The Board received a presentation on Planning Policy delivered by Dan Knowles, Policy Officer – Planning Policy.
The Board heard that nationally, the had been an improvement in emissions from housing stock, significantly since 2014. A new house bult to 2014 standards would typically emit just over 3 tons of CO2 annually (a typical house was considered to be a three-bedroomed house). Since 2014, the grid had decarbonised and emissions from electricity had reduced significantly. Building regulations had changed recently in June 2022 and presently emissions for electricity were calculated to have dropped by 55% since 2013. There also been a moderate improvement to energy efficiency standards to new buildings driven by regulations, resulting in a 31% carbon reduction in new homes and a 27% reduction in non-residential buildings. The 2022 regulations also introduced a new measure, that of primary energy use. All new heating systems must be low temperature i.e. a heat pump. There were new standards for overheating. These new requirements had overtaken the Council’s current policies.
The Government had been promoting its standard for future homes which included 70-80% reduction in CO2 emissions against 2013 standards; further improvements to fabric standards; no new gas boilers would be installed in new homes and gas boilers banned from sale by 2035 and the national grid decarbonised by 2035.
Locally, the Local Plan – Strategies and Sites 2015-2034 (Local Plan Part One) was begun in 2013 and adopted in 2019.The relevant climate change policies were D2 (climate change and sustainable design), D1 (place shaping) and P4 (flooding, flood risk and groundwater protection). Policy D2 was most relevant as it concerned climate change adaptation and energy (low/zero carbon energy; heat networks; new buildings and energy hierarchy). In the borough of Guildford since 2019, on average there had been a 20% carbon reduction via Policy D2.
The energy hierarchy had been applied in Guildford. Developments had been benchmarked against one an other to understand what was achievable. It was anticipated that for dwellings a 10% carbon reduction was achievable against the 2013 standard on fabric alone. It had been more challenging to achieve a benchmark for apartments and non-dwellings, but the policy had been applied and developers were pushed to improve energy efficiencies.
The key issues for the borough would be high temperatures, increased rainfall and drought. Another ambition of D2 was to ensure developments were adaptive to these issues.
The Climate Change, Sustainable Design and Construction SPD was adopted in 2020 which set out clearly to developers what was required of them in terms of D2 and how carbon emissions should be calculated. It also provided guidance on good sustainable design. This document had a positive impact on the quality of submitted applications.
The Local Plan (Development Management Policies) Part two, was currently with the Secretary of State for examination. Within it there were four new policies that directly affected climate change: Policy D12 (Sustainable and low impact development); Policy D13 (Climate change adaptation); Policy D14 (Carbon emissions from buildings); Policy D15 (Renewable and low carbon energy generation and storage). And two peripheral policies that impacted less directly, which were biodiversity and transport. A 20% net gain in biodiversity in new developments was sought.
As well as developing policy, it was explained that the team provided support to Development Management. For example, reading energy statements and Site Waste Management Plans were often long and technical documents and it was important to make them to be properly understood and made accessible to decision makers. It was sometimes required for the team to undertake direct negotiation with developers to encourage them to improve energy and emissions plans. The team were also involved in appeals and keeping policies up to date.
The Climate Change Board discussed the following matters arising from the presentation:
1. With regard to wind turbines, it was noted that there was a national moratorium on construction, unless the turbines were included in a plan. However, any Local Plan process would be put through an examination process to compare its compliance with national policy. Therefore, it would be unlikely that a proposal for wind turbines would be acceptable. A survey had been undertaken in 2015 to look for renewable sites but the borough was constrained due to the vicinity of international airports and protected landscapes, alongside political considerations.
2. With regard to planning permission prior to the introduction of new building standard regulations. It was noted that if building control documents were submitted prior to the introduction of the new regulations the applicant would have a year to commence works under the previous regulations. If not commenced then new building control documents would need to be submitted and those documents would need to be in compliance with the new regulations. It was noted that large developments were unlikely to either have commenced and certainly not concluded within a year and consequently the new regulations would apply to at least some of the site. Very large developments may be constructed to varying standards as new regulations were introduced over time. An explanatory note would be circulated with the minutes.
3. It was acknowledged that the siting orientation of a building to either maximise exposure to solar for energy purposes and then alternatively providing shading during hot weather was problematic. No approach was mandated by the council and the decisions were up to the developer, but there where a number of options to consider. The angle of the eaves, deciduous tree planting and most effectively installing external shutters.
4. The new policy currently at examination didn’t mandate specific measures in regard to wildfire prevention, but developers building in areas at risk should demonstrate that it had been considered. Areas at risk were around the Thames Basin Heath and dry grass in the south of the borough. Anyone wishing to install a fire break could be subject to planning permission in residential areas. Planning permission covered construction, change of use and engineering works.
5. Subject to resources, there was a plan for a Green and Blue SPD in due course. A related key piece of work was the Local Nature Recovery Strategy (LNRS) which was a statutory requirement to be produced by Surrey County Council (SCC). The LNRS would inform the Green and Blue SPD.
6. It was noted that SCC had a buildings adaptation officer who was a specialist and local to Guildford. Ben would send Nat contact details.
7. The CCB should renew links with UNIS and it was hoped that Professor Nichol would be able to attend the next meeting.
8. An energy statement was required by the council when a planning application for a building came in. In the town centre the council asked for a TM59 which would assess and address overheating where the build was a block. For individual dwellings a Standard Assessment Procedure (SAP)was requested. This was the methodology used to assess and compare the energy and environmental performance of dwellings. If overheating was likely then the council would request measures to address it.
The slides for the presentation would be circulated with the minutes.