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Contents
Introduction 4 About the Case Studies 5 Lessons 6 Spatial policies for renewable energy 8 Criteria-based policies for renewable energy 12 Spatial policies for Low Carbon Heat 13 Evidence base 16 Consultation and testing at Examination 18 Conclusions and lessons 19
Introduction
Paragraph 97 of the NPPF advises that to help increase the use and supply of renewable and low carbon energy local planning authorities should consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources. The footnote to the policy makes it clear that where plans identify areas as suitable for renewable and low-carbon energy development, they should set out what criteria have determined their selection, including for what size of development the areas are considered suitable. Authorities should also have policies to ensure any adverse impacts are addressed satisfactorily. Identifying suitable areas for such developments implies a degree of spatial specificity in plans, through mapping or describing broad or specific locations where opportunities may exist and where development might be most appropriate and encouraged. policies need to be supported by a robust evidence base that has been used flexibly according to local circumstances consult widely and early on the evidence base and resultant polices to avoid surprises and reduce risks of challenge. consider whether separate policies are required reflecting different components of carbon reduction (energy efficiency, district heating, renewable energy development) and the different types of developer and possible The case studies illustrate how some planning authorities with recently adopted or emerging plans are taking a spatial approach to policies on renewable energy. Spatial identification of opportunities is most common for district heating Renewable energy and local plan policies - case study 4 delivery mechanisms ensure policies are flexible to reflect viability, costs and constraints, and robust to changes in technology and economic circumstances. It is early days in terms of implementation. The policies are fairly new, so the authorities haven't yet seen how they are working out in practice. However, the case studies do illustrate that some of the fundamentals of good plan-making apply to this area of planning, like any other: and combined heating and cooling but there are a few examples of for freestanding renewable energy developments, such as wind turbines.
Bristol City Council Darlington Borough Council Hastings Borough Council Richmondshire District Council South Staffordshire Council Manchester City Council Stockport Metropolitan Borough Council
For further details on these councils and their plans, see Appendix A.
Lessons
Based on the experiences of the authorities featured here the following lessons can be highlighted. In general though, the same principles which apply to good plan-making overall also apply to this area of policy making: it may be helpful to use consultants that have developed the evidence base (renewable and low carbon capacity, constraints and opportunities) to advise on framing of policies to ensure accurate interpretation of information.
Prepare a robust evidence base use of external independent expertise is important in developing a robust evidence base with the expertise used to support the planning authority at examination collaboration with other authorities in preparing the evidence base helps consideration of a wider geographic area strategically (and identifying where realistic opportunities may be) and also brings economies of scale be prepared to adapt how you use evidence to inform and defend policy in the light of feedback from consultation if necessary.
Achieve a balance between specificity and flexibility ensure policies are flexible to reflect viability, costs and constraints, and be robust to changes in technology and economic circumstances combine identification of opportunities and priorities spatially with criteria in policies against which proposals can be considered to address potential impacts and constraints consider use of landscape character assessments and sensitivity assessments to help assess its capacity to accommodate renewable energy installations and consider proposals apply policies in a pragmatic way, ensuring viability of developments is maintained while reducing carbon emissions. Be clear about delivery mechanisms be clear who the audience is for different policies or components of policies (energy efficiency, carbon savings, district heating, renewable energy development)
Avoid misinterpreting information an Energy Opportunities Map or similar can be used to provide a spatial steer to developers and form the basis for dialogue. It should not imply development will necessarily be permitted in identified areas or will not be permitted outside of these
and consider framing policies to reflect this consider preparing additional guidance to assist interpretation and implementation of complex policies, for example for energy and carbon standards exceeding Building Regulations
masterplanning presents an opportunity to design-in renewable and low carbon energy, including district heating infrastructure, to developments at an early stage.
Understand and explain the links between policy objectives climate change mitigation policies (e.g. district heating, and renewable energy development) have different audiences and delivery mechanisms but are all necessary to promote the common objective of reducing greenhouse gas emissions.
Ensure you engage parties early on getting buy-in from developers, development management, senior management, and politicians at an early stage, and where possible ongoing training, is essential so that the evidence base and policies are understood and implemented as intended.
Hastings Core Strategy Policy SC6 provides support for renewable energy
facilities that meet criteria in the policy including scale and cumulative impact on landscape and built environment, impact on community, economy, biodiversity and historic interests, and on areas
Planning Strategy.
Figure 1 Hastings Core Strategy Key Diagram identifying 5 Potential Areas of Search for Renewable Energy (orange discs)
South Staffordshire
also identifies
locations with greatest renewable energy (wind, small-scale hydro, and biomass) potential on a map in the Core Strategy, reproduced from the supporting Staffordshire County Wide Renewable/ Low Energy Carbon Study. Policy EQ6 also identifies the potential for wind energy development in the District as four large-scale turbines, and sets out criteria against which proposals will be considered. Although the policy does not make reference to particular locations, the supporting text refers to the map of Locations with Renewable Energy Potential which includes four potential sites of greatest opportunity for wind development (for 3 or more turbines) as included in the Renewable Energy Study.
Darlington Core Strategy Policy CS3 provides support for renewable energy. The
text identifies wind energy as having the greatest potential to contribute to the Boroughs renewable electricity supply. Assessments of wind speeds, technical and environmental constraints as well as the potential landscape and visual impact are to be used to help identify sustainable locations appropriate for wind energy development. It also identifies Darlingtons urban fringe including the strategic development locations identified in Policy CS1 as being suitable for small-scale wind energy.
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Figure 2 Richmondshire evidence base Energy Opportunities Map (referred to in Core Strategy Policy CP1) identifying Potential Wind Resource (hatched area in north east of plan area) and Viable Residential Heat Demand (for district heating) (orange areas) Renewable energy and local plan policies - case study 11
natural, built, historic and cultural landscape and townscape including buildings, features, habitats and species of international, national and local importance
residential amenity including visual intrusion, air, dust, noise, odour, traffic generation, recreation and access
cumulative impact.
They also include technology-specific factors, particularly wind turbines. The visual impact of wind development in particular is addressed in most policies, commonly requiring use of landscape character assessments and sensitivity frameworks such as by Richmondshire, and of the criteria used to identify areas suitable for wind development Renewable energy and local plan policies - case study 12
SD-3 identifies two types of area that have distinct energy opportunities identified spatially in its Energy
The potential for district heating networks to be developed will need to be reflected in and encouraged by masterplans incorporating district heating infrastructure, to ensure effective coordination across sites and related infrastructure.
Opportunities Plan:
Network Development Area: where the proximity of new and existing buildings creates sufficient density to support district heating and/or cooling networks (potential district heating areas on the Energy Opportunities Plan); and
John Hiles, Planning Policy Officer Hambleton and Richmondshire District Councils
Microgeneration Area: locations where lower densities and a fragmented mix of uses mean that only building scale solutions are possible (in effect the rest of the Borough).
Manchester s Core Strategy Policy EN5 identifies broad Strategic Areas for low and zero carbon decentralised energy infrastructure in the City Centre, Airport, major development sites, and strategic housing and employment locations. Developments are expected to have energy proposals plans detailing measures to incorporate low and zero carbon energy infrastructure. Policy EN7 has a presumption in favour of low and zero carbon decentralised energy generally, subject to criteria being met, with the supporting text identifying the main sources to deliver the capacity (opportunities for which to be identified in energy proposals plans). Instead, policies often require proposals to be considered with reference to Landscape Character Also in Greater Manchester, Stockports Core Strategy Development Management Policy Renewable energy and local plan policies - case study 14 A number of other emerging plans do not identify areas that may be suitable for renewable energy, on the basis that the information on resource availability and constraints may not be sufficiently robust to delineate suitable areas. Development Management Policy SD-4 requires that new development in Network Development Areas, where technically feasible and financially viable, should consider district heating to help deliver carbon reductions.
Assessments and assessments of relative sensitivity (to wind and large-scale solar, individually and cumulatively) of landscape character types.
This includes areas with experience of large-sale renewable energy developments and pressure for further development e.g. North Devon and Torridge (Local Plan consultation draft, January 2013), Cornwall Council (Local Plan pre submission General Policies March 2013), Northumberland Local Development Plan Core Strategy Preferred Options (Consultation Document: February 2013).
Evidence base
All of the Core Strategy case studies were supported by a renewable and low carbon energy study. The approaches to preparing the evidence base are similar. The evidence base usually has been prepared by independent technical consultants and includes all or some of the following components: Renewable energy potential, assessing the presence and distribution of resources (average wind speed, hydro, biomass) and constraints to deployment, identifying the theoretical and practical potential generation from different resources and areas where development may be appropriate. Evidence to support energy efficiency and carbon reduction standards beyond the Building Regulations, for example identifying current and projected emissions and the contribution that may be made to reducing emissions through tighter standards usually with reference to national standards such as BREEAM and Code for Sustainable Homes. Consultation on the energy assessments helped to build awareness and understanding of the emerging evidence base prior to consultation on resultant Heat mapping identifying areas of high current or potential heat demand and consumption and/or surplus heat generation where district heating or combined heat and power may be most feasible. These are generally more densely developed urban areas with a mix of uses with a constant heat (or cooling) demand, where there may be anchor heat loads (swimming pools, hotels, hospitals or types of industry, or where major development is proposed). Renewable energy and local plan policies - case study 16 policies. In Staffordshire, consultation events were led by the consultants that prepared the joint Staffordshire County Wide Renewable/Low Energy Carbon Study, involving developers, politicians and other interested parties. Often strategic energy assessments undertaken to support Regional Spatial Strategy policy were used, with additional local studies providing more detailed authority-specific evidence.
Similar stakeholder events were held as part of AGMA Decentralised and Zero Energy Carbon Planning study in Greater Manchester to build awareness and take on board views from developers and public, and additional specific consultation on energy policies was undertaken as part of CS consultation.
Collaboration with other authorities in preparing the evidence base is important in considering a wider area strategically (and identifying where realistic opportunities may be) and also has economies of scale.
A sound evidence base is required to demonstrate deliverability of policies including as far as possible, consideration of the effects on development viability.
Examples emerged of specific consultation events on energy policy over and above normal consultation on emerging plans, although Bristol held a specific stakeholder event on climate change as part of the consultation on the Publication version of the Plan.
Karen Johnson, Darlington Borough Council Renewable energy and local plan policies - case study 18
However, developments will also need to be otherwise acceptable and meet a range of criteria. Mapping of suitable areas with potential/ opportunity based on constraints and resource (e.g. wind speed) cannot consider all local issues, impacts and merits of development. It may also be misinterpreted if not carefully drafted, to imply that development outside of such areas is inappropriate. This can be an unintended consequence of attempting to prepare a positive strategy.
Identifying suitable locations for district heating in policy may be more straightforward than for free-standing renewable energy developments, generally being existing urban or major development areas, particularly if in proximity to Renewable energy and local plan policies - case study 19
Darlington Borough Council Core Strategy (adopted in May 2011) policies support renewable and low carbon energy developments generally, with criteria against which proposals will be considered. It supports such development giving significant weight to its environmental, social and economic benefits while requiring potential impacts, including cumulative effects, to be considered and mitigated. The supporting text advises that assessments of wind speeds, technical and environmental constraints as well as the potential landscape and visual impact studies of wind development in the north east of the Borough are to be used to help identify sustainable locations appropriate for wind energy development.
Hastings Borough Council The Planning (Core) Strategy Submission draft examined February 2013) contains a suite of policies addressing renewable and zero carbon development. This includes an energy hierarchy to identify the most suitable and cost effective method of achieving low carbon development, and offset emissions forecast to arise from development over the plan period. It prioritises energy efficiency, then on-site renewable energy generation or on-site connected heating, or combined heat/cooling and power and then suitable additional measures such as larger CHP or district heating systems or Mega Watt (MW) scale wind. The Development Management Plan (Proposed Submission January 2013) Site Allocations include sites with potential for low carbon and renewable energy.
Richmondshire District Council The submitted Local Plan Core Strategy (February 2013) contains 3 components: Supporting renewable and Low Carbon Energy; Ensuring carbon savings in existing and new development; and Climate Change adaptation. Policy CP1 supports and encourages renewable and low carbon energy that responds positively to the opportunities identified in the Richmondshire Local Renewable and Low Carbon Energy Capacity Study (2012) and the studys Energy Opportunities Map and meets criteria set out in the policy including landscape and visual impact (based on a landscape sensitivity framework) and community benefits plus areas of potential wind resource. The supporting text makes it clear that although the deployment of renewable energy will not be precluded outside these areas, the EOM is considered to represent the most promising areas for renewable and low carbon energy generation.
John Hiles, Planning Policy Officer, Hambleton and Richmondshire District Councils t. 01748 827025 e. John.Hiles@Richmondshire.gov.uk
South Staffordshire Council Core Strategy (adopted in December 2012) Policy EQ6 sets a target for renewable energy generation in the plan area, supporting development of biomass-fuelled heat and power generally and including criteria against which proposals are to be considered. The supporting text identifies biomass as the preferred resource and technology to deliver carbon reduction standards. A Design Guide is being developed which will be include advice to householders on energy efficiency and renewable energy.
Manchester City Council The Core Strategy adopted in July 2012 contains a suite of policies (EN4, EN5, EN6 and EN7) encouraging renewable and low carbon energy, and carbon reduction. Policy EN4 aims to reduce carbon emissions through, where possible, development locating close to, and being designed to, enable connection to low or zero carbon supplies. Katrina Holt, Senior Planner t. 0161 234 4570 e. k.holt@manchester.gov.uk
Stockport Metropolitan Borough Council Core Strategy (adopted in March 2011) Policy CS1 requires all development to demonstrate how it will contribute towards reducing the Boroughs carbon footprint by achieving carbon management standards. The Core Strategy seeks to identify and enable opportunities for low and/or zero carbon developments and includes an Energy Opportunities Plan. A suite of development management policies covering energy efficient design, incorporation of low carbon and renewable technologies in existing dwellings and identifying opportunity areas for heat and renewable energy provide for implementation of the policy.
Angie Jukes, Health & Environment Advisor (Planning) t: 0161 474 4385 e: angie.jukes@stockpot.gov.uk
References
Bristol City Council: Core Strategy: http://www.bristol.gov.uk/sites/default/files/documents/planning_and_building_regulations/ planning_policy/local_development_framework/Bristol%20Development%20Framework%20Core%20 Strategy%20June%202011.pdf
CS evidence base Bristol Citywide Sustainable Energy Study http://www.bristol.gov.uk/sites/default/files/ documents/planning_and_building_regulations/planning_policy/local_development_framework/Bristol%20 Development%20Framework%20Core%20Strategy%20June%202011.pdf
CS evidence base: Decentralised Renewable and Low Carbon Energy Study 2009 and Update to 2009 Decentralised Renewable and Low Carbon Energy Study Final Report, (Entec July 2010)
Wind Farm Development and Landscape Capacity Studies: East Durham Limestone and Tees Plain (Arup 2008 for Association of North East Councils), and addendum report 2009 http://www.darlington.gov.uk/Living/Planning/Planning+Policy/background.htm
Local Plan evidence base: Hastings Borough Renewable and Low Carbon Energy Study, (Element Energy 2009) http://www.hastings.gov.uk/environment_planning/planning/localplan/ldf_ documents/renewable_energy_study/
Evidence base: Decentralised and Zero Energy Carbon Planning (Urbed/AECOM/Quantum for AGMA, June 2010) http://www.trafford.gov.uk/environmentandplanning/strategicplanning/ localdevelopmentframework/agmadecentralisedenergystudy/
CS evidence base: Richmondshire Local Plan Renewable and Low Carbon Study (AECOM, August 2012) http://www.richmondshire.gov.uk/pdf/TE010%20Renewable%20and%20Low%20 Carbon%20Energy%20Study%20(August%202012).pdf
CS evidence base: Staffordshire County-wide Renewable / Low Carbon Energy Study (CAMCO, September 2010) http://www.tamworth.gov.uk/PDF/Staffordshire_LDF%20Evidence%20Base%20Report_V7_ ISSUED.pdf
Renewable energy and local plan policies - case study 24
Evidence base: including Decentralised and Zero Energy Carbon Planning (Urbed/AECOM/ Quantum for AGMA, June 2010) http://www.stockport.gov.uk/services/environment/planningbuilding/planningpolicy/ldf/ldfevidence