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Proof of Evidence on Sustainable Development/Sustainability
B T Mould MA (Oxon). MIEMA, C Env. June 2010



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


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. 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 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.



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






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.” 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.





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





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. 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 longterm vision of sustainability in which economic growth, social cohesion and environmental protection go hand in hand and are mutually supporting. 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.



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.


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)


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.



“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)

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”. 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. 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:

• • • •


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.

Securing the Future




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. 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. To fit with this the UK now has Sustainable Development aims of reducing the UK CO2 emissions by 80% by 2050. Securing the Future also identifies wellbeing as being at the heart of sustainable development. The UK Strategy sees a key role for Business in Sustainable Development as outlined in the box below.


2.11 2.12 2.13

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: •

Role of Business in Sustainable Development


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).


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. The UK SD Strategy therefore focused on the need to enable, encourage and engage people and communities in the move toward sustainability (Pg 26). 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. 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

• • • • • • • • • •






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.

In November 2009, the Department for Communities and Local Government issued a consultation document “Zero carbon for new nondomestic 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.”


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



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 longterm 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)”

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. 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. 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





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”.


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.”


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”.


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




duplicates, these initiatives to achieve the most sustainable outcome possible.”


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 2.29

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

2010 level 3

2013 level 4 44%

2016 level 6 Zero carbon

Energy efficiency improvement 25% of the dwelling compared to 2006 (Part L Building Regulations)


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 nonresidential 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 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.




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


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.


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.



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 lowcarbon energy sources within the District.


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”. 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%.”



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”.

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. 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.
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 11 best use of its resources to inform, listen and involve people effectively. This will include providing feedback.




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



4.9 4.10





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. 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.”



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.”


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. 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. 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.






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. 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. 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. 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. 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.





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. 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.”



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 PreSustainability


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.”


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.
Scenario System description CO2 emissions (tonnes p.a.) 470 Energy Efficiency 397 150 kWth Retail ASHP 385 system Residential ASHP 382 system 5 x units 20 m2 panel area 380 to serve 4 x units CO2 savings over base case (tonnes p.a.) - N/A - 73 85 88 90 CO2 savings over base case (%) N/A 16% 18% 19% 19%

Summary of Solar Hot Wa t e r a n d A S H P Systems for the Building


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). 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). 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). 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. 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. 15






Category Reduction of CO2 Low/Zero Carbon Technology Cold Storage Equipment Material Specification Responsible Sourcing of materials NOx emissions Innovation in CO2 emissions Innovation Low/Zero Carbon reduction techniques Innovation - materials

Available Score P r o p o s e d Development Score

15 3 3 4 3 3 2 1 2

5 1 1 1 0 0 0 0 0



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’.





4.1 4.2

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

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.

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%. 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. 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’.






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. 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:// , nor MVDC’s CS19 policy and provides no future proofing. 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. 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.

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. 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 shorttermism to sustainable development means that initial design is crucial to 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.


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. 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 onsite 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. 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. 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. In my view the current proposal fails against the stated UK five SD priorities namely:


4.15 4.16


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.



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.







(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.



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.





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:




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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