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East Devon Local Plan consultation: the costs of development

  • by JW

There are no suggestions on minimising emissions in the design and construction of new developments.

“In new development, we need to consider whole-life carbon emissions and resource depletion. This includes both “in-use” energy efficiency and “embodied” carbon emission contained within the construction process such as the production, supply and recycling of materials.”


The District Council’s ‘issues and options’ as part of the consultation for its new Local Plan looks at “Tackling the climate emergency”:

Objective 2: To ensure all new development moves the district towards delivering net-zero carbon emissions by 2040 and that we adapt to the impacts of climate change. 



How exactly can this be achieved?

The District Council suggests the following:

Reducing carbon emissions from new developments

4.4 It is identified as essential to minimise emissions in the design, construction and operation of new developments. This can be done by incorporating measures such as better insulation, glazing and renewable technologies like solar panels in developments. There are also low carbon heating options such as district heating systems as installed at Cranbrook where hot water is pumped around all houses to supply heating. Local authorities currently have the ability to set energy efficiency standards for new build developments that go beyond the minimum levels set out in
building regulations.

East Devon Local Plan


But, actually, there are no suggestions on minimising emissions in the design and construction of new developments.


There are suggestions in the VGS’s draft submission:

A report shows that Local Plans need to be much more ambitious with zero-carbon standards for new-builds:

Local Plans, housing and carbon commitments – Vision Group for Sidmouth

The LP should insist new-builds go well beyond net zero carbon for operational energy’:

What is a ‘net-zero carbon’ building? – Vision Group for Sidmouth

It should embrace technologies which fundamentally cut the use of carbon:

Circular construction: a solution to embodied carbon in buildings – Vision Group for Sidmouth

Build back better: build low-impact, resilient buildings – Vision Group for Sidmouth


How can “embodied carbon” in buildings and infrastructure be avoided?

The DCC Net-Zero Task Force identifies 4 sources including greenhouse gas generated from mobility, buildings, energy usage and food production. In the UK the built environment and transport account for around 40% and 33% of the total carbon dioxide emissions. Most of such emissions are from burning fossil fuels in buildings and gas-guzzling motor vehicles. In new development, however, we need to also consider whole-life carbon emissions and resource depletion. This includes both “in-use” energy efficiency and “embodied” carbon emission contained within the construction process such as the production, supply and recycling of materials. It is largely due to the “embedded” carbon why existing buildings are considered the “greenest” and why “retrofitting” is considered more suitable, thankfully the path of choice for the Drill Hall but unfortunately not for the former Knowle Hotel. 

In the area, the worst-case scenario with respect to the carbon footprint and environmental impact will be the proposed Sidford Business Park. With increased traffic and pollution, the risk of flooding and ecological harm this will create considerable damage to the AONB and the valley as a resort of quality. The volume of traffic movement including HGVs during and after construction, employees and visiting vehicles choking up the narrow roads in the locality will be considerable. The whole-life emissions from embodied carbon during building and the in-use heating and cooling will be vast. In view of the climate and extinction emergency, there is clearly no justification for such unnecessary out-of-town development especially when there is no evidence of need and plenty of spare office space capacity in the centre of Sidmouth. If we are to avoid a climate change catastrophe, we owe it to future generations to call a halt to the wasteful use of resources and such unsustainable over development.

Unsustainable over-development in East Devon – Vision Group for Sidmouth


The example of the bulldozing of Knowle to create a ‘low-carbon’ new HQ is a case in point – which was about destroying a lot of ’embedded carbon’ and then using tonnes of ’embodied carbon’:

Futures Forum: Knowle: old bricks vs new build: embodied carbon

Futures Forum: Knowle relocation project: reducing carbon emissions


The construction industries are indeed responsible for creating huge amounts of ’embodied carbon’:

Futures Forum: What can be done to mitigate the huge impact of construction on climate change?


The term ’embodied carbon’ is very clear:

Embodied energy, is defined as the Energy that was used in the work of making a product. Embodied energy is attempts to measure the total of all the energy necessary for an entire product Lifecycle. This lifecycle includes raw material extraction, transport, manufacture, assembly, installation, disassembly, deconstruction and/or decomposition.’

Embodied Carbon Assessment – Circular Ecology

Reducing embodied carbon in buildings


On the other hand ’embedded carbon’ is ambiguous as it sometimes refers to ’embodied carbon’:

Embedded energy – Appropedia


It is also sometimes used to refer to ‘sequestered carbon’:

Advances in Sequestering Carbon in the Built Environment

By now, we know that the global design and construction industry is responsible for approximately 39 percent of total greenhouse gas emissions (GHGs). That is subdivided into 28 percent for all the energy used to heat, cool, ventilate, light, and power our buildings; plus, another 11 percent to mine, extract, harvest, process, manufacture, fabricate and transport all the materials used to construct them. Put more simply, that’s 28 percent for building operations and 11 percent for the embodied carbon of construction materials.

As the design and construction industries work to reduce both of these significant contributors to climate change, the question arises as to whether buildings can actually sequester carbon. Sequestering carbon would transform buildings from net negative to net positive environmental impacts. Below we examine several approaches making this possible.

3 Advances in Sequestering Carbon in the Built Environment – Sustainable Brands

Carbon Dioxide Sequestration in Cementitious Construction Materials | ScienceDirect


The District Council claims that ‘climate change considerations also run through the whole of this report’ – but taking into account the use of energy and resources, and the creation of pollution during construction and ‘development’ also need to be taken into consideration.

East Devon Local Plan