Cefnogi
1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd
ID sylw: 5874
Derbyniwyd: 11/03/2026
Respondent ID: 3407
Ymatebydd: Mr Jonathan Davies
I fully support the ambition of VoGC to address, mitigate and adapt to anthropogenic climate change by applying demand-based metrics to reduce carbon emissions from the built environment. Monmouthshire County Council are advancing similar proposals to Inspection this summer and multiple LAs in England have successfully introduced similar targets, defining space heating demand (SHD) and energy use intensity (EUI) targets as scientifically robust metrics that align with best practice for achieving Net Zero emissions. It has been exhaustively demonstrated that better performing buildings, those with improved (reduced) SHD and EUI, more economically achieve operational Net Zero than those delivered to business as usual (BAU) and deliver considerable lifecycle cost savings for occupants. The Building Regulations methodology through the standard assessment procedure (SAP) is deeply flawed and inconsistent with efficiently or effectively achieving Net Zero (as the 2021 report for the Department for Business, Energy and Industrial Strategy "Making SAP and RdSAP 11 fit for Net Zero" concluded) and the replacement Home Energy Model (HEM) has not been demonstrated to be any better aligned. In the context of the declared Climate Emergency, action by the Senedd and Westminster is not moving fast enough to deliver our legal commitments to decarbonise.
I fully support the ambition of VoGC to address, mitigate and adapt to anthropogenic climate change by applying demand-based metrics to reduce carbon emissions from the built environment. Monmouthshire County Council are advancing similar proposals to Inspection this summer and multiple LAs in England have successfully introduced similar targets, defining space heating demand (SHD) and energy use intensity (EUI) targets as scientifically robust metrics that align with best practice for achieving Net Zero emissions. It has been exhaustively demonstrated that better performing buildings, those with improved (reduced) SHD and EUI, more economically achieve operational Net Zero than those delivered to business as usual (BAU) and deliver considerable lifecycle cost savings for occupants. The Building Regulations methodology through the standard assessment procedure (SAP) is deeply flawed and inconsistent with efficiently or effectively achieving Net Zero (as the 2021 report for the Department for Business, Energy and Industrial Strategy "Making SAP and RdSAP 11 fit for Net Zero" concluded) and the replacement Home Energy Model (HEM) has not been demonstrated to be any better aligned. In the context of the declared Climate Emergency, action by the Senedd and Westminster is not moving fast enough to deliver our legal commitments to decarbonise.