Addendum to the Regulation 19 Sustainability Appraisal
4 Main Modification Two – Policy SCC4 Comment
4.1 Overview
4.1.1 Policy SCC4 sets out the requirement for the embodied carbon and waste associated with new development to be considered, forming part of SMBC's strategy to supporting low carbon development, regeneration, and tackling climate change. The term 'embodied carbon' refers to the emissions associated with materials and construction processes throughout the whole lifecycle of a building or infrastructure[35].
4.1.2 SMBC have proposed to modify the wording of Policy SCC4 to refer to the BS EN 15978 standard, which is a European standard that provides guidelines for assessing the environmental performance of buildings and construction work. The policy requirement to consider material re-use when demolishing buildings and structures is proposed to be amended so that it is proportionate and would not impose unnecessary burdens on small-scale developments.
4.2 Assessment of modified policy
4.2.1 Box 4.1 presents the proposed modified text to the Submission version of Policy SCC4, with proposed removed text in strikethrough, and proposed new text underlined and bold.
Box 4.1: Proposed modification to Policy SCC4
Policy SCC4 - Embodied carbon and waste
- Embodied carbon reporting
- All large-scale major new residential developments (50 dwellings or more) and non-residential developments (5,000 m² floorspace or more)
developmentsare required to complete a whole-life carbon assessmentin accordance with RICS Whole Life Carbon Assessment guidancewith BS EN 15978 standard. The assessment should be based on the most appropriate and up-to-date guidance available that complies with the principles outlined in the BS EN 15978 standard. Guidance such as the RICS Whole Life Carbon Assessment guidance (2nd edition) may be used, among others.
- All large-scale major new residential developments (50 dwellings or more) and non-residential developments (5,000 m² floorspace or more)
- Limiting embodied carbon
- Positive weight will be given to applications that can demonstrate embodied carbon (RICS/BS 15978 modules A1 - A5) that is limited to 600 kgCO2e/m2 GIA.
- Building end-of-life
- All new buildings should be designed to enable easy material re-use and disassembly, subsequently reducing the need for end-of-life demolition.
- Demolition audits
- All major development sites that contain existing buildings / structures must carry out a pre-redevelopment and/or pre-demolition audit, following an
well-established industry best practice method (e.g. BRE), for larger structures or significant demolitions. - For smaller-scale demolitions, such as individual walls or small outbuildings, developers are required to consider material re-use where feasible, without the need for a full audit. A simplified, proportionate approach should be taken to assess potential material recovery and reuse.
- All major development sites that contain existing buildings / structures must carry out a pre-redevelopment and/or pre-demolition audit, following an
- Narrative on embodied carbon in minor development
- Proposals for new development of one or more homes or ≥ 100m2 non-domestic floor space, but below the size thresholds for embodied carbon reporting and targets as noted above, should include a general narrative on the options considered (and where possible, the decisions made) to minimise the embodied carbon of the proposed development.
4.2.2 The proposed modification retains the requirement for new major developments to complete a whole-life carbon assessment, but clarifies that use of RICS guidance[36] is not specifically required, and instead ensures compliance with the principles of the BS EN 15978 standard[37]. Additionally, the modification clarifies the proportionate approach that will be permitted for smaller-scale demolitions where a full audit is not necessary.
4.2.3 The proposed changes to Policy SCC4 will still be expected to ensure that opportunities to identify and reduce carbon emissions are explored, and a circular economy is supported. The SA assessment of the policy remains unchanged from the Regulation 19 SA as replicated in Table 4.1 below.
4.2.4 The full assessment narrative and explanation behind each score can be found in Appendix F of the Regulation 19 SA Report (2024)[38].
Table 4.1: Policy matrix for proposed modification to Policy SCC4
|
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
9 |
10 |
11 |
12 |
13 |
14 |
|
|
Policy Ref |
Cultural Heritage |
Landscape |
Biodiversity |
CC Mitigation |
CC Adaptation |
Natural Resources |
Pollution |
Waste |
Transport |
Housing |
Equality |
Health |
Economy |
Education |
|
SCC4 |
0 |
0 |
0 |
++ |
0 |
0 |
+ |
++ |
0 |
0 |
0 |
0 |
+ |
0 |
[35] UKGBC (2024) Embodied carbon. Available at: https://ukgbc.org/our-work/topics/advancing-net-zero/embodied-carbon/#:~:text=Embodied%20carbon%20refers%20to%20the,of%20a%20building%20or%20infrastructure. [Date accessed: 17/04/25]
[36] RICS WLCA Guidance. Available at: https://www.rics.org/profession-standards/rics-standards-and-guidance/sector-standards/construction-standards/whole-life-carbon-assessment [Date accessed: 17/04/25]
[37] BSI Knowledge (2011) BS EN 15978. Available at: https://knowledge.bsigroup.com/products/sustainability-of-construction-works-assessment-of-environmental-performance-of-buildings-calculation-method [Date accessed: 17/04/25]
[38] Lepus Consulting (2024) Sustainability Appraisal of the Sandwell Local Plan 2024-2041: Regulation 19 SA Report Volume 3 of 3: Appendices. September 2024. Available at: https://www.sandwell.gov.uk/downloads/file/3209/slp-reg-19-sustainability-appraisal-vol-3-appendices-september-2024- [Date accessed: 17/04/25]
