TESCO ASHTEAD

Proof of Evidence on Sustainable

Development/Sustainability

B T Mould MA (Oxon). MIEMA, C Env.

June 2010

Sustainability i
Personal Statement

1. Barrie Mould MA (Oxon). MIEMA, C Env. I am chemist by training with more than 35
years professional experience in a wide range of public and private sector roles.
Between 1983 and 1991, I worked in the environmental advisory team at the then UK
Department of Energy. Between 1988 and 1991, I led that team as a Senior Principal
Officer (unified grade 6). I was employed at Atkins Plc as an Environmental Consultant
from 1991 to 2006 and appointed as a Technical Director in 1994. I was appointed as the
Royal Academy of Engineering Visiting Professor in Engineering Design for Sustainable
Development at University of Brighton in 1998, and continue to act in that role at the
School of Environment and Technology at that University.
2. My relevant technical experience includes a wide range of environmental advice in
relation to major infrastructure projects such as 2012 Olympic Park Environmental
Impact Statement and the development of the National Environmental Action Plan for
Estonia. A significant element of my experience has been in relation to the
environmental impacts of energy related investments and the effectiveness of energy
efficient design in buildings and industrial processes. In the area of Sustainable
Development, I was the external advisor in the process of creating the Romanian
National Sustainable Development Strategy, and I was the sustainability advisor in the
team developing the Bahrain National Planning Development Strategy. For a period of
years I was an advisor to HM Prison Service on Sustainable Construction practices and
acted as Project Director and advisor for the CIRIA project “Sustainable Development
indicators for the Construction Industry”. For the last twelve years I have been teaching
about sustainable development issues to engineering undergraduates and on post
graduate MSc courses at the University of Brighton.
3. I am a long term resident of Ashtead having lived in the village since 1979. I have been
asked to provide this Proof of Evidence by members of the SAVE Group.

Scope of Evidence

4. In my evidence, I address the background framework to Sustainable Development in

21st Century UK. In particular I address some of the societal aspects of the concept of
sustainable development and in relation to that the principles of stakeholder
engagement and community consultation. I give my view on the issues that this raises in
terms of the manner in which the issue might appropriately have been tackled in relation
to the current supermarket planning application. I discuss the community engagement
statement that has been produced and highlight it shortfalls.
5. With regard to the matter of the sustainability of the construction proposed I indicate the
current national concerns about climate change and the impact of that energy use (both
heat and electricity) may have on climate change (one of the UK Government key
Sustainable Development issues). I set out the policy framework for reducing energy

Sustainability ii
 related emissions in both commercial buildings and homes. I indicate Tesco’s stated
corporate aims. I discuss the implications of these in terms of the standards of
performance that may be expected for a new supermarket and flats to be constructed in
2011. I compare the proposals made in the application (as set out in the associated
energy statement, BREEAM report and CSH reports) with the standards of performance
that might be expected and find them inadequate within a long term sustainability
framework.
6. Other witnesses will give evidence concerning the general impacts of the proposal on
the traffic and transport in the area (also part of the sustainable development priority
agenda). Also on other environmental impacts such as trees, all of which are relevant to
the Sustainable Development related areas of wellbeing and biodiversity.

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Glossary, Abbreviations

ASHP Air Source Heat Pump

BREEAM Building Research Establishment Environmental Assessment
Method
CHP Combined Heat and Power (normally in energy generation plant)
CO2 Carbon Dioxide
CSH Code for Sustainable Homes
GHG Greenhouse Gases
MVDC Mole Valley District Council
NOx Nitrogen Oxides
p.a. Per annum
SD Sustainable Development
SDS Sustainable Development Strategy
SecFut Securing the Future The UK Government Sustainable Development
Strategy (March 2005)

Sustainability iv
1. INTRODUCTION

1.1 Sustainable development is a pattern of resource use that aims to meet

human needs while preserving the environment so that these needs can
be met not only in the present, but also for future generations. The term
was used by the Brundtland Commission which coined what has become
the most often-quoted definition of sustainable development as
development that "meets the needs of the present without compromising
the ability of future generations to meet their own needs.”
1.2 The United Nations 2005 World Summit Outcome Document refers to the
"interdependent and mutually reinforcing pillars" of sustainable
development as economic development, social development, and
environmental protection.

www.search.com/ reference/

Sustainable_development

1.3 United Nations Conference on Environment and Development (Earth

Summit), held in Rio de Janeiro in June 1992, developed Agenda 21. The
number 21 refers to an agenda for the 21st century. Agenda 21 clearly
identified information, integration, and participation as key building blocks
to help countries achieve development that recognises these
interdependent pillars. It emphasises that in sustainable development
everyone is a user and provider of information. It stresses the need to
change from old sector-centred ways of doing business to new approaches
that involve cross-sectoral co-ordination and the integration of
environmental and social concerns into all development processes

Sustainability 1
2. SUSTAINABLE DEVELOPMENT/ SUSTAINABILITY

THE EU SUSTAINABLE DEVELOPMENT STRATEGY (EU SDS)

2.1 In July 2009 the Commission adopted the 2009 Review of EU SDS. It
underlines that in recent years the EU has mainstreamed sustainable
development into a broad range of its policies. In particular, the EU has
taken the lead in the fight against climate change and the promotion of a
low-carbon economy.

2.2 Sustainable development is set out in the Lisbon Treaty as the overarching
long-term goal of the EU. The Sustainable Development Strategy of the
European Union (EU SDS), as revised in 2006, is a framework for a long-
term vision of sustainability in which economic growth, social cohesion and
environmental protection go hand in hand and are mutually supporting.

2.3 The Renewed EU Sustainable Development Strategy as adopted by the

European Council on 15/16 June 2006 set out the commitment to
Sustainable Development as shown in the box below.

RENEWED EU SUSTAINABLE DEVELOPMENT STRATEGY

OUR COMMITMENT TO SUSTAINABLE DEVELOPMENT (Pg1)

Sustainable development means that the needs of the present generation should be met
without compromising the ability of future generations to meet their own needs. It is an
overarching objective of the European Union set out in the Treaty, governing all the Union’s
policies and activities. It is about safeguarding the earth's capacity to support life in all its
diversity and is based on the principles of democracy, gender equality, solidarity, the rule of
law and respect for fundamental rights, including freedom and equal opportunities for all. It
aims at the continuous improvement of the quality of life and well-being on Earth for present
and future generations. To that end it promotes a dynamic economy with full employment
and a high level of education, health protection, social and territorial cohesion and
environmental protection in a peaceful and secure world, respecting cultural diversity.

2.4 Amongst others issues it also sets out the following objectives:
• Social Equity And Cohesion Promote a democratic, socially inclusive, cohesive,
healthy, safe and just society with respect for fundamental rights and cultural
Diversity that creates equal opportunities and combats discrimination in all its
forms.( Pg4)
• Open and Democratic Society Guarantee citizens’ rights of access to information
and ensure access to justice. Develop adequate consultation and participatory
channels for all interested parties and associations.(pg4)
• Make Polluters Pay Ensure that prices reflect the real costs to society of
consumption and production activities and that polluters pay for the damage they
cause to human health and the environment.(pg5)
2.5 The Review “Mainstreaming Sustainable Development into EU policies:
2009 Review of the European Union Strategy for Sustainable
Development” also includes the following statement on issues for business
action.

Sustainability 2
 “Corporate Social Responsibility (CSR) is an opportunity for enterprises to
combine economic, social and environmental objectives. Greater
commitment to CSR on the part of European enterprises will enhance
Europe's capacity for sustainable development. The Commission and many
EU Member States have intensified their efforts to promote the uptake of
CSR, with the emphasis on dialogue between stakeholders.” (Pg3)

UK BACKGROUND SD GENERAL

2.6 The UK Government and devolved governments are pursuing the goal of
sustainable development - “to enable all people throughout the world to
satisfy their basic needs and enjoy a better quality of life, without
compromising the quality of life of future generations”.

2.7 This is anticipated to be in an integrated way through:

• a sustainable, innovative and productive economy that delivers high levels

of employment;
• a just society that promotes social inclusion, sustainable communities and
personal wellbeing;
• protection and enhancement of the physical and natural environment, and
efficient use of resources and energy
• promotion of a clear understanding of, and commitment to, sustainable
development so that all people can contribute to the overall goal through
their individual decisions.

2.8 The Government’s overarching strategy for sustainable development is

detailed in Securing the Future (March 2005). The following ‘purpose’, was
agreed by the UK Government and the Devolved Administrations, and was
adopted as the framework goal for sustainable development:

Securing the Future

The goal of sustainable development is to enable all people throughout the world to
satisfy their basic needs and enjoy a better quality of life, without compromising the
quality of life of future generations.

For the UK Government and the Devolved Administrations, that goal will be pursued in an
integrated way through a sustainable, innovative and productive economy that delivers
high levels of employment; and a just society that promotes social inclusion, sustainable
communities and personal wellbeing. This will be done in ways that protect and enhance
the physical and natural environment, and use resources and energy as efficiently as
possible.

Government must promote a clear understanding of, and commitment to, sustainable
development so that all people can contribute to the overall goal through their individual
decisions.

Similar objectives will inform all our international endeavours, with the UK actively
promoting multilateral and sustainable solutions to today’s most pressing environmental,
economic and social problems. There is a clear obligation on more prosperous nations
both to put their own house in order, and to support other countries in the transition
towards a more equitable and sustainable world.

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 2.9 The Government set out five key issues for the Strategy all of which are
relevant to this Planning Application:

• Living Within Environmental Limits - Respecting the limits of the planet’s

environment, resources and biodiversity – to improve our environment and
ensure that the natural resources needed for life are unimpaired and remain
so for future generations.
• Ensuring a Strong, Healthy and Just Society - Meeting the diverse needs
of all people in existing and future communities, promoting personal
wellbeing, social cohesion and inclusion, and creating equal opportunity for
all.
• Achieving a Sustainable Economy - Building a strong, stable and
sustainable economy which provides prosperity and opportunities for all, and
in which environmental and social costs fall on those who impose them
(polluter pays), and efficient resource use is incentivised.
• Promoting Good Governance - Actively promoting effective, participative
systems of governance in all levels of society – engaging people’s creativity,
energy, and diversity.
• Using Sound Science Responsibly - Ensuring policy is developed and
implemented on the basis of strong scientific evidence, whilst taking into
account scientific uncertainty (through the precautionary principle) as well as
public attitudes and values.
2.10 Chapter 4 of Securing the Future is entitled “Confronting the Greatest
Threat: Climate Change and Energy”. It sets out the UK approach (Pg 73)
to this as:

• Sustainable development and climate change are two vitally important and
interrelated challenges facing us in the 21st century. Our ability to develop
more sustainably will determine the speed and degree of climate change we
experience. And as the climate changes the choices available to us to
develop sustainably will change.
• We need to significantly reduce our greenhouse gas emissions – at home,
at work and when travelling, so that we can change the course of climate
change. Furthermore, some climate change is now inevitable due to our
past greenhouse gas emissions.
• We need to adapt – at the same time as we act to reduce emissions – to
better manage the future impacts of climate change on the environment,
economy and society.
2.11 To fit with this the UK now has Sustainable Development aims of reducing
the UK CO2 emissions by 80% by 2050.

2.12 Securing the Future also identifies wellbeing as being at the heart of
sustainable development.

2.13 The UK Strategy sees a key role for Business in Sustainable Development
as outlined in the box below.

Role of Business in Sustainable Development

Business has a key role in sustainable development – by taking account of their economic,
social and environmental impacts, tackling the key sustainable development challenges, and
generating wealth and jobs. This runs through all four priorities and is highlighted in each of the
chapters.

Business investment, enterprise and trading are essential in creating the wealth to tackle
poverty and other social challenges, at home and abroad. Government has an important role to
play through active economic, social and environmental policies that support or stimulate
action. But ultimately it is the action taken by businesses themselves that will deliver a supply
Sustainability 4
of products and services that are clean, resource-efficient, and fair to employees and
communities. These include:

•
 2.14 The UK Strategy also sets a high value on Community engagement in
developing the vision for the long term sustainable future:

Community engagement should be central to the process of drawing up the

local statutory strategic plans for the area, such as the local development
documents, including area actions plans in the Local Development
Framework (LDF), the Sustainable Community Strategy, and the Local Area
Agreement (LAA) as well as to solving public problems. Community buy-in is
essential in achieving local ownership of and legitimacy for these plans, which
will shape the long-term vision and the future distribution of land and
development in an authority’s area. Local action-planning, for example by
voluntary groups, in the shape of parish plans, neighbourhood action plans,
and other forms of participative involvement, offers an effective way of
engaging local citizens and communities in contributing to those processes.
(pg 127).

2.15 The UK Government as a result of the 2004 “Taking It On” consultation,

which was aimed at helping develop the UK SD strategy, identified the
following as the main priority areas for immediate action:

• Active, inclusive and safe - Fair, tolerant and cohesive with a strong local
culture and other shared community activities.
• Well run - with effective and inclusive participation, representation and
leadership.
• Environmentally sensitive - providing places for people to live that are
considerate of the environment.
• Well designed and built - featuring a quality built and natural environment.
• Well connected - with good transport services and communication linking
people to jobs, schools, health and other services.
• Thriving - with a flourishing and diverse local economy.
• Well served - with public, private, community and voluntary services that
are appropriate to people's needs and accessible to all.
• Fair for everyone - including those in other communities, now and in the
future
• From local to global: building sustainable communities creating places
where people want to live and work, now and in the future.
• Climate change and energy - confronting the greatest threat.

2.16 The UK SD Strategy therefore focused on the need to enable, encourage

and engage people and communities in the move toward sustainability (Pg
26).

2.17 The Government saw, as part of its aim, the creation of sustainable
communities that embody the principles of sustainable development at the
local level. This would involve working to give communities more power
and say in the decisions that affect them; and working in partnership at the
right level to get things done.

2.18 It saw that action by citizens and communities is central to the

implementation of this new approach. Government has already recognised
this in its broader commitment to community engagement (Pg 27). To this
end is moved forward with the programme “Community Action 2020 –
Together We Can” As part of the actions of this it saw engagement as a

Sustainability 5
 key action to provide opportunities for community involvement in
Sustainable Community Strategies and local action plans such as parish
plans, neighbourhood plans, housing and planning policies.

UK BACKGROUND CLIMATE CHANGE ASPECTS OF SD

2.19 In November 2009, the Department for Communities and Local

Government issued a consultation document “Zero carbon for new non-
domestic buildings Consultation on policy options”. A number of relevant
key statements from the document are set out in the box below.

“The Government believes that it is right to regulate to reduce the carbon emissions of new
non-domestic buildings because there is sufficient evidence to show that the market, even
with the influence of market-focused policies like the EU Emissions Trading Scheme (EU
ETS) and the CRC, will not make this change alone.”

“As the price of energy rises, the cost of running less efficient buildings will increase
significantly, but by then it will be too late (or much more costly) to change the building, since
the technologies will be ‘locked in’. Therefore there is a strong argument for regulating at the
point of build. In this light, the zero carbon ambition for new non-domestic buildings, as for
homes, will be based on the following key features:

• zero carbon is essentially a design or ‘point of build’ standard that will be

assessed when a building is signed off. Ensuring buildings are able to be
operated to their full potential design potential – and that this actually happens
– are important issues.”

“The case for regulation at the design and build stage is:
• structures and technologies are ‘locked in’ for the lifetime of the building – action
at this stage can reduce future, often more complex and expensive, ‘retrofit’
needs
• the fact that building owners and occupiers (who dictate the market sale or rental
value of new buildings) do not have long-term knowledge about future energy
price rises means that market mechanisms (e.g. cap and trade schemes) do not
fully incentivise the necessary actions
• the market is not driving low carbon buildings through a price premium, certainly
not yet
• energy costs of commercial buildings are often a small proportion of the
organisation’s total cost base – so incentives for low carbon construction
approaches, even where rational, are not always sufficiently strong
• innovation in reducing emissions from new non-domestic buildings could have a
spill-over demonstrator effect, influencing best practice and cost of retrofit
• regulation can reduce cost by increasing demand and certainty – for example in
stimulating new markets for new technologies or low and zero carbon generation
schemes.”

2.20 The document argues that the reasons for setting a high level of energy
efficiency for non-domestic buildings are exactly the same as those for
homes namely:

• “Whole life cost: in general, energy efficiency measures will often entail lower
life-cycle costs than low and zero carbon technologies (fuel, maintenance,
replacement). Because those cost differentials may not be fully reflected in the
market price of the building, the developer might, in the absence of a minimum

Sustainability 6
 energy standard, choose a carbon compliance strategy which does not minimise
whole life costs”.
• “Robustness: energy efficiency measures are less dependent than low and
zero carbon technologies upon the behaviour of occupants in order to realise
carbon savings. For example, occupants cannot easily ‘turn off’ the insulation in
an exterior wall, and will not need to service or replace that insulation in order to
maintain its effectiveness. That is not equally true of low and zero carbon
technologies”.

• “Future-proofing: buildings are long-lived assets (although non-domestic

buildings tend to be renovated more frequently than homes), and the cost of
retrofitting is high. It may therefore be appropriate to seek an energy efficiency
standard which we will not regret at a later date, once the implications of long-
term carbon reductions and energy security are better understood. At the same
time, future-proofing also means building to a standard which we will not regret
in terms of climate change adaptation (in particular overheating)”

CONSULTATION ON A PLANNING POLICY STATEMENT: PLANNING FOR

A LOW CARBON FUTURE IN A CHANGING CLIMATE

2.21 Addressing climate change is one of the Government’s principal concerns

for sustainable development. In July 2007 the Government’s “Building a
Greener Future: Policy Statement” announced that all new homes will be
zero carbon from 2016.

2.22 The Climate Change Act 2008 introduced a statutory target of reducing
carbon emissions by 80 per cent below 1990 levels by 2050, with an
interim target of 34% by 2020. The Low Carbon Transition Plan and the
Renewable Energy Strategy were both published on 15 July 2009 and set
out how the UK will achieve dramatic reductions in emissions and meet
targets on renewables.

2.23 The UK Government in December 2007 issued Planning Policy Statement

(PPS): Planning and Climate Change supplement to PPS 1 and it begins
thus by putting Sustainable Development as an overarching policy aim with
climate change and a low carbon economy as being two material issues to
be taken into account in planning decisions.

“Planning Policy Statement: Planning and Climate Change

“Planning Policy Statements (PPS) set out the Government’s
national policies on different aspects of spatial planning in
England. PPS1 sets out the overarching planning policies on the
delivery of sustainable development through the planning
system.
“This PPS on climate change supplements PPS1 by setting out how
planning should contribute to reducing emissions and
stabilising climate change and take into account the
unavoidable consequences. It does not seek to assemble all
national planning policy relevant or applicable to climate
change and should be read alongside the national PPS/G series.
Where there is any difference in emphasis on climate change
between the policies in this PPS and others in the national
series this is intentional and this PPS takes precedence.
Tackling climate change is a key Government priority for the

Sustainability 7
 planning system. The ambition and policies in this PPS should
therefore be fully reflected by regional planning bodies in the
preparation of Regional Spatial Strategies, by the Mayor of
London in relation to the Spatial Development Strategy in
London and by planning authorities in the preparation of Local
Development Documents. Similarly, applicants for planning
permission should consider how well their proposals for
development contribute to the Government’s ambition of a
low-carbon economy and how well adapted they are for the
expected effects of climate change. Applicants and planning
authorities should bear in mind that the policies in this PPS are
capable of being material to decisions on planning
applications”.
2.24 To help further develop the ability of the UK to move forward with these
plans, in March 2010, the UK Government (Department for Communities
and Local Government) issued a Consultation Paper “Consultation on a
Planning Policy Statement: Planning for a Low Carbon Future in a
Changing Climate”. The purpose of the consultation was to get stakeholder
views and comments on the new draft planning policy which combines and
updates the existing planning policy statements on climate change (PPS1
supplement) and renewable energy (PPS22). The Consultation paper sets
out in the introduction the importance of climate change issues in the
planning system.

“In December 2007, the Government published Planning Policy Statement

(PPS): Planning and Climate Change supplement to PPS 1. This placed
tackling climate change at the heart of planning. Its cross-cutting importance
was signalled by making it a supplement to PPS 1: Delivering Sustainable
Development, which sets out the overarching planning policies on the
delivery of sustainable development through the planning system.”
2.25 Paragraph 9 of the Consultation sets out the reasoning for the proposed
consolidation of planning statement namely:

“One of the central challenges for planning is to respond to, and integrate
with, the Government’s ambitions to tackle climate change. Planning makes a
significant contribution to both mitigating and adapting to climate change
through its ability to influence the location, scale, mix and character of
development. The draft PPS sets out how planning, in providing for the new
homes, jobs and infrastructure needed by communities, should help shape
places to achieve lower carbon emissions and greater resilience to the
impacts on climate change. The planning system sets out the overall
framework for development. This should help secure progress against the
UK’s emissions targets, both by direct influence on energy use and emissions
through, for instance, encouraging energy efficiency, and through bringing
together and encouraging actions from others. Planning should give local
communities real opportunities to take action on climate change and should
be doing so now”.

2.26 Paragraph 12 of the Consultation states:

“Planning low carbon communities requires joined-up working. This includes

taking account of the raft of work taking place in and around the planning
community. For example, the proposed changes to energy efficiency and
carbon standards in Part L of the Building Regulations (see proposed policy
LCF8.1); the Government’s target for new homes to be zero carbon from
2016 and ambition for new non-domestic buildings to be zero carbon from
2019 ….. All of these initiatives are designed to cut green house gas
emissions and planning needs to ensure that it integrates with, not

Sustainability 8
 duplicates, these initiatives to achieve the most sustainable outcome
possible.”
.
2.27 In the Consultation it states that the Government:

“expects planning to continue to provide for the development needs of all in the
community, contribute to housing supply and economic growth and support
social justice. Planning should also continue to sustain biodiversity and
protect natural and historic environments. All planning strategies, and the
decisions taken in support of them, must however reflect the Government’s
ambition to help business and communities build a low carbon future and
prepare for the impacts of climate change. Plan-making and development
management should fully support the transition to a low carbon future in a
changing climate”.

2.28 Further relevant extracts from the Consultation are set out in Annex B.

2.29 Greener Homes for the Future, (published by the Department for
Communities and Local Government). In 2006 the Government announced
a 10-year timetable towards a target that all new homes from 2016 must
be built to zero carbon standards, to be achieved through a step by step
tightening of the Building Regulations. From April 2008, all new social
housing must be built to a minimum of Code level 3. The Code 3 standard
is currently voluntary for privately built housing.

Date 2010 2013 2016

Code Level level 3 level 4 level 6
Energy efficiency improvement 25% 44% Zero
of the dwelling compared to 2006 carbon
(Part L Building Regulations)

2.30 The 'Merton Rule' planning policy, pioneered by the London Borough of
Merton, in 2003 which requires the use of on site renewable energy to
reduce CO2 emissions in the built environment. Most local authorities have
followed Merton's lead, which now affects planning permission for all new
major development projects throughout the UK. The Merton Rule is a
prescriptive planning policy that requires new developments to generate at
least 10% of their energy needs from on-site renewable energy equipment.
The most commonly accepted threshold is 10 homes or 1,000 m2 of non-
residential development. This is the accepted definition by local (and
regional) planning authorities, academic institutions, trade and professional
bodies, and the development, construction and engineering industries.

MOLE VALLEY CORE STRATEGY – ISSUES RELEVANT TO

SUSTAINABLE DEVELOPMENT

2.31 Mole Valley District Council issued it adopted its new Core Strategy in
October 2009. It has a number of statement, related document and policies
associated with it that relate to Sustainable Development (e.g. CS12 and
CS19). Those that are of particular relevance relate to Community
consultation (based on the associated Statement of Community
Involvement) and Sustainable Construction, Renewable Energy and
Energy Conservation.

Sustainability 9
 2.32 One aim of the Strategy is to require development to reduce its impact on
the climate and environment, to use natural resources wisely, and reduce
emissions that contribute to climate change. Relevant paragraphs are in
the box below.

7.3 Sustainable Construction, Renewable Energy and Energy Conservation

7.3.1 Ensuring that we are living within the environment's limit is a key principle of
sustainable development. A major challenge in achieving this objective is however,
addressing the issue of and effects from climate change.

7.3.2 In a bid to tackle climate change and the effects, the UK has signed up to the Kyoto
Protocol and made a commitment to cut greenhouse gas emissions by 12.5% on 1990
levels by 2012. In addition, the Government has committed to go beyond the Kyoto
Protocol and reduce carbon dioxide emissions by 20% on 1990 levels by 2010 and in the
longer term to make real progress towards a reduction of 80% by 2050

2.33 The Council sees this part of the strategy being delivered as set out in the
box below.

7.3.3 As part of tackling climate change and reducing carbon dioxide emissions,
Government is tightening the Building Regulations to bring about a 20% reduction is carbon
emissions from new housing by 2010 and nearly 50% by 2013, in order to achieve zero
carbon residential development in 2016. In accordance with national and regional guidance
this objective should be supported by the planning system.

7.3.4 Alongside ensuring that development is provided in sustainable locations, the Council
proposes that the causes and effects of climate change are reduced and mitigated against
by introducing sustainable construction; renewable energy; and energy conservation
principles into new development. New development and the redevelopment and
refurbishment of the existing building stock can help tackle the causes of climate change
through reducing the reliance on energy sources that generate greenhouse gases such as
carbon dioxide. It can help mitigate the impact of new development on the causes of
climate change through, for example, careful design and efficient resource use. This is
highly relevant considering the long life span of developments.

2.34 To support this, the Council adopted a core strategy Policy CS19.

Policy CS 19
Sustainable Construction, Renewable Energy and Energy Conservation

1. In order to support the Core Strategy's overarching aim of achieving sustainable

development, and to reduce the causes of and effects of climate change, new
buildings and the redevelopment and refurbishment of the existing building stock
will be required to:

a. minimise energy use through its design, layout and orientation;

b. maximise on-site recycling facilities and the re-use and recycling of
materials used in construction; and
c. meet at least Level 3 of the Code for Sustainable Homes for housing, or
BREEAM 'Very Good' construction standards for all other development, or
higher as dictated by future legislation and guidance (Code Level 4 from
2013 and Code 6 by 2016). This must include a 10% reduction in total carbon
emissions through the on-site installation and implementation of
decentralised and renewable or low-carbon energy sources.

Sustainability 10
 2. Applicants will be required to submit evidence to demonstrate how these
requirements have been met unless it can be demonstrated that compliance is
not technically or financially achievable having regard to the type of development
involved and its design.

3. The Council will explore the opportunities for decentralised and renewable or low-
carbon energy sources within the District.

2.35 MVDC sets out the standards it believes necessary to move forward on
this issue in Paragraph 7.3.8 of the Core Strategy: “It is therefore
considered as well as all new homes meeting at least Level 3 of the Code
for Sustainable Homes, all other development should meet the BREEAM
'Very Good' construction standards, or higher as dictated by future
legislation and guidance”.

2.36 Further relevant paragraphs from the Core Strategy document are
presented in Annex A to this document. The cover expected construction
standards, reducing carbon emissions, and the means of implementing
and monitoring the policy. A key statement relating to Sustainable
Development appears in Paragraph 7.3.12.

“To achieve the Council’s overarching objective of creating sustainable

developments and to reduce the causes of and effects from climate change,
carbon emissions from new buildings should be reduced by at least 10%.”

2.37 Core Policy CS12 on Sustainable Economic Development sets out that
The sustainable growth of the District's economy will be supported
through the provision of a flexible supply of land to meet the varying needs
of the economic sectors . Of relevance to the Tesco application are the
first two of the eight elements noted namely:

• “Safeguarding and recycling accessible and well located industrial and

commercial sites which will be identified through the Development
Management Development Plan Document.”
• “Encouraging, where appropriate, mixed use development”.

STATEMENT OF COMMUNITY INVOLVEMENT

2.38 As part of the Local Development Framework there was a statutory

requirement for MVDC to prepare a Statement of Community Involvement.
The Statement of Community Involvement (February 2010) sets out how
the Council intends to work with stakeholders in the preparation and
revision of planning policies and guidance that will make up the Local
Development Framework. It also sets out the arrangements for community
participation and public consultation in the determination of planning
applications.

2.39 Some key paragraphs of the introductory section are included in the box
below. These highlight MVDC’s desire to involve communities in planning
issues and discussion and clearly imply an open and active engagement.
The indication is that early involvement of communities in the planning
process is vital for the effective decision making.

1.11 The Council aims to strengthen community involvement in planning by ensuring

that it adopts a continuous, active and open approach which values the
contributions of a wide range of people and organisations. It aims to make the
Sustainability best use of its resources11to inform, listen and involve people effectively. This
will include providing feedback.
 2.40 This theme is further developed in Chapter 4 of the Statement of
Community Involvement. It sets the process of community involvement
firmly in the framework of sustainable development (see Paragraph 4.1 in
the quote below). It puts an onus on the Council and the prospective
applicant of significant developments (both applications from Tesco fit the
criteria for significance) to consult with stakeholders including the local
community.

Chapter 4 Community Involvement in Planning Applications

4.1 The Statement of Community Involvement must also set out the Council's
policy for involving the community in the determination of planning
applications, this includes applicants, applicants, local residents,
representative bodies and other stakeholders. ……. It puts spatial
development plans, including the Local Development Framework, into action
and seeks to achieve good design and sustainable development.

4.3 The Council aims to publicise and consult on the applications it receives, in a
manner appropriate to the specific type of application. It seeks to ensure that
interested parties are made aware of proposed development that could affect
them, so that they have the opportunity to make comments on applications.
These will be taken into account when the application is determined.

4.8 However the Council does encourage all applicants to discuss their proposals
with those who may have an interest in them before submitting an pplication.
For the smallest application, this might be an informal discussion with
the neighbours, although for a significant application, wider community
discussion, displays and exhibitions might be appropriate. This promotes a
better understanding of the proposal and can identify issues and problems
very early on, as well as ensuring the input of the community to make
appropriate changes to the scheme at an early stage.

4.9 The Council will expect prospective applicants for significant development to
consider the benefits of carrying out pre-application consultations, ……….

4.10 The Council will encourage applicants for significant developments to submit,
with their application, a public consultation statement setting out the
measures they have taken to consult the community on their proposals before
finalising their submitted scheme.

3. SD PRINCIPLES AND THE APPLICATION

Sustainability 12
 SOCIAL ISSUES - CONSULTATION AND COMMUNITY ENGAGEMENT

3.1 Within the framework of SD, the process of community consultation is seen
to be vital and a two way process. MVDC recognises this in its Core
Strategy.

3.2 The Statement of Community Involvement supporting the second

application was produced on behalf of Tesco by G L Hearn. It sets out that:

“Tesco is fully aware that the Council suggests that applicants for major schemes
should where possible usually undertake a programme of public consultation.
Appendix 2 sets out the public consultation that was undertaken previously
by Tesco for the larger scheme.

“Due to the obligations placed on Tesco to submit the planning application as soon as
possible following the submission of the planning appeal ( and the appeal
being placed in abeyance and the need for the new application to be
considered by the start of early February 2010) there has been limited time to
undertake a programme of consultation similar to that which was undertaken
previously. Despite this Tesco is keen to ensure people are aware of the new
proposals.

“It is acknowledged by Tesco that the previous planning application attracted

significant interest from the Council and the residents of Ashtead. Many
issues were raised during the previous planning application submission and
consultation process and these were then identified in the letters received by
the Council and subsequently highlighted in the Council’s Planning
Committee report and the also the decision notice that followed.

“To include residents and groups of interest who made representations o n the
previous application, Tesco have issued a flyer to all relevant groups, bodies
and people advising them of the new application and the significant changes
between the two schemes. This flyer has been issues to tie in with the formal
submission of the planning application and provides a list of key changes and
also provides a web address where anyone can view the scheme and make
comments.”

3.3 The Statement also notes that:

“If Tesco or their consultant team need to or are requested to meet with local groups
and bodies or members of the public or Councillors to explain the proposals
in more detail this is something Tesco would be willing to undertake.”

3.4 The process adopted by the applicant has very little of a two way
engagement and consultation element in at all. In relation to the second
planning application, there seems to have been one public meeting with
the community and that was after the planning application had been
submitted.

3.5 There are many public bodies that have issued Guidance on the process
of Consultation (e.g. Suffolk County Council - Consultation and
Engagement Guidance) and there is a clear thread that runs through them.

3.6 Consultation and engagement is a two way process. It involves informing,

listening and responding. It is also about asking people/customers/
stakeholders what their views and opinions are on issues and
developments that affect them, their families, and their wider work and
social communities.

Sustainability 13
 3.7 The key advantage to holding a public meeting is that it is a two way
process that can give members of the public the opportunity to give their
views and seek answers. It also offers an opportunity to present to the
public a high level or detailed overview of the subject you are consulting
on.

3.8 As a general rule Consultation and engagement methods can be split into
two groups, Quantitative (such as surveys) and Qualitative (Interviews,
focus groups etc). Using a Quantitative approach, i.e. surveys, gives
statistical information using a sample drawn from the whole population or
group. If a sample has been drawn using statistically reliable methods then
it could be possible to extrapolate this out to the population as a whole.

3.9 A qualitative approach i.e. interviews and focus groups offer a much more
interactive experience and should be used to gain a more detailed
understanding of issues than the more simplistic answering, the "how" and
"why" questions that shape quantitative work. As a smaller number of
peoples views are being sort qualitative consultation cannot provide
statistically reliable results. However it is more likely to provide a rounded
view on why opinions and views are held. The two approaches can
compliment each other and if possible the best method may be using a
combination of both.

3.10 The applicant was well aware of the community’s overall concerns and
feelings about the proposed development as a result of the first application
receiving a significant number of objections from the public.

3.11 In relation to the second application there has been shown to be a very
significant public reaction with over 1000 objections and then the petition
against the development that was signed by over 6000 residents of the
village. The Company’s response was to provide a single information flyer
delivered to the homes in the village at the time of the application was
made.

CLIMATE CHANGE ISSUES

3.12 The UK commitment is to reduce CO2 emissions by 80% by 2050 being

set out in the UK Climate Change Act which became law in November
2008. The Act sets legally binding targets for the UK to reduce greenhouse
gas emissions by at least 80% by 2050, and CO2 emissions by at least 26
per cent by 2020, both set against a 1990 baseline.

3.13 Tesco’s Sir Terry Leahy, gave a speech at the SCI Conference at the Royal
Society in London in October 2009 where he is quoted as saying:

“We wanted new stores and other buildings constructed between 2007 and
2020 to emit on average no more than half the CO2 of an equivalent store
built before 2007. We have built environmental stores in every country in
which we operate, each time cutting emissions more than the last. Our
Cheetham Hill store in Manchester cut emissions by 70 per cent compared to
a standard store in 2007. Last month we opened our first environmentally
LEED Gold-rated store in the US. Next month we will open in Ramsey in
Cambridgeshire our first zero-carbon store: a clear sign that supermarkets, in
their direct operations, can be low-carbon exemplars.”
3.14 Tesco’s in their Planning Statement (paragraph 3.47) sets out:

“Tesco place significant importance and investment on sustainability and energy

efficiency measures which are detailed in submissions prepared by Scott
Wilson, there being an Energy Statement, Code for Sustainable Homes Pre-

Sustainability 14
 assessment, BREEAM pre-assessment and covering letter to the latter two
documents. The requirements have changed since the previous application
due to very recently adopted planning policy by the Council in terms of the
Core Strategy.”

3.15 The Energy Report indicates that used best practice principles to create a
sustainable energy solution saving 19% total CO2 over a Part L compliant
building, with a 4% reduction in CO2 attributed to onsite renewable energy
generation. Scott Wilson carried out the energy assessment of energy
efficiency, low carbon and renewable technology options and compared
this with a base case.

Summary of Scenario CO2 emissions CO2 savings over CO2 savings

Solar Hot System description (tonnes p.a.) base case over base case
Wa t e r (tonnes p.a.) (%)
a n d
A S H P
470 - N/A N/A
Systems Energy Efficiency 397 - 73 16%
for the
Building 150 kWth Retail ASHP 385 85 18%
system
Residential ASHP 382 88 19%
system 5 x units
20 m2 panel area 380 90 19%
to serve 4 x units

3.16 The proposed option incorporates energy efficiency measures – increased

insulation, glazing and lighting efficiency and renewable energy sources –
an Air Source Heat Pump (ASHP) system and solar hot water (SHW).

3.17 The Code for Sustainable Homes report sets out that the 9 flats will
achieve a Code Level 1 rating. The pre-assessment gives indicative scores
ranging between 41.73% - 43.91%. Taking all these factors into account,
the CSH pre-assessments predict a CSH 1 star rating, with the potential to
rise to a high CSH 1 star rating (for Level 1, the score needs to be
36%points; Level 2, 48 points; and Level 3, 57 points).

3.18 In the energy section of the assessment, the dwellings score a maximum
of 12 out of 29, with particular low performance on the emission of CO2
compared to the Target Emission Rate – 2 out of 15. In the materials
section they score 10 out of 24. In the Health and Wellbeing section they
score 1 out of a possible 12 points. It is recognized that with the site
developed as planned there will be no points available for ecology (0 out of
9 possible points).

3.19 In the view of Scott Wilson, it impossible for the 9 flats to achieve Code
Level 3. Scott Wilson suggests that, if the number of flats were reduced to
7, then they should be able to achieve Code Level 2.

3.20 Scott Wilson has also undertaken a BREEAM assessment of the

supermarket proposal and this reveals a BREEAM “Good” rating with a
score of 50.48%. (Good requires 45% and Very Good required 55%).
There are some significant variations revealed in the scores assessed in
different parts of process – the proposal scores only 48.15% for the energy
part of the assessment; 20% for innovation and 12.5% for waste. The
Table below shows some of the poorer areas of performance.

Sustainability 15
 Category Available Score P r o p o s e d
Development
Score
Reduction of CO2 15 5
Low/Zero Carbon Technology 3 1
Cold Storage Equipment 3 1
Material Specification 4 1
Responsible Sourcing of materials 3 0
NOx emissions 3 0
Innovation in CO2 emissions 2 0
Innovation Low/Zero Carbon 1 0
reduction techniques
Innovation - materials 2 0
.
3.21 In the last year Tesco’s have publicised the opening of new stores at
Ramsey and Cheetham Hill. The Ramsey store has been independently
assessed as “excellent” according to the BREEAM rating system.
Cheetham Hill has been independently assessed and awarded a BREEAM
score of ‘very good’.

Sustainability 16
4. CONCLUSIONS - SUSTAINABLE DEVELOPMENT.

4.1 Tesco considers that its proposal accords to the principles of PPS1 by
promoting sustainable development.

4.2 In Tesco’s 2009 Corporate Social Responsibility Report the following

statement appears:

“We listen to people in the community from the moment we identify a site for a new
store or an extension. We want to respond to suggestions and concerns
people might have. This does not stop once the store is open – when people
tell us deliveries are creating congestion we act to adjust delivery times so
they do not clash with busy periods such as the school run. This also helps to
consolidate deliveries of our own and suppliers’ products to Express stores in
the UK, which are in busy urban areas.” (Pg 20 Tesco CSR Report 2009)

SOCIAL – COMMUNITY ENGAGEMENT

4.3 On the basis of the lack of community engagement and consultation this
proposed development cannot be said to meet one of the key social
criteria of Sustainable Development. For the long term sustainability of any
such project, there is a need to take into account the views of the
community in which it is to be located. To take these views into account,
there needs to be a constructive dialogue and appropriate compromises
and concerns openly discussed and agreed. This has not happened in this
case and Tesco has failed to deliver what it claims to do on its own CSR
Report.

CLIMATE CHANGE

4.4 Sustainable Development is part of the process of “future proofing”, as far

as is sensible and practical, the society that we continue to develop. This
means looking beyond the next few years and on into the medium term
future. Elements of the construction proposed will have a design life of
between 40 and 60 years so that is the time frame in which the relevant
planning should be set. In that period, the UK has committed to reducing
CO2 emissions by 80%.

4.5 Energy Statement shows only 4% reduction in CO2 from onsite resources.
It fails to meet MVDC CS 19 policy or the well known, long established and
widely accepted Merton Rules. The dwellings only achieve Code Level 1
within the CSH, while MVDC CS19 looks for a minimum of Level 3
currently, and the HMG timetable looks to require Level 4 by 2013.

4.6 Scott Wilson’s view that better CSH and BREEAM ratings are not possible
on the site with the current proposal is not an argument to accept that the
current proposal is the best that can be done, and therefore accepted, but
rather that the current proposal is faulty and needs to be re-examined to be
able to provide suitable (and achievable) long term (future proofing)
performance. Tesco has shown that it can be done. Ramsey store has
been independently assessed as “excellent” according to the BREEAM
rating system. Cheetham Hill has been independently assessed and
awarded a BREEAM score of ‘very good’.

Sustainability 17
 4.7 Maximising the energy efficiency of building fabric and systems reduces
the overall demand for energy, before further steps are taken to meet the
remaining demand through on-site or off-site activity. This is best achieved
at the design and build stages. As with homes, the Government wants to
set energy efficiency standards for non-domestic buildings that are at the
highest practicable level.

4.8 In my view this proposal is a retrograde step, it fails to move towards

Tesco’s own commitment as set out by Sir Terry Leahy nor the commitment
on the Tesco 2010 CSR Report web pages “new stores built between
2007 and 2020 to emit half the CO2 of a 2006 new store” http://
cr2010.tescoplc.com/environment.aspx , nor MVDC’s CS19 policy and
provides no future proofing.

4.9 Fundamental design change is required to meet BREEAM Very Good or

Excellent rating – but this should be the aim. This has not been done.
Many of the proposed measures look like add-ons to a basic standard
design and this kind of approach is never going to achieve the necessary
results (as accepted by MVDC officers). This should not be accepted – the
future is important.

4.10 Tesco knows how to do it – the box below sets out some of the measures
that it indicates on its own web site that it is employing at other sites
worldwide:

All our stores in the US are about 30% more energy efficient than a typical supermarket* and contain a number
of green features: from increased insulation and night shades on refrigeration cases to keep cool air from
escaping; to hybrid parking spaces and bike racks to encourage employees and customers to use greener
transport.

We opened our first environmental store in Korea on 13th October 2008. The new store reduces CO2 by 50%
compared to a store built in 2006 and energy use by 40%. It incorporates 69 carbon saving features including:
• Solar power from windows and car-park roof (23.7 tonnes)
• Wind power
• LED lighting installed in apparel section, food court, tenant mall and outdoor signage (214 tonnes)
• CO2 refrigeration compressors (saves 2,281 tonnes CO2)
• AHU inverters (235.6 tonnes)
• Ice thermal storage (120 tonnes)
• Freezer cabinets with doors (86 tonnes) (annual CO2 savings shown in brackets)

In the UK, in 2008, we invested over £26 million in 47 CHP and CCHP plants for local generation, as well as 27
wind turbines and one store installation for solar generation. These technologies are expected to reduce our
carbon emissions by about 6,000 tonnes of CO2 per annum.

OVERALL

4.11 Sustainable Development is about process as well as product. The Tesco

proposals and the manner of their development do not rate highly on either
aspect. Tesco appears to be trying to get too much on to the site (or
minimise the investment in associated works) to deliver a satisfactory
product, and in so doing, trying to bypass the right process, as the
Company knows the community is very much against the scale of the
development proposed.
4.12 There is a need for a paradigm switch for planners and developers to meet
the needs of community empowerment and the low carbon, high energy
cost future in the framework long term sustainability. The shift from short-
termism to sustainable development means that initial design is crucial to

Sustainability 18
 minimise future resource demands. Sustainable Communities need to
have a strong say in what happens to the ambiance and culture of their
community without this being imposed from external sources who may
have different interests at heart. The village community in Ashtead should
be one of the main voices to be heard in the decision on the development
of the 53 -57 The Street site within the planning framework agreed by the
democratically elected Mole Valley District Council.
4.13 It may also mean that accepted solutions and practices in terms of
development densities need to be put aside. The newly developed
assessment tools for sustainability assessment of buildings (e.g. those
such as BREEAM for non-residential and CSH for residential properties)
clearly punish higher density development which do not allow space for
ecology and biodiversity issues. To get higher ratings with these
assessment tools (as is required by most Planning Authorities including
MVDC in its CS19 policy), development densities are going to have to be
changed or schemes altered to fully include these issues from the very
start of the design process.
4.14 For the proposed development the sustainability of the scheme could have
been much improved by:
• Having a number of public meetings and focus group discussions with
members of the Ashtead community ahead of making the second
application.
• Proposing a ground source heat pump solution (with underfloor heating)
supported by a micro-CHP, to provide heat and hot water to the
supermarket and the flats above it. The micro-CHP will provide some on-
site electricity production and provide revenue earning potential through the
feed-in tariff process
• Using the south facing roofs and some facades and flat surfaces for PV
electricity panels for provision of power to the supermarket. With the newly
instituted feed-in tariffs such a solution could provide a potential revenue
earning stream.
• Providing some elements of green-roof solutions on roofs that are not south
facing – helping on the biodiversity front and assisting in the provision of a
sustainable drainage scheme.

4.15 The potential extension and restructuring of parts of the car park provides
adequate opportunity for the provision of the ground source heat pump
collection pipework.
4.16 If further off-site acceptable solutions were to be included in assessing the
scheme, then the provision of an extensive array of PV panels on the
south facing roof of the Peace Memorial Hall could provide a significant
potential area for renewable energy generation, to go alongside PV
powered car park lighting. Again under the feed-in tariff arrangement, this
could provide a positive revenue stream with about an estimated 10-12
year pay back on investment.
4.17 In my view the current proposal fails against the stated UK five SD
priorities namely:

Living Within Environmental Limits - Respecting the limits of the planet’s

environment, resources and biodiversity – to improve our environment and
ensure that the natural resources needed for life are unimpaired and remain so
for future generations.

Sustainability 19
 There is almost no future proofing in the proposal. The construction will have a
design life of 40 -60 years and yet it does not even meet today’s sustainability
targets never mind the tightened goals for 2013, 2016 and 2019 when ultimately
“zero carbon” design is required, nor move towards Tesco’s own stated goals for
2020.

Ensuring a Strong, Healthy and Just Society - Meeting the diverse needs of
all people in existing and future communities, promoting personal wellbeing,
social cohesion and inclusion, and creating equal opportunity for all.

The proposal does not appear to meet the needs of the existing community in
Ashtead as strongly expressed in the number of objections and signatures on
the petition. The promoter seems to have made little attempt to engender social
cohesion, and the wellbeing scores on the CSH assessment are very poor.

Achieving a Sustainable Economy - Building a strong, stable and sustainable

economy which provides prosperity and opportunities for all, and in which
environmental and social costs fall on those who impose them (polluter pays),
and efficient resource use is incentivised.

It would appear that some of the objectors and petitioners believe that the
environmental and social costs of this proposal will not be entirely picked up by
the proposer, indeed it appears that they fear that that in the end the community
will have to pay for some of the environmental and social costs of the proposal.

Promoting Good Governance - Actively promoting effective, participative

systems of governance in all levels of society – engaging people’s creativity,
energy, and diversity.

There has been no promotion of effective or participative engagement with key

stakeholders in the planning system. If either of the proposals are accepted as
they are, then this project will be seen to have been anti-democratic, with the will
of the local community and their ward councillors being over-ruled and no
attempt to develop consensus with such key stakeholders. That certainly is not
sustainable development.

Using Sound Science Responsibly - Ensuring policy is developed and

implemented on the basis of strong scientific evidence, whilst taking into account
scientific uncertainty (through the precautionary principle) as well as public
attitudes and values.

The strong scientific evidence, as repeatedly stated by the UK Government, is

that Climate change is a real threat to the long term future of our society and
therefore a key issue for sustainable development. It has set out national
policies to move to alleviate this which looks for significant reductions in energy
related emissions and building standards and codes to support them. The
proposal does not meet the policy current requirements. Public attitudes and
values in Ashtead do not appear to be in line with the proposal as they seem to
see a different village social environment than those assessed by Tesco’s
consultants.

Sustainability 20
Sustainability 21
 ANNEX A.

ANNEX CONTAINING ADDITIONAL SECTIONS ON MOLE

VA L L E Y D I S T R I C T C O U N C I L’ S C O R E S T R AT E G Y
STATEMENTS ON SUSTAINABLE CONSTRUCTION,
RENEWABLE ENERGY AND ENERGY CONSERVATION

(The following paragraph numbers are those from the MVDC Core Strategy Statement)

Construction Standards
7.3.6 In order to drive a step-change in the improvement of the overall sustainability of new
homes the Government has introduced The Code for Sustainable Homes (The Code). The
Code provides a comprehensive measure of the sustainability of a new home by rating and
certifying new homes against nine categories of sustainable design: energy/CO2, pollution,
water, health and well-being, materials, management, surface water run-off, ecology, waste.

7.3.7 The Code uses a 1 to 6 star rating system to communicate the overall sustainability
performance of a new home. A home can achieve a sustainability rating from one star to six
stars depending on the extent to which it has achieved Code standards. One star is the entry
level ‒ above the level of the Building Regulations; and six stars is the highest level ‒
reflecting exemplar development in sustainability terms. The Code currently proposes that
by 2010 all new homes should achieve a Level 3 status. This will then rise to Level 4
between 2013 and 2016 and then from 2016, all new homes should achieve a Level 6
status. That is to say that by 2016 all new homes should be zero carbon developments.

7.3.8 Whilst the Government has yet to provide a Code for other types of development,
making sure that they are as energy efficient as possible is just as important. It is therefore
considered as well as all new homes meeting at least Level 3 of the Code for Sustainable
Homes, all other development should meet the BREEAM 'Very Good' construction
standards, or higher as dictated by future legislation and guidance.

Reducing Carbon Emissions

7.3.12 To achieve the Council s overarching objective of creating sustainable developments
and to reduce the causes of and effects from climate change, carbon emissions from new
buildings should be reduced by at least 10%. The amount of energy to be supplied to a
development through de-centralised and renewable or low-carbon energy sources (in order
to achieve a 10% reduction in carbon emissions) should be based on the carbon emissions
of that development after energy efficiency measures have been installed. Therefore, the
amount of energy to be produced through such measures will decrease if the energy
efficiency of the building is maximised.

Sustainability 22
7.3.14 The Council's policy is in-line with the general concept of the South East Plan.
However, Policy CS19 focuses on a 10% reduction in the development's predicted carbon
emissions through the use of on-site renewable technology rather than basing the
percentage on the predicted energy consumption figure. The Council's rationale for a
differing approach is to be consistent with the Code for Sustainable Homes. The Code
requires developers to calculate the energy use and energy efficiency of a building in terms
of carbon emissions rather than energy consumption. As well as being consistent with the
Code this approach is likely to bring about greater reductions in carbon dioxide emissions by
ensuring efforts are focused on reducing carbon emissions rather than simply replacing one
method of generating energy with another regardless of the effect of overall carbon
emissions.

7.3.17 The use of Combined Heat and Power (CHP) is encouraged for large mixed
developments and large buildings. Mini and micro- CHP is a developing technology, which
may be suitable for single unit developments. Considerable reductions in carbon dioxide
emissions can be achieved by using biomass as a fuel for CHP.
7.3.18 Any on-site renewable contribution included in the development to satisfy the
requirements of this policy can also be used to gain credits for the development under the
Code for Sustainable Homes scoring system.

Implementing the Policy

7.3.20 The Council will require evidence to be submitted with planning applications for all
new developments to demonstrate how the requirements of the policy have been met
unless, it can be demonstrated that compliance is not technically or financially achievable
having regard to the type of development involved and its design.

Delivery of Policy / Monitoring

This policy will be implemented by working in partnership with planning applicants and
delivered through the development and building control processes.

The following indicators will be used by the Council to assess the effectiveness of the policy:
• Number and percentage of new buildings/ refurbishments incorporating
decentralised and renewable or low-carbon energy sources meeting the 10%
required reduction in predicted carbon emissions.
• Number and percentage of new homes meeting Code Level 3 (up until 2013); Level
4 (up until 2016); and Level 6 (2016 and beyond).
• Number and percentage of new buildings meeting the BREEAM 'Very Good'
construction standard or higher.
• Number and percentage of buildings that have not complied with the policy or future
legislation and guidance requirements based on technical or viability reasons.

Sustainability 23
 ANNEX B

ANNEX CONTAINING ADDITIONAL MATERIAL FROM HMG

“CONSULTATION ON A PLANNING POLICY STATEMENT:
PLANNING FOR A LOW CARBON FUTURE IN A CHANGING
CLIMATE”

GOVERNMENT’S OB JECTI VES

Climate change is the greatest long-term challenge facing the world today. Addressing
climate change is therefore the Government’s principal concern for sustainable
development.

The Government expects planning to continue to provide for the development needs of all in
the community, contribute to housing supply and economic growth and support social
justice. Planning should also continue to sustain biodiversity and protect natural and historic
environments. All planning strategies, and the decisions taken in support of them, must
however reflect the Government’s ambition to help business and communities build a low
carbon future and prepare for the impacts of climate change.

Plan-making and development management should fully support the transition to a low
carbon future in a changing climate. This means planning should:

• shape places so as to help secure radical cuts in greenhouse gas emissions. This
requires the location and layout of new development to be planned to deliver the
highest viable energy efficiency, including through the use of decentralized energy,
reducing the need to travel, and the fullest possible use of sustainable transport.
• actively support and help drive the delivery of renewable and low carbon energy.
• shape places and secure new development so as to minimise vulnerability and
provide resilience to impacts arising from climate change, and do so in ways
consistent with cutting greenhouse gas emissions.
• ensure local communities are given real opportunities to take positive action on
climate change; in particular by encouraging community-led initiatives to reduce
energy use and secure more renewable and low-carbon energy.

Proposed LCF6.1 Local planning authorities should assess the suitability of sites for new
development, and for what type and intensity of development, against the following criteria:
(i) the extent to which existing or planned opportunities for decentralised energy
could contribute to the energy supply of new development on the site;

(ii) the potential for new development on the site to contribute heat demand where a
heat network exists or could be provided;

(iii) the impact on travel demand of developing the site and whether there is a
realistic choice of access, and opportunities to service the site, through
sustainable low carbon transport;

Proposed LCF6.2 Where sites perform poorly against the criteria in LCF6.1 they should not
be allocated or identified for new development unless:

Sustainability 24
 (i) there are proposals in the local development framework which would improve
their performance; and/or,

(ii) their performance would be improved by, for example, limiting development on
the site to particular uses and/or density.

Policy LCF 7: Local planning approach to setting requirements for using

decentralised energy in new development

Proposed LCF7.1 Local requirements for decentralised energy should be set out in a
development plan document (DPD) and be derived from an assessment of local
opportunities in line with LCF1.4. Local requirements for decentralised energy should:

(i) relate to identified development areas or specific sites;

(ii) be consistent with giving priority to energy efficiency measures; and,

(iii) focus on opportunities at a scale which developers would not be able to

realize on their own in relation to specific developments.

Proposed LCF7.2 Local requirements should be consistent with national policy on allowable
solutions set out in support of the zero carbon homes and buildings policy.

Policy LCF 13: Designing for a low carbon future in a changing climate

Proposed LCF13.1 Local planning authorities should engage constructively with developers
to deliver well-designed, sustainable buildings and high-quality local environments suitable
for low-carbon living in a changing climate.

Proposed LCF13.2 In determining planning applications, local planning authorities should

expect proposed new development to:

(i) be designed to reduce greenhouse gas emissions by:

a. using landform, layout, building orientation, massing and landscaping

to reduce likely energy consumption;
b. using the layout, density and mix of development to support identified
opportunities for decentralised energy;

Proposed LCF13.3 Local planning authorities should expect proposals for major22 new
development to demonstrate through the submitted Design and Access Statement how the
proposed development complies with the criteria in LCF13.2. In determining planning
applications for major development, local planning authorities should give great weight to
compliance with the criteria. Where a proposal for major development fails to meet one or
more of the criteria, the application should be refused planning permission unless it can be
demonstrated by the applicant (having regard to the type of development and its design) that
meeting a criterion is not feasible.

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