GBC Policy

Policy D2: Sustainable design, construction and energy 

Sustainable development

Proposals for zero carbon development are strongly supported. Proposals for development, including refurbishment, conversion and extensions to existing buildings, must set out in a sustainability statement how they will deliver:

• sustainable design and construction practice including (where applicable): 
• the efficient use of mineral resources and the incorporation of a proportion of recycled and/or secondary aggregates
• waste minimisation and reusing material derived from excavation and demolition
• the use of materials both in terms of embodied carbon and energy efficiency
• landform, layout, building orientation, massing and landscaping,
• the lowest level of carbon emissions (direct and embodied) that is achievable,
• the highest levels of energy and water efficiency that are achievable and
• measures that enable sustainable lifestyles for building occupants wherever opportunities to do so are identified.

When meeting these requirements, the energy and waste hierarchies should be followed except where it can be demonstrated that greater sustainability can be achieved by utilising measuresfurther down the hierarchy. The Sustainable Design and Construction Supplementary Planning Document (SPD) sets out guidance on appropriate standards and practice.

Climate Change Adaptation

Developments should be fit for purpose and remain so into the future. Development proposals must set out in a sustainability statement how they have incorporated adaptations for a changing climate and changing weather patterns in order to avoid increased vulnerability and offer high levels of resilience to the full range of expected impacts.

Renewable, low carbon and decentralised energy

The development of low and zero carbon and decentralised energy, including (C)CHP distribution networks, is strongly supported and encouraged.

All new developments must connect to (C)CHP distribution networks where they exist, or incorporate the necessary infrastructure for connection to future networks, unless it can be clearly demonstrated that doing so is not feasible or that utilising a different energy supply would be more sustainable.

Proposals for development within heat priority areas as shown on the Policies Map and all sufficiently large or intensive developments must demonstrate that heating and cooling technologies have been selected in accordance with the following heating and cooling hierarchy unless it can be clearly demonstrated that an alternative approach would be more sustainable:

1. Connection to existing (C)CHP distribution networks
2. Site wide renewable distribution networks including renewable (C)CHP
3. Site wide gas-fired (C)CHP distribution networks
4. Renewable communal heating networks
5. Gas-fired communal heating networks
6. Individual dwelling renewable heating
7. Individual dwelling heating, with the exception of electric heating

All (C)CHP must be of a scale and operated to maximise the potential for carbon reduction.

Developments that do not connect to or implement (C)CHP or communal heating networks should be ‘connection-ready’.

Energy statements must be provided to demonstrate and quantify how development will comply with the energy requirements of this policy. Guildford Borough Council will work proactively with applicants on major developments to ensure these requirements can be met.

Carbon reduction

New buildings must achieve a reasonable reduction in the carbon emissions that remain after efficiency measures have been applied of at least 15 per cent. This should be achieved through the provision of appropriate on-site renewable and low carbon energy technologies. Proposals should set out how this will be achieved in an energy statement.

GGG Response

Summary

We OBJECT to this policy

The emphasis on energy and waste hierarchies and reduction of carbon emissions as part of building design are welcomed. 

However, the emphasis on CCHP (Combined Cooling Heating and Power) and communal heating networks seems curious – no such networks are currently locally available. 

There is an element of “greenwashing” – the imposition of aspirational environmental targets while ignoring the simple fact that building dormitory towns is environmentally unsustainable. 

These all require increased car use and will lead to increased congestion and so air pollution and higher carbon dioxide emissions and a few solar panels on roofs will not compensate for the considerable environmental cost. 

Detailed Response

Sustainability should be an overarching ambition, conditioning the whole local plan and running through it, as claimed in the NPPF, “like a golden thread”.  It should be set out clearly in Policy S1, not buried away as a minor detail in Policy D2.

This policy amounts to “greenwashing”, expounding aspirational environmental targets while ignoring the plan to build dormitory towns in the Green Belt that are environmentally and socially unsustainable.  These settlements will require vastly increased car use and will lead to unacceptable traffic congestion, overstretched social infrastructure, and higher greenhouse gas emissions and noise and light pollution.  This policy should not be just about saving energy but about preserving the borough’s stock of natural capital, especially the countryside, from futile attempts to rig the housing market.  

This policy’s emphasis on Combined Cooling Heating and Power and communal heating networks is meaningless, since no such networks are available locally.