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Guildford Borough Council

Submission Local Plan: Strategy and Sites - Main Modifications

Submission Local Plan: Strategy and Sites - Main Modifications - Part 1: Policies

Policy D2: Sustainable design, construction and energy


Sustainable development

4.5.9 Achieving sustainable development means that plans should secure net gains within economic, social and environmental objectives (NPPF, paragraph 8). Environmental objectives include using natural resources prudently, minimising waste, mitigating and adapting to climate change and moving to a low carbon economy.

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Climate change and the low carbon economy

4.5.11 The South East of England is likely to face significant challenges from a changing climate and changing weather patterns. To avoid the costs associated with retrofitting and replacement, new buildings should be future proofed; suited to, and easily adaptable for, the range of climate conditions and weather patterns we are likely to see over the next century, and adaptable to new technologies. The buildings we build today are likely to be with us into the next century, so the benefits of building adaptable and efficient developments will last a long time.

4.5.12 A significant percentage of our carbon emissions come from our homes (32 per cent in our borough[28]). Our current housing stock will remain in use for a long time so retrofitting existing homes for better energy efficiency is a vital step for reducing carbon emissions. The Council supports the retrofitting of buildings for energy efficiency where planning permission is required. Retrofitting heritage assets in a way that conserves their significance can be difficult. In these cases, the Council will work with applicants to find appropriate solutions, and bodies like Historic England provide useful guidance.

Resources and waste

4.5.13 Projections of changing rainfall patterns, an increasing population, planned reductions in abstraction and proposed water transfer schemes mean that our water supply is likely to come under increasing pressure in an area already identified as being under serious water stress. Producing clean water carries a carbon cost, so using water more efficiently can have an impact on carbon emissions as well as helping to conserve water stocks.

4.5.14 The issue of waste is directly linked to the way we use resources. Reusing waste products and materials and reclaiming materials through recycling can reduce our consumption of primary resources and support the move to a circular economy. Around a third of the UK's waste comes from the construction and demolition sector.

4.5.15 Early engagement between developers and the Council to help achieve the greatest sustainability benefit is encouraged. The Council will support this work by signposting relevant advice and providing guidance through the Sustainable Design and Construction Supplementary Planning Document (SPD).

POLICY D2: Sustainable design, construction and energy

Sustainable development

(1) Proposals for zero carbon development are strongly supported. ApplicationsProposals for development, including refurbishment, conversion and extensions to existing buildings, are required to set out in a sustainability statement how they will should include information setting out how deliver:sustainable design and construction practice will be incorporated including (where applicable):

(a) the efficient use of mineral resources and the incorporation of a proportion of recycled and/or secondary aggregates

(b) waste minimisation and reusing material derived from excavation and demolition

(c) the use of materials both in terms of embodied carbon and energy efficiencyuse of landform, layout, building orientation, massing and landscaping to reduce energy consumptionthe lowest level of carbon emissions (direct and embodied),

(d) the highest levels of energy and water efficiency andthat meets the highest national standard and

(e) measures that enable sustainable lifestyles for the occupants of the buildings

(2) 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 measures further down the hierarchy. The Sustainable Design and Construction Supplementary Planning Document (SPD) sets out guidance on appropriate standards and practice.

(2a) Major development should include a sustainability statement setting out how the matters in this policy have been addressed. Smaller developments should include information proportionate to the size of the development in the planning application.

Climate Change Adaptation

(3) All Ddevelopments should be fit for purpose and remain so into the future. Development proposalsProposals for major development are required to 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

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

(5) Where (C)CHP distribution networks already exist, new developments are required to connect to them or be connection-ready unless it can be clearly demonstrated that utilizing a different energy supply would be more sustainable or connection is not feasible. All new developments are required to 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.

(6) 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:demonstrate that (C)CHP has been given adequate consideration as the primary source of energy.

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

(7) All (C)CHP systems are required to be scaled and operated in order 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'.

(8) 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

(9) New buildings must achieve a reasonable reduction in carbon emissions of at least 20 per cent below the relevant Target Emission Rate (TER) set out in the Building Regulations 2010 (as amended) (Part L). This should be achieved through the provision of appropriate renewable and low carbon energy technologies in the locality of the development and improvements to the energy performance of the building. Where it can clearly be shown that this is not possible, offsite offsetting measures in line with the energy hierarchy should be delivered. Proposals should set out how this will be achieved in an energy statement.

(10) Retail units falling within Use Classes A1, A2, A3 and A4 in Guildford Town Centre are not subject to the carbon reduction requirement at paragraph (9).

(11) Planning applications must include adequate information to demonstrate and quantify how proposals comply with the energy requirements at paragraphs 5-10 of this policy. For major development, this should take the form of an energy statement.

 * (C)CHP refers to both combined cooling heating and power (CCHP) and combined heating and power (CHP).


4.5.16 Zero carbon development means development where emissions from all regulated energy use are eliminated or offset. This definition may be reviewed in the future.

4.5.16a The definition of major development includes residential development of 10 dwellings or more (gross) and non-residential development of 1,000 sqm gross new floorspace or more. Sustainability and energy statements should set out a level of detail proportionate to the scale of development.

4.5.17 The energy and waste hierarchies set out the sequence of steps that should be followed to make development more sustainable. The sequence of steps in the hierarchies will sometimes depend upon the full life cycle approach to impacts. As an example, landfill may be preferable to energy recovery for some materials. Decisions in this regard should be based on information or guidance from a reliable and authoritative source.

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4.5.19 The approach to water management should follow the basic principles of the hierarchies, with elimination and efficiency as the first steps, and other measures, including water harvesting and grey water reuse systems, coming later.

The energy hierarchy

The waste hierarchy

Step 1: Eliminate energy need

Developments should be designed to eliminate the need for energy through measures including:

  • design of the scheme layout
  • thermally efficient construction methods and materials
  • design features that eliminate the need for appliances
  • making optimal use of passive heating and cooling systems

Step 2: Use energy efficiently

Developments should incorporate energy efficient systems, equipment and appliances to reduce the remaining energy demand. Energy storage devices may improve efficiency.

Step 3: Supply energy from renewable and low carbon sources

The remaining energy need should be met from renewable and low carbon sources.

Step 4: Off set carbon emissions

As a final step, remaining emissions should be offset, for example through off-site measures that reduce carbon emissions or remove carbon from the atmosphere.

Step 1: Eliminate waste

Construction practice and design should reduce waste wherever possible through measures including:

  • efficient procurement avoiding over-supply and excessive packaging
  • eliminating waste at the design stage.

Step 2: Reuse waste materials

Reuse waste materials, ideally in its current location, avoiding the energy costs associated with transport and recycling.

Step 3: Recycle/compostwaste materials

Recover materials through recycling and substitute for primary materials. Compost organic material to produce rich soils that replace fertilisers, ideally in a closed system to avoid the emissions released by organic material in landfill.

Step 4: Recover energy

If it cannot be reused or recycled, use waste instead of fossil fuels in energy generation to recover embodied energy.

Step 5: Disposal to landfill

Usually the last resort. Disposal to landfill wastes materials and embodied energy.


4.5.20 The highest level “national standard” of for water efficiency means refers to any nationally described standard for water consumption in new developments. The “highest national standard” refers to the standard that has the lowest water consumption. At the present time, the highest national standard that developments should achieveis the “optional requirement” described by regulation 36 paragraph 2(b) of the Building Regulations 2010 as a minimum. This “optional requirement” which sets a water efficiency standard for new buildings dwellings of 110 litres per occupant per day. If one or more the “optional requirement” building regulation is tightened, or a new national standards is are introduced,, the highest level of water efficiency will refer to the standards that has have the lowest water consumption will apply. Compliance with the “optional requirement” is assessed through the building regulation process.  

4.5.21 The suitability of measures that support sustainable lifestyles for building occupants will be considered on a case by case basis. They could include features such as storage for recyclable materials, energy storage devices, composting facilities, laundry drying areas, use of natural light and solar gain, energy saving appliances, parking for bicycles and electric vehicle charging points.

4.5.22 The full range of expected climate change impacts are set out in publications from UK Climate Projections 2009 (UKCP09, to be reviewed in 2018) and from other national and international bodies. The Guildford Environmental Sustainability and Climate Change Study presents a summary from several sources.

4.5.23 Decentralised energy means energy that is produced near where it is used, as opposed to energy produced at a large plant and supplied to energy users through the national grid. Energy can refer to electricity and heat. The Council supports delivery of decentralised energy schemes with an aspiration that these should have some degree of community benefit and/or community ownership where this is possible.

4.5.24 (C)CHP refers to both combined cooling, heating and power (CCHP) and combined heating and power (CHP). The energy hierarchy should be followed when considering which technology to use and consideration should be given to whether the need for cooling can be met through passive cooling and other design features. The solution that results in the lowest carbon emissions should be chosen.

4.5.26 Where (C)CHP distribution networks already exist, new developments are required to connect to them unless there are clear reasons why this is not feasible. When considering new power and heating systems, the hierarchy should be followed unless it can be clearly demonstrated that other sources of energy would be more sustainable, particularly through lower carbon emissions and taking full account of the benefits of providing both heating and cooling.

4.5.27 Sufficiently large or intensive developments are defined as any of the following:

(a) residential only developments of at least 50 dwellings per hectare and/or at least 300 dwellings

(b) residential only developments of 50 dwellings or more that are located near a significant source of heat

(c) mixed developments of 50 dwellings or more that include either two or more non-residential uses or a single use that would generate significant amounts of heat, such as a swimming pool.

4.5.28 Where developments fall within Heat Priority Areas, as shown on the Policies Map, the provision of new (C)CHP distribution networks should be considered feasible unless it can clearly be demonstrated otherwise. Where single building networks are proposed, these should be capable of expanding to connect with other networks and heat sources in the future. Outside the Heat Priority Areas, the provision of new (C)CHP distribution networks should be considered feasible for sufficiently large or intensive developments unless it can be demonstrated otherwise. Where sites have a variable density and it can be shown that the use of a (C)CHP distribution network across the whole of the site is not feasible, consideration must be given to a partial solution on the higher density elements of the site.

4.5.28a (C)CHP systems should be scaled and operated in a way that produces the lowest carbon emissions. A CHP system only generates carbon and financial savings when it is running and the more it runs, the more energy efficient and cost-effective it will be. As a result, CHP will likely only be appropriate where there is a high and constant demand for heat. A recommended rule of thumb is at least 4,500 - 5,000 hours per year, depending on the application. The size of the system should be determined by the heat load and demand profile. If there is a high demand for cooling then CCHP, with the heat converted to cooling, may also be environmentally and economically viable. (C)CHP systems should be designed and operated to be energy efficient, with the selection of optimum operating temperatures and measures to minimise heat losses.

4.5.29 'Connection-ready' means developments that are optimally designed to connect to a (C)CHP or communal heat network on construction or at some point after construction. Developments will be 'connection-ready' if they use a centralised communal wet heating system rather than individual gas/electric boilers or electric heating, and proposals comply with the minimum requirements outlined in the Chartered Institute of Building Services Engineers (CIBSE) Heat Networks Code of Practice.

4.5.30 New developments, except retail developments in Guildford Town Centre, but including non-retail units within mixed use developments, must achieve a reasonable reduction in carbon emissions of at least 20 per cent through the provision of appropriate low and zero carbon energy technologies in the locality of the development and improvements to the energy performance of the building. This should be achieved after energy efficiency has been addressed, in line with the Energy Hierarchy. Technologies will be considered appropriate only where they would be effective. The reduction in emissions is judged against a baseline of the relevant Target Emission Rate (TER) set out in the Building Regulations. For types of development where no TER is set out, reductions should be made against the typical predicted energy use of building services. This The 20% figure represents a minimum standard and where possible this should be improved upon exceeded in order to meet the requirement to deliver the lowest level of carbon emissions (direct and embodied). The Council will review this standard at appropriate intervals.

4.5.30a The financial viability of the requirements set out in Policy D2 will be considered as part of the planning application process.

Reasoned justification

4.5.31 The NPPF requires the planning system to shape places in a way that contributes to "radical reductions" in greenhouse gas emissions and states that plans should take a proactive approach to mitigating and adapting to climate change in line with the objectives of the Climate Change Act 2008, which includes CO2 emissions reductions targets of 34 per cent by 2020 and 80 per cent by 2050 against a 1990 baseline. The UK has a further target for generating 15 per cent of energy (including heat) from renewable sources by 2020. These national targets are ambitious so our borough's efforts at carbon reduction and increasing renewable energy must also be ambitious.

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4.5.33 Local Authorities are empowered to require developments to provide a proportion of their energy from renewable and low carbon sources through planning policy. Our borough lags behind much of the UK in small scale renewable energy generation capacity[29]. In order to play our part in achieving the UK's carbon reduction and renewable energy commitments, new developments are required to meet a percentage of their energy requirements through on-site low and zero carbon energy generation.

4.5.34 The NPPF requires the Local Plan to have a positive strategy to promote renewable, low carbon and decentralised energy, and places particular significance on (C)CHP networks. Therefore, the development of decentralised energy, and particularly (C)CHP distribution networks, is strongly supported.

4.5.35 (C)CHP distribution networks can work at a range of scales from a single building up to a city and can provide low or zero carbon power, heat and cooling in a cost-effective, efficient and environmentally sound way. (C)CHP removes the need for individual gas boilers and large plant rooms, which provides flexibility in building design and maximises space for living and amenity. The UK Government Heat Strategy outlines the significant role that (C)CHP could play in decarbonizing the UK gas grid, offering a future-proofed, flexible and efficient solution to local energy supply.

4.5.36 Where (C)CHP uses a gas fired engine it will produce direct carbon emissions, though these systems are still highly efficient. The engines in (C)CHP systems need replacing after a certain amount of time so there is an opportunity to replace gas engines with engines that use renewable fuels when they come to the end of their lives.

4.5.37 It is acknowledged that requiring developers of a single building to consider implementing (C)CHP on a scale wider than their own development would not be fair. Therefore, the Council encourages the delivery of single building communal systems that can be connected to (C)CHP distribution networks and other sources of heat in the future.

4.5.37a National planning policy instructs local planning authorities to promote and encourage low carbon development subject to considerations of feasibility and viability. The Council has produced the "Assessment of the Viability of Carbon Emission Targets for New Builds" which sets out the viability of achieving the 20 per cent reduction in carbon emissions and provides examples of how it can be achieved. The assessment identifies a cost impact on retail development and it is acknowledged that there are particular viability issues for retail developments in Guildford town centre. As Guildford town centre is a sustainable location for retail developments, new retail units in the town centre are exempted from the carbon reduction requirement as, on balance, this could have a negative impact on sustainable development by discouraging retail development in this sustainable location.

4.5.38 The Guildford Environmental Sustainability and Climate Change Study identifies the particular issue of increasing pressure on water stocks in an area already classed as being under serious water stress. Water consumption in our borough is significantly higher than in other parts of the UK. This indicates both a significant scope for improving the way we use water and the need for a water efficiency standard in new dwellings above the basic national standard. At the present time, the only standard that can be adoptedhighest national standard is the "optional requirement" set out in the building regulationsin regulation 36 paragraph 2(b) of the Building Regulations 2010 (as amended) of 110 litres per occupant per day. However, this standard may be improved in the future and it is considered that local circumstances warrant the implementation of the highest standard available and the highest standard will always be sought. This standard is considered a minimum as in many cases it may be possible to achieve a better standard.

4.5.39 The Surrey Waste Partnership, comprising Surrey County Council and Surrey's Borough and District Councils, is responsible for setting the waste management strategy. Surrey County Council is responsible for implementing much of the strategy through its Waste Plan. The waste management behaviour of households in our borough is best addressed through policies and action plans created by our recycling and waste services team. However, around a third of the UK's waste comes from the construction and demolition sector, which is an area where planning policy can have an impact. Construction waste should be reused and recycled where possible in line with the waste hierarchy.

Key Evidence

  • Guildford Environmental Sustainability and Climate Change Study (Guildford Borough Council, 2013)
  • Guildford Renewable Energy Mapping Study (Guildford Borough Council, 2015)
  • Assessment of the Viability of Carbon Emission Targets for New Builds (Guildford Borough Council, 2017)


Monitoring Indicators



Data source

Megawatts of installed small scale low and zero carbon energy capacity

Increase in capacity to reach UK average

Ofgem Feed in Tariff quarterly reports

Low and zero carbon decentralised energy networks

Increase in number

Planning applications and appeals

Average energy consumption/carbon emissions per household

Reduction in energy consumption/emissions to reach UK average

National statistics

No. of new dwellings complying with higher water efficiency standard

All new homes to comply with standard

Building regulations final certificates

Amount of waste sent for energy recovery/recycling

Increase in amount sent for recycling

National statistics




[28] UK local authority and regional carbon dioxide emissions national statistics: 2005-2012 (2013, DECC)

[29] Guildford Environmental Sustainability and Climate Change Study 2013