Working on sites in South Gloucestershire means meeting the council’s sustainability policies at the planning stage – a defined set of technical thresholds you need to evidence, not just aspire to. This guide breaks down the key policies and the latest guidance on how to demonstrate compliance, especially for major residential developments.
In this blog, you’ll learn:
- The key sustainability policies affecting planning applications under South Gloucestershire Council
- How these policies apply to new residential and commercial developments
- When a Sustainable Energy Statement is required
- What developers must do to demonstrate compliance
What Are the Key Sustainability Planning Policies?
South Gloucestershire Council applies several local plan policies to new developments to ensure energy efficiency, carbon reduction, and climate resilience. The most relevant for major development proposals include:
- Policy PSP6 – On-site Renewable and Low Carbon Energy
- CS1(8) – High Quality Design
- CS3 – Renewable and Low Carbon Energy Generation
- CS4 – Renewable or Low Carbon District Heat Networks
Major development is defined as:
- Non-residential development of over 1,000 sqm of floor space
- Residential development of 10 or more dwellings
PSP6: On-Site Renewables and Low Carbon Energy
South Gloucestershire’s Local Plan Policy PSP6 has specific requirements for major greenfield residential developments:
- Proposals must demonstrate a minimum 20% reduction in total (regulated + unregulated) CO₂ emissions using renewable and/or low carbon energy generation.
- Energy efficiency measures must exceed current Building Regulations Part L (2021) as a first step.
- Developers must show how roofs are designed and oriented to support the efficient installation of solar technologies.
- Supporting evidence – such as SAP calculations and completed Energy Tables 1a-1c – must be provided in the Energy Statement.
A technical point worth flagging early
PSP6’s 20% reduction applies to total emissions – regulated (heating, hot water, fixed lighting) and unregulated (appliances, cooking, plug loads) combined. Standard SAP and SBEM software, which is what most Part L compliance work runs on, only calculates the regulated portion. That means the unregulated element has to be estimated separately to complete the Energy Tables This is a common point of disagreement with planning officers over baseline assumptions if it isn’t handled carefully from the outset.
Source: South Gloucestershire Council, Local Planning Application Requirements
A fabric-first strategy combined with full electrification is often the most reliable route to clearing this threshold with genuine headroom, rather than a marginal pass.
A 19-20 dwelling greenfield site in South Gloucestershire, targeting PSP6’s 20% CO₂ reduction requirement through a fabric-first and renewables strategy:
A practical note on PSP6 vs. the council’s wider ambitions
PSP6’s 20% figure is the statutory minimum, but it isn’t necessarily where the conversation with a climate officer ends. South Gloucestershire has declared a Climate Emergency and, jointly with Cotswold District Council and other West of England authorities, promotes its own Net Zero Carbon Toolkit – targeting space heating demand of 15 kWh/m²/yr or below, an overall Energy Use Intensity of 35 kWh/m²/yr or below for residential schemes, and no new fossil-fuel connections. In practice, this means an application that technically clears PSP6 can still face pushback or negotiation delays from officers pushing for closer alignment with these considerably tighter targets – worth factoring into the programme for a scheme, not just the design.
Source: Net Zero Carbon Toolkit, South Gloucestershire Council, Cotswold District Council and West of England authorities, p.10, “KPIs – New Housing Target Table.”
What if the 20% target isn’t viable on-site?
PSP6 is explicitly framed around major greenfield residential developments – on constrained brownfield or urban infill sites, hitting 20% through on-site renewables alone can run into genuine spatial or structural limits. Where that’s the case, the usual route is to combine a strict fabric-first approach with a detailed Energy Hierarchy Assessment that justifies any shortfall, and to explore heat network connection or off-site mitigation as an alternative route to the same outcome. This is typically a negotiation with planning officers rather than an automatic exemption, so it’s worth building the justification early rather than raising it after a first submission is challenged.
Why PSP6 can feel like a bigger ask than the “20%” headline suggests
PSP6 was adopted on 8 November 2017, when Part L 2013 was still the active national baseline. Part L’s 2021 interim update already delivered roughly a 31% CO₂ reduction against that 2013 baseline in its own right. That means a scheme meeting today’s Part L 2021 minimum is starting from a considerably tighter energy position than PSP6’s drafters were working from – so reaching an additional 20% reduction on top of that baseline typically demands a larger renewables installation (bigger PV arrays, higher-spec heat pumps) than the policy’s original 20% figure might suggest at first glance.
Sources: South Gloucestershire Council, Policies, Sites and Places (PSP) Plan, adopted 8 November 2017; MHCLG/DLUHC, The Future Homes Standard: 2019 Consultation on changes to Part L and Part F (Government Response).
CS1(8): High-Quality Design
South Gloucestershire’s Core Strategy policy CS1(8) expects developers to integrate energy conservation and efficiency into their building design, including:
- Strategic siting and orientation of buildings and roof slopes to maximise solar gain
- The use of fabric-first principles to reduce heating demand and improve airtightness
- Demonstrating how the scheme outperforms Part L 2021 standards
- In non-residential developments, targeting BREEAM “Very Good” or higher is encouraged
CS3: Renewable & Low Carbon Energy Generation
Policy CS3 supports energy generation from renewable or low-carbon sources, including:
- Air/ground source heat pumps
- Solar PV and solar thermal
- CHP, energy from waste, and other decentralised technologies
Proposals must not negatively impact nearby properties or protected landscapes. Proposals for standalone installations (e.g. solar farms or biomass boilers) should also include installed capacity (kW), predicted generation (kWh/yr), and CO₂ savings (tonnes/yr).
CS4: Renewable or Low Carbon District Heat Networks
Policy CS4 encourages developers to connect to district heating networks where viable. Requirements vary by scale:
- Large scale (100+ dwellings or >10,000 sqm): Mandatory feasibility assessment for connecting to or creating a heat network, using the CIBSE CP1 Heat Network Code of Practice.
- Smaller scale (fewer than 100 dwellings or under 10,000 sqm): Connection is encouraged, rather than mandatory, where technically and financially viable.
If your project includes industrial waste heat, you must demonstrate how it will be captured and redistributed – or explain why it is not feasible.
When is a Sustainable Energy Statement Required?
Under South Gloucestershire’s Planning Application Requirements, a Sustainable Energy Statement is required for all major developments. This statement may be a standalone report or included within the Design and Access Statement. If you’re unsure whether your project needs an Energy Statement, a Sustainability Statement, or both, our guide to what a Sustainability Statement covers sets out the distinction.
The statement should include:
- The applicable version of Building Regs (currently Part L 2021)
- Baseline energy demand and emissions
- Proposed energy efficiency measures beyond Building Regs
- Heating and hot water system specs (with low-carbon alternatives encouraged)
- On-site renewable energy generation details and system performance
- Climate resilience and overheating risk assessments – typically dynamic thermal modelling under CIBSE TM59 for residential schemes (which also satisfies Building Regs Part O), or CIBSE TM52 for non-residential buildings
Sources: GOV.UK, Approved Document O: Overheating; CIBSE TM59: Design Methodology for the Assessment of Overheating Risk in Homes.
What About Commercial Developments?
For non-residential developments over 1,000 sqm, South Gloucestershire Council also requires a Sustainable Energy Statement as part of major applications. These must demonstrate:
- How the scheme meets or exceeds Part L (2021) SBEM compliance
- Opportunities to incorporate low-carbon heating systems and on-site renewables
- Assessment of connection feasibility to district heat networks (as required under Policy CS4)
- Commitment to energy efficiency and sustainability standards, with a BREEAM “Very Good” rating encouraged for large-scale commercial buildings
What Does This Mean for Developers?
South Gloucestershire Council places a strong emphasis on energy performance and renewable integration. To comply:
- Integrate energy modelling and sustainability assessments from the early design stage
- Use a fabric-first approach to exceed Part L performance
- Include heat pumps, PV panels, or other renewables to meet PSP6’s 20% CO₂ reduction requirement
- Complete and submit the required Energy Tables and supporting SAP/BRUKL documentation
- Factor in climate resilience, including dynamic overheating risk assessments
What’s Next?
South Gloucestershire’s policies require a proactive approach to sustainability and planning compliance – developers who plan ahead avoid delays and build long-term value into their schemes, rather than scrambling to retrofit a strategy once a climate officer flags a gap.
Get in touch with our sustainability consultants to discuss your Sustainable Energy Statement, SAP Calculations or overheating risk assessment.
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