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Representation 1715 on BMSDC Joint Local Plan Consultation Document (Interactive) by David Howorth

Support / Object: OBJECT
Document Link: BMSDC Joint Local Plan Consultation Document (Interactive) - ENVIRONMENT, Climate Change, Q53
Representation: The water regulations are, in my opinion, the worst constructed of any part of the building regulations, and are positively harmful to sustainable building. What matters as far as water is concerned is the quantity of water consumed and particularly hot water. As long as water meters are not mandatory, other regulation is meaningless. The chosen method of restricting the choice of fittings is particularly stupid, resulting in a pure box-ticking exercise to meet regulations and poorer results for the end-user in many cases, whilst not limiting actual water usage.

Original submission

Here are my comments on the Babergh & Mid Suffolk Joint Local Plan:
Consultation Document.

I dispute the statement on p69: 'Whilst the planning system has a role to play in delivering sustainability in buildings, construction methods and the energy performance of buildings are primarily addressed via Building Regulations'. Building Regulations merely provide the minimum legal obligation. They most certainly do not set out or even describe sustainable building methods.


I do not support the Council's initial preference to include water efficiency measures in new build as questioned in Q53 on p61. The water regulations are, in my opinion, the worst constructed of any part of the building regulations, and are positively harmful to sustainable building. What matters as far as water is concerned is the quantity of water consumed and particularly hot water. As long as water meters are not mandatory, other regulation is meaningless. The chosen method of restricting the choice of fittings is particularly stupid, resulting in a pure box-ticking exercise to meet regulations and poorer results for the end-user in many cases, whilst not limiting actual water usage.


As regards Q54, also on p61, I would support the council in applying additional energy efficiency standards to all buildings where possible and certainly to all buildings over which they exercise control.
Specifically, I would like to see all council and social housing built to the passivhaus standard. Norfolk and Essex both have many examples and Suffolk as yet has not a single example.


The Suffolk Design Guide for Residential Areas, referred to on p64 and implied in questions Q60 and Q61, should be brought up to date and should recognize that timber frame and lath-and-plaster walls are completely inappropriate and irrelevant for modern times. The Design Guide should encourage buildings with energy efficient fabric, rather than emphasising inefficient features like dormers, chimneys, changes of roof level. It is fine for people who want to spend additional money to provide a sustainable and energy efficient building that also has these outdated features, but grossly irresponsible of the council to require them.


David Howorth


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