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Proposed new building regulations not ambitious enough in reducing CO2 emissions!

Towards the end of 2019 the Government consulted on Changes to Part L and Part F of the Building Regulations. This consultation set out the Government plans for the Future Homes Standard to be introduced by 2025.  It is the first stage of a two-part consultation about proposed changes to the Building Regulations. Sounds pretty boring stuff doesn’t it? However in reality It one of the key areas which need to be dealt with in order to tackle climate change.

The Friends of the South Downs have responded to the consultation which ended in February 2020 asking the Government to ramp up their efforts to meet their own climate change ambitions by re-writing the proposed standards to introduce zero carbon homes by 2025.     CLICK HERE  to is see our response to the consultation.

Professional organisations are also also asking for major improvements in meeting climate change targets, for instance the Chartered Institution of Building Services Engineers (CIBSE) say: “The CIBSE very much agree with the stated overall ambition described in the Consultation Document, but have strong concerns that the proposals set out are not sufficiently ambitious to deliver significant progress towards meeting the objectives of reducing carbon emissions, annual energy consumption and peak demand, and ensuring affordability to consumers. The proposals for Part L 2020 do not represent the required “meaningful and achievable step” towards zero carbon, and the timeline and content of the Future Homes Standard is not ambitious enough, nor does it begin to address real in-use energy performance and carbon emissions”.


Click this image to read the the Government’s own Committee on Climate Change in report to Parliament in 2019


The need for a more ambitious stance on tackling climate change is desparatly needed. For instance the Government’s own Committee on Climate Change in their report to Parliament in 2019 confirmed that buildings account for 17% of all greenhouse gas emissions in the UK (see page 85).

Our Society’s report not only asks for zero carbon homes standards by 2025 but we also say:

  • In the context of a Climate Emergency, the proposed options for 2025 are not nearly ambitious enough and could actually result in a retrograde step.The Intergovernmental Panel on Climate Change (IPCC) report (Oct18) makes it clear that it is now urgent that we reduce carbon emissions, stating that we have less than 12 years to stop climate change. Even the introduction of the proposed 31% uplift (option 2) does not go nearly far enough to reduce energy demand in buildings if we are to achieve Net Zero by 2050 or earlier.
  • We must retain the powers of local authorities to set higher requirements than national standards where practical and demonstrably viable, particularly those councils that have declared a ‘Climate Emergency’.  Where local conditions allow, we believe that Local Authorities and National Parks should be able to set higher standards.  As with all development, any Local Plan policy is subject to viability tests and thus, allowing LAs to set higher standards does not restrict development.

We understand the results of the consultation will be announced later in 2020.

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What have Building Regulations got to do with climate change?

The average household in the UK emits 2.7 tonnes of CO2 every year from heating their home. The Government’s Committee on Climate Change (CCC) has identified the need to reduce emissions from the UK’s buildings – which made up 19% of the UK’s overall total emissions (2017 data). The government has already declared that we will have to move away gas central heating in new homes constructed after 2025. However that’s not the whole story. The way a house is constructed is very important when it comes to reducing greenhouse gases. The UK was very close to achieving the design of new homes to a ‘net zero carbon’ output in 2016 but the Government backed away withdrawing the regulations. However, since then new evidence has persuaded Parliament to legally commit to the UK achieving ‘carbon net zero’ by 2050. To achieve net zero action will be needed on many fronts including how houses are built.

In the latter part of 2019 the Government consulted on new standards for building regulations (to come into operation from 2025). Our Society took a look at these proposed regulations and found they were only aimed at making a 31% improvement! We decided to make a robust submission to the government asking them to go over ‘carbon net zero by 2025, in just under 5 years. A bold request you might ask?  Our Policy Officer Vic Ient studied reports from a number of organisations including the Passivhaus Trust  and found that the technology and design capabilities are already available to achieve ‘net zero’ carbon emissions. Click below to see our report and submission:

SDS Comments on The Future Homes Standard 2019 Consultation dated 07-02-20

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The Shale Wealth Fund: compensating local communities

Government is consulting on the creation of a fund to ensure that local communities where shale gas is being extracted (“fracking”) benefit from that activity. The Society has responded to the consultation as follows:


These are the comments of the South Downs Society, the national park society for the South Downs National Park.

The Society has nearly 2,000 members and its focus is campaigning for the conservation and enhancement of the special qualities of the national park and their quiet enjoyment. Our comments will reflect this focus.

We note an emphasis in the consultation on the role of shale gas in regional development and the wish (para 1.19) to “rebalance growth across the regions”. The need for such a rebalancing is clearly less in evidence in the south east, unless it is intended to suggest that this region be accordingly afforded lower priority in pressures for exploitation.

We query what is intended by the expression (para 3.3) “shale sites themselves are small, with a lesser visual impact than many other forms of development.”  It is our understanding that the visual impact – as well as aural, disturbance, aerial and subterranean impacts – will be considerable, and significantly greater than for conventional fossil fuel exploitation, owing in part to an increased number and frequency of wellheads.

We address below the consultation questions on which we wish to express a view.

Consultation Question 1: Do you think that providing opportunities for both local and regional investments are the right priorities for the Shale Wealth Fund?

Yes. While residents and others may be affected locally by visual and other impacts and traffic, there may be regional impacts such as effects on aquifers (notwithstanding government assurances) and the tourist economy.

Consultation Question 2: Do you agree that a more local level should receive revenues before a more regional level (establishing the ‘trickle up’ principle)?

No. This may provide an undesirable incentive to some local communities to seek to outweigh any genuine planning and environmental concerns with money or investment. Planning decisions should not be made on those lines. This seems less likely to happen at regional level.

Consultation Question 4: Should the government retain flexibility regarding the proportion of funding between delivering benefits at local and regional levels, to enable learning from the industry pilot schemes and once the magnitude of shale revenues becomes clearer?


Consultation Question 5: Do you have views on how the “local community” to a shale site should be defined for the purposes of the Shale Wealth Fund?

The community should be defined to include those likely to be affected by activities associated with extraction, such as lorry movements, as well as those directly affected by a drilling site by living close by.

Consultation Question 6: Do you agree that the “local community” should be defined on a case-by case basis?


Consultation Question 7: Do you think a set of principles should be developed to ensure consistency of approach for different shale developments?


Consultation Question 9: Do you agree that at a local level, it should be for local people to determine how the Shale Wealth Fund is spent?

While local people should be involved in the decision making, there should be objectives or criteria set for the funding to ensure it is used to compensate for the full range of impacts from fracking, including allocating to projects which improve the natural environment under threat.

Consultation Question 11: At the local level, should expenditure from the Shale Wealth Fund be subject to any ring-fences for a specific purpose? If so, should these be locally or centrally determined, and do you have views on what they should be?

A significant part of any extraction could take place beneath the South Downs National Park despite robust arguments having been made against that. If so, given the national park statutory purposes of conservation, understanding and enjoyment, it would be appropriate not only to compensate local communities but also recreational users of those parts of the park affected by fracking related activities, either beneath, within or close to the park. This would indicate a need for part of the fund within a national park to be ring-fenced to provide environmental enhancements and improved access, preferably to be allocated by the national park authority.

Consultation Question 12: At the local level, would an appropriate use of the Shale Wealth Fund be to make direct payments to households?

No. Other than, say, compensation for subsidence, other physical damage or blight – which should presumably be handled separately – it would be inappropriate for individual householders to be incentivised to overcome any legitimate concerns they may have about the proposed activity in order to unbalance the consideration of proper planning issues.

Consultation Question 14: How can the government ensure that decisions are as directly influenced by local residents as possible?

By affording more scope for local planning authorities (the traditional and democratically accountable mechanism) to consider the full range of potential effects of any proposal including aerial and subterranean impacts; and by discouraging ministers and planning inspectors from overruling the planning decisions made.

Consultation Question 16: What kind of investments do you think should be made from a regional level of the Shale Wealth Fund?

It would be appropriate to include investment in the natural environment and reductions in carbon emissions to compensate for the negative impacts of fracking including climate change.

Consultation Question 17: Do you think a regional level of the Shale Wealth Fund should be administered by direct grants to specific organisations, or through an open bidding process? How can the views of residents across the regions be best taken into account?

We would support an open bidding process, enabling environmental organisations like ourselves, as well as community groups, to apply for funding. If it were decided to allocate funds direct to specific organisations, that should include the national park authorities where they have planning responsibilities for any areas affected by fracking and associated activity.

Consultation Question 18: Do you have views on how a regional level of the Shale Wealth Fund should be governed? Are there existing regional organisations, or local or national governance structures that would be particularly suited to oversight of such a fund?

National park authorities should be responsible for, or at least involved in, the governance of any fund disbursed in a national park.


Click on this link for the consultation paper and full list of questions:



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The Society welcomes removal of overhead power line at Cocking

Southern Electric Power Distribution has taken down unsightly overhead power lines which marred the appearance of the otherwise picturesque downland village of Cocking, particularly views of the 11th century church. This scheme had been put forward by the Society and we have been swift to congratulate all those concerned.

The link below will take you to a press release from the South Downs National Park Authority which describes the scheme.

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Press release from the Society February 2014: Drilling for gas in the national park? No thanks!

Drilling for gas in the national park? No thanks!

 National Park “Friends” group, the South Downs Society, has thrown its weight behind objections to a proposal for an exploratory drill for shale gas near Fernhurst, West Sussex.

“The current planning application may only be for exploration,” says Society chairman Robert Cheesman, but “we can have a good idea about what might happen next. This Society supports renewable energy – at the right scale and in the right place – over the extraction and burning of more fossil fuels. And running a major gas extraction operation within the national park can’t be right. It runs counter to government planning policy.”

A range of environmental organisations, as well as local residents, are campaigning against the proposals from Celtique Energie and are pressing for them to be rejected by the South Downs National Park Planning Committee when it considers the application. If gas is found in sufficient quantities, the controversial fracking technique may be used to extract it – and, as well as the likely setback to meeting the country’s climate change targets, there are major concerns about the risks, experienced elsewhere, of seismic activity and the pollution of underground water sources.

Says Robert Cheesman, “Government is telling local planning authorities not to worry about these uncertainties but as a Society – with both a large and a small “s” – we are entitled to reassurance.”

The South Downs Society has today submitted its response to the planning application, pointing out that the choice of a location within the national park has not been justified. The Society’s comments have also included its strong concerns over landscape damage, unacceptable levels of lorry traffic, noise and light pollution, loss of tranquillity, threat to local archaeological heritage and impact on enjoyment of the national park and its network of rights of way.


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National park group seeks greener green energy from wind farm

South Downs National Park friends group, the South Downs Society, today called for a better deal for the Park from energy giant E.ON and their scheme for a huge offshore wind farm.

A public examination by government appointed officials is now under way into the proposals – known as the Rampion wind farm — for nearly 200 giant turbines, out to sea but clearly visible from the Sussex coast. Environmental organisations have generally welcomed the commitment to generate much needed energy from renewable, sustainable sources but fear that the sight of the massed ranks of turbines will seriously detract from the age-old pleasure of looking out to sea, especially from the Sussex Heritage Coast around the Seven Sisters cliffs and Beachy Head.

E.ON have said that they will put all their power transmission cables underground if they are given permission to build the wind farm, but green groups like the South Downs Society are still concerned.

“Of course we’re pleased that the cables would go underground,” says Society chairman, Robert Cheesman, “but, first, we need to be satisfied that the best route has been chosen. It seems that E.ON’s preference for taking the cables through the national park has been made on financial grounds, and that’s not good enough when one of our most treasured landscapes is at stake. And second, the cabling process itself will be a huge operation, meaning major disruption to the landscape, to wildlife and people’s enjoyment.”

The Society has this week submitted its comments to the Examining Panel and has requested the opportunity to address a public hearing on the impact of the proposals on the national park – on the Downs themselves from digging the cable trenches, and on sensitive seaward views.

“The company knows there will be damage. Their own landscape consultants have told them that,” says Robert Cheesman, “and our aim, if they are given the go-ahead, is to compensate for that by seeking the best possible package of environmental and access improvements.”

The examination of the proposals will conclude by January 2014, with a decision from the Secretary of State for Energy and Climate Change expected next summer. If approved, construction is anticipated to begin in 2015 and the wind farm could start generating electricity in 2018/9.