulation” to “energy efficiency improvement measures” so that it can include measures such as draught-stripping and upgraded appliances

Policy ES4(c): The wording “or other residences” should, in my opinion, be removed because it effectively prevents solar energy installations in all but a very few locations. There are two reasons why I believe this is unreasonably restrictive: Firstly it is not consistent with the commitments agreed to at the Paris COP21 (effectively committing all countries to decarbonise their energy supplies in the next few decades) and it would effectively mean that more solar panels will need to be installed in the countryside. The book ‘Sustainable Energy Without The Hot Air’ provides a very clear explanation of the difficult choices we face and we all need to do our bit. Secondly, there are now plenty of systems on the market that alow much more sympathetic integration into existing roofs. I have attached two examples of ‘solar slates’ that are far more discrete than large rectangular panels.

Michael PawlynRIBA FRSA

Director

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