You are on page 1of 114

Hertfordshire County Council Hertfordshire Environmental Forum Hertfordshire Technical Chief Officers Association

Hertfordshire Renewable Energy Study


Planning Considerations
July 2005 Entec UK Limited

Report for Mr John Wood Director of Environment Hertfordshire County Council County Hall Hertford SG13 8DN

Hertfordshire County Council Hertfordshire Environmental Forum Hertfordshire Technical Chief Officers Association

Main Contributors Alan Chaplin Jenni Heaton

Issued by

Alan Chaplin

Approved by

Hertfordshire Renewable Energy Study


Planning Considerations
July 2005 Entec UK Limited

Entec UK Limited
Atlantic House Imperial Way Reading RG2 0TD England Tel: +44 (0) 1189 036061 Fax: +44 (0) 1189 036261

Executive Summary
The achievement of sustainable development will require action by many people and organisations. It will require radical changes in the way we plan and make decisions; in the way we live and carry out our business. Facing up to these radical changes will strengthen us as a region now and benefit generations to come. (Source: The East of England Sustainable Development Framework, October 2001, The East of England Regional Assembly and The East of England Sustainable Development Round Table) Entec UK Ltd was engaged by the clients, Hertfordshire County Council, Hertfordshire Environmental Forum (HEF) and the Hertfordshire Technical Chief Officers Association (HTCOA), to undertake research to identify the realistic potential for renewable energy development in the county and to explore the opportunities and constraints to this form of development. PPS22 sets out the Governments national land use planning policies for renewable energy. The ODPM has also produced Planning for Renewable Energy: A Companion Guide to PPS22 offers practical advice as to how these policies can be implemented on the ground. The Companion Guide also includes examples of best practice. The East of England Regional Spatial Strategy (December 2004) is currently undergoing review and a draft version was the subject of consultation from 8 December 2004 to 16 March 2005. An Examination in Public is scheduled to begin on 13 September 2005. Renewable energy is used to describe the various ways in which continuous energy flows that occur naturally in the environment, from the sun, wind, oceans, plants and the fall of water, are harnessed. Energy from waste is also referred to as renewable energy where it emanates from within the earth. National policy is to encourage the development and use of renewable energy resources where they have prospects of being economically viable and environmentally acceptable. The aim is to reduce the adverse environmental impacts of producing energy from fossil fuels, notably carbon dioxide (CO) emissions. In addition, renewable energy sources can also contribute towards the greater diversity and security of the nations energy supply. The accompanying technical report on renewable energy in Hertfordshire, which has also been prepared by Entec, concludes that there is the technical potential within Hertfordshire to achieve the levels of renewable energy production proposed in the East of England Sustainable Development Round Table Study. If the 2010 regional targets are to be met, onshore wind must be encouraged, along with all other forms and scales of renewable energy schemes. In order to meet the 2020 targets, emerging technologies, such as biomass, will be needed, although the long initiation periods for bringing such development into operation means that proposals must be brought forward now. Renewable energy in new development will only make a marginal difference to meeting the regional targets, but would help encourage more affordable and a greater choice of renewable energy technologies in the market place, as well as possibly raising public awareness.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

ii

Planning applications for renewable energy projects should be assessed against specific criteria set out in local development documents, as well as the East of England Regional Spatial Strategy. Local planning authorities may include policies in local development documents that require a percentage of the energy to be used in new residential, commercial or industrial developments to come from on-site renewable energy developments. The opportunity for incorporating renewable energy projects in all new development should be considered. Authorities will need to have a clear understanding of energy usage in their areas in order to set clear baselines and be able to track progress against effective targets. The options for the planning system in Hertfordshire are set out in terms of three broad ways in which the planning system might engage in the future in the promotion of renewable energy: Business as usual; What is possible; and Extending the case for renewables. Business as usual is not considered to be an option if Hertfordshire and the East of England intend to move towards, yet alone reach, their own targets. In terms of what is possible, there is the technical potential within Hertfordshire to achieve the levels of renewable energy production proposed in the East of England Sustainable Development Round Table Study. The last option, extended, provides the basis for blue sky thinking by the local authorities in particular, which might provide a convenient way of kicking off the Local Development Frameworks that are due to prepared over the next few years. A number of possible actions and considerations flow from the extended position: Renewable Energy in New Development The application of renewable energy as a requirement to (virtually) all new development, particularly for residential development, appears to offer an opportunity that should be seriously considered if there is a serious intent to meet renewable energy targets at the regional and county levels If this approach was to be adopted, the local authorities would need to think about seeking to remove, or at least modify, in Policy ENV8, sub-paragraph (c), of the draft East of England Plan the words above the same threshold, in order to ensure that a regional policy allows local development documents to require all developments (or at least all residential development) to incorporate equipment for renewable power generation so as to provide at least 10% of their predicted energy requirements. If this was introduced into the development plan via the new Local Development Frameworks, possibly just over half of the new dwellings proposed for Hertfordshire in the current regional plan period to 2021 could become the subject

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

iii

of such a renewable energy requirement, so long as the RSS confirmed such an approach and so long as the local planning authorities introduced the requirement as a co-ordinated group. Community Heating and CHP Community heating schemes and combined heat and power are subjects that the local authorities should research in detail in due course if it is considered that there may be future opportunities for these forms of energy production and distribution, particularly with regard to the larger scale of developments that will need to be considered in the county. Wind Energy With regard to wind energy, the local authorities should not only consider aiming for at least 5 additional wind turbines in the county, but also whether the community is willing to extend its ambitions to accommodating and actively encouraging around 30 large wind turbines in Hertfordshire. Planning Application Statements With regard to energy consumption statements, local planning authorities should consider whether they should specifically seek written evidence from applicants on an examination of the options for different heating and power systems when certain types of development proposals over a particular size are submitted as planning applications.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

iv

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Contents

1.

Introduction
1.1 1.2 1.3 1.4 1.4.1 1.4.2 1.5 1.5.1 1.5.2 1.5.3 1.5.4 The Study Study Objectives The Renewable Energy Options Report Structure of the Report Sections Appendices The Planning System National Planning and Policy Statements Regional Planning and Regional Spatial Strategies Local Development Frameworks The Development Plan and the Development Control System

1
1 1 1 2 2 3 3 3 4 4 5

2.

The National Planning Context


2.1 Planning Policy Statement 22 (PPS22): Renewable Energy

7
7

3.

The Regional Planning Context


3.1 3.2 3.3 3.4 3.5 3.5.1 3.5.2 3.5.3 3.5.4 3.6 East of England Regional Spatial Strategy (RSS) East of England Sustainable Development Round Table, 2001 East of England Draft Plan, December 2004 Regional Planning advice for Local Development Frameworks Regional Planning Advice on Location Sustainable Communities Plan growth areas Settlements outside growth areas Non-designated landscapes Designated landscapes Hertfordshire Structure Plan

11
11 11 11 13 14 15 15 15 15 16

4.

The Local Planning Context


4.1 PPS12 on LDFs

17
17

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

vi

5.

Planning Issues
5.1 5.2 5.2.1 5.2.2 5.2.3 5.2.4 5.2.5 5.2.6 5.2.7 5.3 5.3.1 5.3.2 5.3.3 5.3.4 5.3.5 5.3.6 5.4 5.5 5.6 The Different Forms of RE and their Implications for Planning Wind power Project Initiation Evaluation Implementation Maintenance Decommissioning Smaller Scale Turbines Domestic wind turbines Biomass energy Co-firing Large-scale power generation Small to Medium-scale power generation and CHP schemes Power generation from waste Transport fuels EIA requirements Water power Solar power Landfill gas

19
19 19 19 20 21 21 21 22 22 22 23 23 25 25 26 26 27 27 28

6.

Renewable Energy Development in Hertfordshire


6.1 6.2 The Potential for RE in Hertfordshire Meeting the Targets

29
29 29

7.

Local Planning Approach


7.1 7.2 7.3 7.4 7.5 7.5.1 7.5.2 The Vision Sustainability and Plan Objectives The Wider Context Woking Borough Council Cornwall Cornwall Structure Plan The District Local Plans

31
31 31 34 34 35 36 36

8.

Local Planning Policies


8.1 Local Planning Policies

39
39

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

vii

8.2 8.3 8.4 8.4.1 8.4.2 8.4.3 8.4.4 8.4.5 8.4.6 8.4.7 8.4.8 8.5 8.5.1 8.5.2 8.5.3 8.5.4 8.5.5 8.5.6 8.5.7 8.6 8.6.1 8.6.2 8.6.3 8.7 8.7.1 8.7.2 8.7.3 8.7.4 8.7.5 8.8 8.8.1 8.8.2 8.9

Good Practice The Assessment of Policies A General Criteria-based Policy Government Guidance Woking Borough Local Plan Penwith Local Plan Rochford District Local Plan Caradon Local Plan Oldham Unitary Development Plan London Borough of Merton Recommended Policy Wording Checklist A Policy for Renewable Energy in New Development Government Guidance Planning Officers Society Woking Borough Council London Borough of Merton Oldham Metropolitan Borough Council Recommended Policy Wording Checklist South East Plan Opinion Poll A Policy Supporting Small-scale Renewable Energy Government Guidance Community Involvement Community-based Projects Policies on particular types of Renewable Energy Government Guidance Penwith Local Plan Oldham Unitary Development Plan Caradon Local Plan Recommended Policy Wording Checklist Policies that promote a form of Renewable Energy in an Area Government Guidance Regional and Sub-Regional Considerations SMART Policies

39 40 42 42 42 43 43 44 44 45 46 47 47 47 48 48 49 50 52 53 53 53 54 54 54 54 55 56 57 58 58 59 59

9.

Planning Applications
9.1 9.2 9.3 9.4 Planning Applications Housing Developments Development Control Issues Environmental Impact Assessments

61
61 62 63 64

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

viii

9.4.1 9.4.2 9.4.3 9.5

The Environmental Statement Schedule 1 development Schedule 2 development London Renewables advice to Planning Authorities

64 64 65 66

10. Monitoring
10.1 10.1.1 10.1.2 10.1.3 10.1.4 Monitoring Renewable Energy Targets East of England Plan East of England Sustainable Development Framework Monitoring in the South East Region Monitoring Nationally

67
67 67 67 68 69

11. The Options for Planning


11.1 11.2 11.3 11.3.1 11.3.2 11.3.3 11.3.4 11.3.5 11.3.6 11.3.7 11.3.8 Business as Usual What is Possible Extending the Case for Renewables Renewable energy requirements for new development The Contribution from New Housing Development The Implications of a New Policy Sustainable Buildings Combined Heat and Power Community Heating Promoting Wind Energy Energy Consumption Statements

71
71 71 72 72 73 74 75 76 77 78 78
11 30 52 67 73 74

Table 3.1 Regional renewable energy targets for the East of England 2010 and 2020 Table 6.1 Potential renewable energy production in Hertfordshire by 2010 Table 8.1 South East Plan MORI Poll Table 11.1 East of England Plan Indicators Table 11.1 Proposed New Dwellings 2001-2021, Draft East of England Plan, Dec 2004 Table 11.2 Estimated Number of Dwellings Requiring Planning Permission after 2008

Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Appendix 6 Appendix 7 Appendix 8

Recent Renewable Energy Planning Applications in Hertfordshire Examples of Renewable Energy Schemes Public attitudes to Renewable Energy Renewable Energy in an AONB Code for Sustainable Building Sustainable Building Task Group Report Policy ENV8 in the Draft Regional Plan Information Sources

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

1. Introduction

1.1 The Study


Entec UK Ltd was engaged by the clients, Hertfordshire County Council, Hertfordshire Environmental Forum (HEF) and the Hertfordshire Technical Chief Officers Association (HTCOA), to undertake research to identify the realistic potential for renewable energy development in the county and to explore the opportunities and constraints to this form of development.

1.2 Study Objectives


The objectives of the study were to: ! ! ! ! ! ! ! ! develop a clear understanding of the constraints and barriers to renewable energy project development; develop realistic renewable energy targets with broad agreement from the key stakeholders; identify locational and technological criteria for assessing proposed projects; develop scenarios to aid the understanding of policy options and potential implications for the county; develop model policies to inform local development frameworks and development control decisions; improve understanding between planners, developers, potential developers and other key stakeholders; present clear advice on how to maximise the potential direct and indirect benefits of renewable energy developments; and maximise the training potential of this exercise for members and officers in the county.

1.3 The Renewable Energy Options Report


This report should be read with the Renewable Options Report which details the technical background to renewable energy in Hertfordshire. Together, this and the Options report represent the response to the objectives of the study and its brief. The Renewable Options Report was first circulated as an interim consultation document in January 2005 when it provided key information to stakeholders, illustrated what renewable energy could look like in Hertfordshire, and identified what barriers are needed to be overcome to enable renewable energy to happen. The January 2005 report was then updated following a workshop for stakeholders and published in the form of a separate companion report, entitled Renewable Energy Options for Hertfordshire.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

This report deals with the role that the local planning system might play in the development of renewable energy. In particular, this report deals with advice on the subject of renewable energy in respect of local development frameworks and development control decisions. The earlier report of January 2005 indicated that there is the technical potential within Hertfordshire to achieve the levels of renewable energy production being sought at the regional level. Achievement of the technical levels would, however, be highly dependent upon a range of factors, many of which will be beyond the direct influence of stakeholders within Hertfordshire. Whilst strong regional and local planning policies, combined with increasing public awareness, could play a major part in attracting developers and influencing the deployment of renewable technologies in Hertfordshire, one of the most important factors influencing the uptake is commercial competitiveness (financial viability). In turn, competition and financial considerations will be strongly influenced by a wide range of global political factors, national regulations, and grant schemes, as well as the fundamental economic viability of the technologies. However, for the more competitive renewable technologies, such as onshore wind, planning policy will remain a critical issue for attracting commercial developers. In 2004, a review for the East of England Sustainable Development Round Table proposed a target of 153 GWh of electricity to be produced from within the county of Hertfordshire by 2010, with estimated contributions as follows: Onshore Wind: 96,000 MWh per year Biomass: 57,000 MWh per year Total: 153,000 MWh per year

1.4 Structure of the Report


The structure of this particular planning considerations report, as part of Entecs overall Hertfordshire Renewable Energy Study, is as follows. 1.4.1 Sections Section 2 sets out the national planning context by reference to Planning Policy Statement 22 on renewable energy. Section 3 examines the regional planning context and in particular the draft East of England Plan published in December 2004. Section 4 briefly considers the local planning context with regard to the advice in Planning Policy Statement 12 on Local Development Frameworks. Section 5 discusses some of the main planning issues that arise as a result of the different forms of renewable energy and some of the implications for planning associated with the various technologies and developments. Section 6 cross refers to the main findings in the Renewable Options Report, including the potential for meeting the targets for renewable energy in Hertfordshire.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Section 7 is an introduction to the local planning approach that authorities can consider, including some examples of more general approaches to energy matters that certain local authorities have adopted. Section 8 sets out an analysis of possible approaches to the construction of local planning policies, including examples from other authorities. The report provides a framework for local planning authorities to be able to consider and construct their own wording and set of policies as part of their Local Development Framework process. Section 9 provides some basic guidance on dealing with planning applications in relation to renewable energy proposals, including an example of advice to planning authorities in London. Section 10 deals briefly with question of monitoring and the systems that will need to be considered in the future. Section 11 concludes by examining the options for planning, expressed in the form of business as usual, possible and extended, including recommendations on future planning policy and research. 1.4.2 Appendices The report also contains the following additional information in the form of appendices:
Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Appendix 6 Appendix 7 Appendix 8 Recent Renewable Energy Planning Applications in Hertfordshire Examples of Renewable Energy Schemes Public attitudes to Renewable Energy Renewable Energy in an AONB Code for Sustainable Building Sustainable Building Task Group Report Policy ENV8 in the Draft Regional Plan Information Sources

1.5 The Planning System


In dealing with the role that the local planning system might play in the development of renewable energy, a brief description of the planning policy context is described below. The planning system in the UK operates within a hierarchical structure of guidance and plans covering the national, regional and local levels. 1.5.1 National Planning and Policy Statements Climate Convention (1997 Kyoto Conference) Under the Kyoto Protocol, the UK has committed to reduce Greenhouse Gas emissions overall by 12.5% below 1990 levels by 2008-2012. Climate Change the UK Programme (2000, UK government) In order to achieve the above target, the government has set a domestic goal of a 20% reduction in CO emissions by 2010 set out in the Climate Change Programme. The Energy White Paper Our energy future creating a low carbon economy (2003) This white paper set out four key goals:

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

! ! ! !

To cut CO emissions by 60%, by about 2050 To maintain the reliability of energy supplies To promote sustainable economic growth To ensure every home is adequately and affordably heated

Achieving emissions reductions of these magnitudes will require significant behavioural changes, with potentially major impacts on businesses and communities. Substantial improvements in energy efficiency will be required, but will also have to be accompanied by a major reduction in fossil fuel usage. The Energy White Paper also sets a target to supply 10% of the UKs electricity from zerocarbon, or carbon neutral, renewable sources (such as wind, wave, tidal, hydro and solar power, and biomass) by 2010, and a target of 20% of the UKs electricity by 2020. 1.5.2 Regional Planning and Regional Spatial Strategies Under the Planning and Compulsory Purchase Act 2004, existing Regional Planning Guidance documents (RPGs) are being replaced by new statutory Regional Spatial Strategies (RSS), which will form part of the statutory development plan. Each RSS is intended to be more regionally specific than previous guidance, reflecting regional diversity, and there will be greater flexibility for a RSS to depart from national policy where that is justified by regional circumstances. The East of England Plan is, at the moment, a draft revision to the Regional Spatial Strategy for the East of England. The formerly approved regional plan is known as Regional Planning Guidance 14 (RPG14), whilst the new RSS will be referred to as the East of England Plan. The East of England Plan is the document that sets out the strategy to guide planning and development in the East of England to the year 2021. The East of England Plan is dealt with in detail in Section 3 of this report. 1.5.3 Local Development Frameworks In September 2004 the Planning and Compulsory Purchase Act 2004 introduced significant changes for development plan preparation. The old system of Structure Plans, Local Plans and Supplementary Planning Guidance is now being replaced with Local Development Frameworks (LDFs) for each local planning authority. Local Development Frameworks are intended to streamline the local planning process, by incorporating greater flexibility and front loading in the process, by increasing community and stakeholder involvement, and by promoting sustainability. Local development documents (which will make up the LDF) will go beyond the development and use of land, to include policies that influence the nature of places and how they function. These documents are intended to be developed via a continuous, rather than fixed, interval process. The LDF must be in general conformity to Regional and National policies. For renewable energy, regional guidance determines the broad criteria and locations for development in order to guide the preparation of the local development documents. These should contain a spatial strategy for renewable energy including type, mix and broad location of development (with details and maps of specific sites and proposals if relevant).

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

LDFs will need to have regard for the resources, in broad terms only, likely to be available for implementing policies that encourage renewable energy developments. 1.5.4 The Development Plan and the Development Control System Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that if regard is to be had to the development plan for the purpose of any determination to be made under the planning Acts, the determination must be made in accordance with the plan unless material considerations indicate otherwise. Where a policy or proposal exists in the development plan (i.e. in the adopted RSS or LDF) which is relevant to a particular planning application proposal, then the decision-maker must have regard to that policy or proposal, unless material considerations indicate otherwise. The LDFs will therefore be crucial in setting the local policies and proposals for their areas, which in turn will influence how prospective applicants and developers will look at the opportunities and constraints within each administrative area.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

2. The National Planning Context

2.1 Planning Policy Statement 22 (PPS22): Renewable Energy


PPS22 sets out the Governments national land use planning policies for renewable energy. The ODPM has also produced Planning for Renewable Energy: A Companion Guide to PPS22 which offers practical advice as to how these policies can be implemented on the ground. The Companion Guide also includes examples of best practice. (For PPS22 and the guide, go to http://www.odpm.gov.uk/stellent/groups/odpm_control/documents/contentservertemplate/odpm _index.hcst?n=5681&l=3 ) The Government is committed to delivering 10% of electricity from renewable sources by 2010 and 20% by 2020. PPS22 aims to strongly encourage the development of renewable energy schemes, in both urban and rural locations, in order to contribute towards these targets. A range of sizes of renewable energy developments are anticipated, from domestic through to commercial scales, and utilising a wide range of different technologies (e.g. biomass, energy from waste using biological and thermal processes, small hydro, solar electricity, solar heating and wind). PPS22 includes a number of key principles relevant to local planning authorities (LPAs) as follows: Local Development Documents should contain policies designed to promote and encourage, rather than restrict, the development of renewable energy resources. Planning authorities should set criteria to be applied in assessing planning applications for renewable energy projects. PPS22 underlines that particular renewable energy technologies cannot be ruled out or restrained without sufficient reasoned justification and that poorly justified constraints may be subject to government intervention. The wider environmental and economic benefits of renewable energy proposals are material considerations in determining whether proposals should be granted planning permission. local planning authorities should not make assumptions about the technical and commercial feasibility of renewable energy projects. Small scale projects can provide a limited but valuable contribution to overall outputs Local Planning Authorities should foster community involvement in renewable energy projects

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Development proposals should demonstrate environmental, economic and social benefits as well as how environmental and social impacts can be minimised PPS22 and its Companion Guide provide specific advice to LPAs on the preparation of Local Development Documents. A summary of the key elements, which are of relevance to Hertfordshire, is set out below. LPAs should only allocate specific sites for renewable energy in plans where a developer has already indicated an interest in the site. Plans should set out criteria based policies for assessing planning applications for renewable energy. It is likely that there will be two types of policy areas dealt with by criteria-based policies, supported by an overarching policy in the core strategy. These would relate to: Standalone renewable energy schemes The Companion Guide states that it is important that policies address the full range of technologies and not just those highlighted in the Regional Spatial Strategy. The policy should address impacts on landscape, townscape, natural, historical and cultural features (possibly referenced to a landscape Character and Sensitivity Assessment). There should also be reference to the impacts on the amenity of the area in relation to visual intrusion, noise, dust, odour and traffic. Integration in new development PPS22 states that LPAs may include policies that require a percentage of the energy to be used in new residential, commercial or industrial developments to come from on-site renewable energy developments. Such policies should ensure that the requirement is only applied to developments where the installation of renewable energy is viable. They should also be flexible and not place an undue burden on developers in terms of the proportion or type of renewable energy to be provided. PPS22 also provides further policy advice on certain locational considerations. For example, in relation to nationally recognized designations such as Areas of Outstanding Natural Beauty (AONB), planning permission should only be granted where it can be demonstrated that the objectives of the designation will not be compromised by the development. Small-scale developments should be permitted provided there is no overriding environmental detriment. With parts of The Chilterns AONB falling within Hertfordshire, an example is provided at Appendix 4 on planning guidance published within the last year for the Blackdown Hills AONB on renewable energy and wind turbines. In Green Belts many renewable energy projects will comprise inappropriate development and therefore careful consideration needs to be given to the visual impact of the project. Developers will need to demonstrate very special circumstances, which outweigh any harm, if projects are to proceed. PPS22 also points out that LPAs should not adopt a sequential approach in considering renewable energy projects, as most renewable energy resources can only be developed where the resource exists. Some previously developed sites may, however, be suitable, particularly where they are in remote locations unsuitable for other uses. It also states that many type of renewable energy are capable of being accommodated in urban, as well as rural, areas and that criteria based policies should reflect this situation. PPS22 and the Companion Guide advise that Supplementary Planning Documents could play a critical role in implementing renewable schemes. Topics that such documents might cover

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

include design guidance on integrating renewables, or site development briefs where renewable generation is to be included.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

10

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

11

3. The Regional Planning Context

3.1 East of England Regional Spatial Strategy (RSS)


The East of England Regional Spatial Strategy (December 2004) is currently undergoing review and a draft version was the subject of consultation from 8 December 2004 to 16 March 2005. An Examination in Public is scheduled to begin on 13 September 2005. Following the Examination, the Panel will produce a report on its recommendations and, in the light of these recommendations, the Secretary of State will propose changes to the draft East of England Plan. These proposed changes will then be the subject of a further round of consultation before the Plan is published in its final form by the Secretary of State.

3.2 East of England Sustainable Development Round Table, 2001


In order to identify suitable regional targets to help meet national targets, the East of England Sustainable Development Round Table regional partnership commissioned research that concluded that the renewable energy technologies with the greatest potential for the region are off-shore and on-shore wind, biomass, bio-fuels and solar power.

Table 3.1 Regional renewable energy targets for the East of England 2010 and 2020
2010 Excl. off-shore wind 10% 2010 Incl. off-shore wind 14% 2020 Excl. off-shore wind 17% 2020 Incl. off-shore wind 44%

Although the report in 2001, Making Renewable Energy a Reality: Setting a Challenging Target for the East of England, highlighted the fact that use of wind power is expected to contribute significantly to meeting the 2010 target, developments using a range of technologies, from domestic through to large commercial ventures, will also be required. Many renewable energy technologies are best suited to small- and medium-scale generation and distribution such that every area in the region, including those not previously accommodating generation infrastructure, will need to promote renewable energy development. For those technologies not yet commercially tested, demonstrator projects would need to be approved now in order to establish effective operation in time to meet the targets.

3.3 East of England Draft Plan, December 2004


The East of England Regional Spatial Strategy (December 2004), when eventually approved, will form the statutory framework for local development plans and transport plans produced by

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

12

the local authorities in the region. The draft plan aims to address the four keys areas of sustainable development, namely: Social progress which recognises the needs of everybody Effective protection of the environment Product use of natural resources The maintenance of high and stable levels of economic growth and employment. In order to enable the quantum move required towards the use of renewable energy, there are many policies within the Spatial Strategy specifically designed to promote its usage. These are summarised below: Policy SS16: Quality in the built environment Promotion of design excellence, including increased building energy efficiency and use of renewable energy supplies. Policy NSR1: Promoting cluster and strategic sites Renewable energy highlighted as an emerging strategic employment cluster / sector. Policy NSR5: Transport infrastructure Transport improvements to support renewable energy generation will be prioritised (subject to site approval). Policy GYL1: Economy and regeneration Promotion of renewable energy employment cluster (utilising existing offshore engineering skills). Policy KL1: Kings Lynn sub-region Attraction of investment in expanding economic sectors, including bio-fuels and other renewable energy technologies. Policy T11: Environment and safety When implementing renewable energy, transport planning, movement corridors and investment should minimise environmental damage and take into account national designations and landscape character. Policy ENV8: Renewable energy and energy efficiency This is the main policy for the promotion of energy efficiency and renewable energy. The draft policy and its supporting text, as published in December 2004, is reproduced in full at Appendix 7.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

13

3.4 Regional Planning advice for Local Development Frameworks


The draft version of the East of England Regional Spatial Strategy (December 2004) currently requires Local Development Documents to: Contain policies for promoting and encouraging energy efficiency and renewable energy, presuming in favour of renewable energy development. Require developers to maximise energy efficiencies to be gained from sustainable design and construction, community heating and combined heat and power schemes Encourage developers to strive to achieve energy efficiency standards that exceed minimum standards. Require energy consumption statements for development proposals above a threshold of 1000 sq. m., or 50 dwellings, in order to ensure that the technical, environmental and economic feasibility of alternative systems such as decentralised energy supply systems based on renewable energy combined head and power (CHP) district or block heating or cooling, if available heat pumps, under certain conditions are considered and taken into account before construction starts. Require all developments above a threshold of 1000 sq. m., or 50 dwellings, to incorporate equipment for renewable power generation so as to provide at least 10% of their predicted energy requirements. Specify the locational and other criteria by which applications for renewable energy developments will be assessed. Define and relate renewable energy and energy efficiency policies to the Sustainable Communities Plan Growth Areas, the settlements outside these Growth Areas, and designated and non-designated landscapes, in accordance with the detailed guidance provided in the RSS. Favourably consider the onshore developments associated with offshore energy generation. Encourage the use of existing infrastructure and the under-grounding of cables connecting new plant to the grid, wherever possible. Encourage methane exploitation from appropriate landfill sites, provided this is not used to prolong landfill operations beyond currently agreed targets. Actively encourage the development of community-based schemes in accordance with the detailed guidance provided in the RSS.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

14

The RSS considers that supplementary planning guidance and development briefs should be used by the local planning authorities to support the above policies, where appropriate. Renewable energy technologies include photovoltaic energy, solar-powered and geo-thermal water heating, wind (onshore and, where relevant, offshore), energy crops and biomass, energy from human sewage and agricultural plant and animal waste, but not energy from domestic or industrial waste, except the harvesting of methane from existing landfill sites.

3.5 Regional Planning Advice on Location


Appendix C of the draft East of England Plan provides further guidance to LPAs on locational considerations and criteria. This states that Renewable energy developments have to be located where they are technologically and economically feasible. As this can range from heavily urbanised to remote rural areas, all parts of the region are potentially suited to some form of renewable energy technology. Areas of search for renewables are not considered appropriate at this time as renewable energy technology is subject to rapid technological change, with new, and more efficient, equipment constantly coming on-stream. The Appendix sets out principles for determining locational criteria for renewable energy development based on: A regional energy hierarchy i.e. in descending order of priority; o o o
o

use less/reduce the need for energy use energy more efficiently use renewable energy use clean and efficient technology for fossil fuel powered heating and cogeneration.

A spatial approach - local development documents should define and relate renewable energy and energy efficiency policies to: o o o
o

sub-regional growth areas settlements outside growth areas non-designated landscapes designated landscapes.

Small-scale and community-based schemes appropriate to local need are most likely to be permissible in areas which are: o o o
o

within or close to settlements within suitable landscapes close to the origin of the energy resource close to groups of buildings (in rural areas).

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

15

LPAs are advised to incorporate detailed criteria related to the following spatial categories in their local development documents. 3.5.1 Sustainable Communities Plan growth areas These are seen as areas of maximum potential for the development of renewable energy technology and the application of energy efficiency measures by virtue of the opportunities for new homes, business and commercial developments. Given the scale and level of development the scope for energy efficiency measures, combined heat and power (CHP) and district heating schemes presents the region with a significant prospect of meeting energy saving and climate change/greenhouse gas emission targets. The major opportunities are seen as energy from sewage waste, wind, solar and methane. Agricultural land within the growth areas also has potential for energy crops with the added advantage of reduced transport distances to generation plants that will be easier to locate on urban / urban edge sites. 3.5.2 Settlements outside growth areas Whilst development rates will be slower in these areas than the Sustainable Communities Plan growth areas there is still seen to be significant potential to develop renewable energy and energy efficiency measures in new development. Renewable energy technology opportunities will be more limited, with solar and small-scale wind being most suitable. Settlement edges however, will have potential for larger-scale wind, energy crops, energy from sewage waste and landfill methane. Towns will also provide locations for siting generation plants for combusting energy crops from adjacent farms. 3.5.3 Non-designated landscapes These areas comprise primarily agricultural land and woodland, covering the majority of the regions area. The non-designated landscapes are likely to be the principal locations for largescale developments associated with wind, biomass and agricultural wastes, with their related combustion plants and infrastructure. They may also be the areas to accommodate smallerscale developments, including individual, or small groups of, turbines, hydro schemes and sewage plant bio-gas installations. The Appendix states that the potential for using these developments as a focus for regenerating the rural economy should be a major policy objective of local development documents. 3.5.4 Designated landscapes Areas statutorily designated internationally and nationally for the protection of their landscape quality, coastal heritage, biodiversity, cultural and heritage interests designations are not considered to be suitable for the construction of large-scale renewable energy infrastructure, especially wind-turbines. However, small-scale developments of wind turbines, energy crops, hydro schemes and bio-gas from small sewage plants may be acceptable.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

16

Developers should be required to undertake assessments to demonstrate that adverse impacts can be satisfactorily addressed. They should also show that that there is an overriding need for the development in terms of local social and economic conditions. The Appendix also states that Local Development Documents and Supplementary Planning Documents should specify detailed criteria specifying energy efficiency standards in excess of the minimum (using SAP rating, Ecohomes rating or BREEAM (the Building Research Establishment Environmental Assessment Method). Local planning authorities should require that all new residential development achieve an NHER of at least 10. Local Development Documents, supported by supplementary guidance, should also specify detailed locational criteria related to the following renewable energy technologies; solar photovoltaic, solar thermal, wind, small scale hydro, biomass and combined heat and power. These criteria should focus on encouraging the development of such technologies and mitigating their effects, rather than as a basis for justifying the refusal.

3.6 Hertfordshire Structure Plan


Until the East of England Plan is adopted, the development plan for Hertfordshire will comprise the adopted Hertfordshire Structure Plan and all relevant adopted Local Plans. Policy 54 deals with energy generation and states that, where there is a viable choice between development to generate energy by renewable or non-renewable means, priority will be given to renewable generation, subject to the other policies of this Plan. Renewable energy developments are supported subject to their impacts.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

17

4. The Local Planning Context

4.1 PPS12 on LDFs


Planning Policy Statement 12 (PPS12) on Local Development Frameworks (LDFs) outlines the new system of development plans. The shift towards community involvement, sustainability and spatial planning lie at the heart of the change. This approach will require the integration of environmental, social and economic considerations in the light of local conditions. In order to improve efficiency and effectiveness of the planning system, there is an emphasis on the principle of front-loaded and evidence-based decision-making. The Local Development Frameworks portfolio will consist of : A Statement of Community Involvement Development Plan Documents A Core Strategy Policies and proposals on land-use topics (including site-specific allocations) Area Action Plans A Proposals Map Supplementary Planning Documents Within Hertfordshire, 10 separate local planning authorities (LPAs) will be preparing LDFs, all of which will need to include the subject of renewable energy development proposals. A Local Development Scheme, submitted by each LPA, sets out the LDF programme and timetable. PPS12, in respect of the LDF, talks of LPAs having a proactive positive approach to managing development that is: Flexible Appraised for sustainability Managed efficiently Sound and based on robust credible evidence and that: Strengthens community and stakeholder involvement Front-loads the process PPS12 states that LPAs should adopt a spatial planning approach to LDFs in order to ensure the most efficient use of land and to approach this objective by balancing competing demands within the context of sustainable development.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

18

PPS12 explains that the new form of spatial planning: Goes beyond traditional land use planning; Means that planning can consider the wider issues (such as the issues associated with carbon reduction and renewable energy promotion); Enables development and land use plans to be brought together with other policies and programmes; and Means that there is a need to work collaboratively.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

19

5. Planning Issues

5.1 The Different Forms of RE and their Implications for Planning


Renewable energy is used to describe the various ways in which continuous energy flows that occur naturally in the environment, from the sun, wind, oceans, plants and the fall of water, are harnessed. Energy from waste is also referred to as renewable energy where it emanates from within the earth. National policy is to encourage the development and use of renewable energy resources where they have prospects of being economically viable and environmentally acceptable. The aim is to reduce the adverse environmental impacts of producing energy from fossil fuels, notably carbon dioxide (CO) emissions. In addition, renewable energy sources can also contribute towards the greater diversity and security of the nations energy supply. It must be recognised, however, that some renewable energy resources can only be utilised where they occur and that often their location will be, as a matter of necessity or convenience, in rural areas and open landscapes. It is the planning system that is left to try to ensure that a balance is achieved between utilising and, indeed, encouraging the particular energy resource and the need to take account the potential impact on the local environment and amenities.

5.2 Wind power


5.2.1 Project Initiation Wind energy is recognised as one of the most promising renewable resources and the technology is well advanced. Wind turbines can be deployed singly, in small clusters, or in larger wind farms. Developers are generally attracted to areas of higher elevation and open landscapes in order to find the best wind resource with sufficiently high annual mean wind speeds. Knowledge of the local wind resource is critical to designing a wind energy system and predicting its output. For domestic installations, a good source of information on local wind speeds is the NOABL database. For a major wind farm development, a developer would normally need to seek permission to erect a temporary mast of at least 40 metres in height for monitoring the wind speeds for a period of between 12 and 18 months. The scale of the proposed wind power development is seen by developers as crucial to the planning risk. Many developers have chosen to concentrate on developments over the 50MW threshold defined by Section 36 of the Electricity Act, which require DTI approval, rather than rely on the unpredictability of local authority planning approvals. However, Hertfordshire is probably not best placed to win large-scale development due to local wind conditions. Similarly, small-scale schemes tend to involve local power distribution and often local ownership, significantly improving local support. It is the mid-range schemes (5 to 30MW) which have encountered the most resistance during the planning process. In order to meet the regional targets, it will be essential to promote schemes of all scales to obtain maximum benefit. Therefore, it is important that planning policies and guidance are tailored to meet the needs of each of the various scales of development.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

20

In order to reduce risk, developers will seek out those local authorities offering favourable development climates, i.e. those adopting a proactive rather than reactionary stance. The cost of local educational programmes (for the general public, planning officers and committee members) has been a significant factor in development appraisals, encouraging developers towards local authorities that have engaged with the impact of renewable energy as part of their Agenda 21 work. 5.2.2 Evaluation Local authorities can significantly increase the likelihood of development proposals coming forward by producing indicative potential development maps for their areas. These could indicate not only wind speed data and grid accessibility information, but also safeguarded areas (e.g. airport/low flying/radar zones, areas of high landscaping sensitivity), transport route separation zones, communication line-of-site pathways, residential developments and cumulative wind-farm development separation data. Indications could be given for which areas could accommodate large schemes, which would be more suitable for mid-range schemes (depending on the particulars of the site), and which could at best support small-scale schemes subject to sensitive development. Visual amenity is often a primary factor in planning applications. Individual turbines and wind farms are highly visible over wide areas and while it might be possible to locate such developments in sympathy with the landform and existing features in the landscape, regard must also be paid to their wider landscape impact. (For example, grid connections could be routed underground, to ameliorate visual impact, though this will considerably add to development costs and environmental disturbance). There is also a need to consider the potential cumulative impact that might occur with two or more schemes in an area. i.e. The number, size, layout, colour, height, profile and cumulative impact of the proposals need to be considered, together with the impact of additional power lines, fencing, buildings, sub-stations, access tracks (including surfacing materials, cuttings, embankments, drainage channels), and anemometer masts. Wind turbines can also cause problems of shadow flicker, reflected light, television and radio interference and noise, both from the turbine and the blade movement. A suggested minimum separation could be specified in planning policies between wind turbines and nearby dwellings in order to prevent issues of visual and noise disturbance, or left variable (but sufficient) depending on factors such as wind direction or background noise. The potential for noise generation is generally the biggest factor for deciding how much generating capacity can be installed at a potential site. During the EIA and site design process, noise minimisation will often heavily influence the layout and design. Wind turbines can also affect electromagnetic signals as used by television broadcasting and radio communications, although many options for fixing potential television reception problems are available. Fixed communication links require a line-of-sight path between the transmitter and receiver and thus a wind farm can be designed so that turbines are placed away from the line of sight in order to avoid affecting such communication links. The Radio-communications Agency (RA) holds a central register of all civil radio communications installations in the UK. Areas of nature conservation or archaeological importance are normally avoided by developers, although protected species or habitats might exist at any site. In many cases, archaeological features are relatively small and in a buried, or ruined, state. It is relatively straightforward for a wind farm to be designed around such features and proper on-site construction standards will

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

21

ensure that such protected sites remain intact. More significant cultural heritage features and their settings are, of course, protected from any developments through national and local planning policy. Due to the large investment in planning and developing wind infrastructure, larger-scale developers are inclined to avoid areas with designated protection policies in development plans, such as Green Belts and AONBs, although it is not uncommon to come across proposals for individual turbines in such areas. National grid connection, or the lack of it, is becoming an increasingly significant barrier to the development of many wind farm projects. A connection to the local electricity network, which can carry away all the generated electricity from the site at an affordable price, is essential for a successful project. However, small-scale wind power is particularly suitable for remote off-grid locations where conventional methods of supply are expensive or impractical. As the proportion of energy generated from wind-power increases, the impact on grid balancing becomes significant, and use of large-scale energy storage schemes such as hydro-pumping become necessary. Local use and storage of the generated electricity mitigates this issue, promoting the location of turbines in industrial or urban locations. 5.2.3 Implementation Modern commercial wind turbines are extremely large structures, with a 2MW wind turbine having blades of 40 metres in length that would arrive on site on 47 metre-long lorries. The erection of a 2MW turbine requires either an 800 tonne mobile crane, or a massive crawler crane. Traffic generation during construction needs to be considered and the roads to the site must be able to accommodate the largest vehicles, as well as other construction traffic. It must also be possible to build roads across the site, which allow the construction traffic to work. Wind farm access roads and foundations could effect local hydrology, which in turn will have an influence on local habitats and water abstraction. The restoration of temporary construction roads back to their original land use could be a matter for planning conditions. Typically a developer would expect a 9 to 30-month programme to develop a project (i.e. secure planning consent and reach financial close), with a further 9 to 18-month programme for construction. These time-scales are of course dependent upon the scale of the project, the site location and the prevailing public opinion towards the proposal. Significant public opposition or EIA issues can effectively prevent wind-power development due to excessive development timescales. 5.2.4 Maintenance The actual land take with wind turbines is minimal. Whilst wind farms usually extend over large areas of land, traditional farming is relatively unimpeded and only about 1% to 5% of the wind farm area is normally rendered unusable for farming or other uses by the development. Equipment maintenance generates little traffic, with most monitoring and control being performed remotely. 5.2.5 Decommissioning Since most wind turbines have an operational life of around 20-30 years, consideration should be given to the future of the site. Turbines can be re-powered with more efficient (possibly smaller) systems, or replaced, or removed completely. Decommissioning should be the subject

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

22

of appropriate planning conditions that require the reinstatement of the landscape and its vegetation. 5.2.6 Smaller Scale Turbines TV (Thames Valley) Energy provide the support for the Countryside Agencys Community Renewables Initiative covering Berkshire, Buckinghamshire and Oxfordshire. Their information sheet for community groups and not-for-profit organisations states: Small wind turbines are sized at a hub height of 25 metres and under. Turbines need to be mounted on a tower of a height that reduces the blocking effect of the buildings, residential properties and trees. They are noiseless, but a planning application will be required. Windspeeds are the vital factor, with wind speeds of 5 m per second and above, at a height of 10m being recommended. Clearskies grants are available for 50% of installed capital costs and a 6kW turbine will cost in the region of 19,000. This will generate approximately 14,000 units of electricity when wind speeds average 5.5m per second at a hub height of 15m. 5.2.7 Domestic wind turbines Later this year, British Gas has announced that the company will be commencing a trial programme of domestic-size wind turbines on houses in Scotland and South West England, which, if successful, could be expanded to include properties across the whole of the UK. The vanes extend to 1.75m (about 5ft 9in) from vane tip to vane tip. The structure bolts on to a property wall or gable-end of a building, similar to a satellite dish, and stands about 2.5 metres (about 8ft 2in) high. British Gas estimates that the small turbine would produce around 1 kilowatt of electricity, which might cut around one-third of an average household electricity bill and reduce CO emissions by about half a tonne per annum. The turbine would cost around 1,500, including installation, and would operate in wind speeds as low as three miles per hour. It is the first time a major supplier has tested domestic wind turbines, although some homeowners have already bought and installed such equipment. Properties taking part in the trial will be in both urban and rural areas, although it clearly going to be easier to accommodate such potentially noticeable and intrusive structures on larger and more isolated dwellings. In many instances, planning permission is likely to be required, for example if the structure is higher than the apex of the roof of a dwelling. The turbine manufacturer in the trial, Windsave, would like to see permitted development status for all such devices so that homeowners do not have to apply for planning permission on an individual basis, although this would appear to be optimistic and possibly not acceptable to communities where the visual impact of such equipment is perceived as far more obtrusive than ordinary TV aerials and satellite dishes.

5.3 Biomass energy


Biomass energy covers the full range from large-scale electricity production such as in commercial co-firing power stations, down to medium and small-scale electricity and heat production facilities, and domestic heating systems. It also covers transport fuels such as biodiesel and bio-ethanol derived from starch and oil crops and waste products.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

23

5.3.1 Co-firing Existing coal-fired power stations can burn up to 10% biomass products using existing technology, (though 5% may be nearer the practical limit due to problems of feedstock pulverization and combustibility). Co-firing is currently eligible for ROCs as a method of promoting the production of local feedstocks, however this is likely to end in 2016, increasing feedstock availability for dedicated biomass energy production. A wide range of biomass feedstocks have been trialed including specialist wood crops, cereal crops, olive pips, waste slurries and palm oil, though most are currently being imported due to lack of appropriate and adequate local fuel supplies. Increased transportation, associated with the shipment of bulky feedstocks, is the biggest planning impact of co-firing technology. However, a significant proportion of power stations currently use rail shipment. Since this method of renewable energy generation is unlikely to persist once ROC eligibility is removed, significant development in new offsite infrastructure is unlikely to be economically viable. 5.3.2 Large-scale power generation In order to be economically viable, biomass plants require large volumes of suitable fuel to be available at the lowest possible price, which generally means within a relatively close local area of the installation. Biomass may also be hampered in part from the lack of a wide enough market for the fuel that it requires to use and which therefore may not be made available in sufficient quantities within an accessible distance of the plant. Often biomass development occurs close to energy crop production sites or near specialist feedstock production such as chicken farms. As technology improvements increase the variety of viable feedstocks, the range of potential sites will grow. By far the most obvious and wide-ranging visual impact in the countryside is the growing of the energy crops, which of course does not require planning permission as such. (Although the growing of biomass crops does not fall under the control of the planning system, the Environmental Impact Assessment (EIA) Regulations introduced in February 2002 require land owners of permanent pastures / semi-natural habitats to inform Defra before converting land to intensive agriculture. Defra can then undertake an environmental assessment of this change and can prevent harmful changes from taking place.) Specialist wood crops such as willow or poplar are grown on a two to three-year rotation period. Straw and whole crop cereals can also be used, both annual and less-energy intensive perennial varieties. The growth of such crops could be undertaken on set-aside land and the production of crops for fuel could prove a valuable form of diversification for local farmers. In order to meet the targets defined from energy crops significant areas of land would need to be allocated to energy crop production. This would primarily be agricultural land, though the possibility of using brownfield land as part of a long-term reclamation process should not be ruled out. There must be a sufficient supply of the feedstock, of an appropriate quality and over the longterm, in order to operate the plant. The feedstock quality and consistency must be maintained throughout the entire life of the project. Grant support is available for the establishment and growing of energy crops, subject to certain rules, which include being located within a reasonable distance of the end use (10 mile radius for small installations, 25 miles for large installations), along with providing a minimum establishment of three hectares. One-off

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

24

payments are also available for the establishment of the crop. In the past, there was a differential between short rotation coppice (SRC) and miscanthus. However, reform of the Common Agricultural Policy (CAP) has made the enhanced rate for SRC redundant from 2005. CAP reform will also lead to replacement of the Arable Area Payments Scheme (AAPS) under which set-aside payments are made. The AAPS will be replaced by a single payment scheme from 2005. The current maximum limit for grant aid is 500,000. The establishment and growing of biomass may be supported through other schemes, including the Woodland Grant Scheme and the Farm Woodland Premium Scheme (on which there is up-to-date information available on the Defra web site at www.defra.gov.uk). Key issues for local planning authorities to consider when evaluating applications for biomass plant are: visual intrusion, including any chimneys, noise from engines, boilers, handling equipment and traffic, light pollution from plant operational around the clock, potential pollution of ground and water courses, emissions into the air, and traffic resulting from the transport of the fuel to the site and the subsequent removal of by-products and any waste. The kind of questions that would need to be asked about proposals that would generate a significant amount of traffic would be: What will be the traffic flows associated with the scheme? What will be the emissions from the vehicles? What access routes will be used for the delivery of the crop? What traffic management controls will be needed and proposed? What are the fuel handling and temporary storage requirements? Planning authorities may wish to control the number of vehicle movements of construction and operational traffic to and from the site in a specified period and, where possible, the route of such movements, particularly of heavy vehicles, by imposing suitable conditions, or entering into planning agreements with the developer. As with all thermal treatment processes, most concerns expressed involve the emission of pollutants to the atmosphere. (Pollution Prevention and Control for larger biomass plants is covered by the Environment Agency). Biomass developments are often seen as high-risk due to the high levels of investment finance required, potential variability of local fuel supplies and the need for an affordable national grid connection. However, with the increased interest in renewable energy technology as a commercial investment and recent changes in the 2004 Energy Act concerning favourable grid connection charging for renewable energy sources has lessened the financial barriers.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

25

5.3.3 Small to Medium-scale power generation and CHP schemes Many biomass plants will be small, only provide heat, and may be easily incorporated into existing or new buildings. Where they are included in agricultural buildings, they may not require specific planning permission if they are ancillary to the main use of the site. However, heat and power generation plants will require planning permission. The generating plant and activities directly related to it are subject to planning control, but the growing and harvesting the biomass crops are outside planning control. Small-scale schemes are now benefiting from maturing feedstock distribution networks, though transport costs can still be significant for locations remote from centres of production, and costs associated with storage requirements of sensitive fuels such as wood pellets. Fuel costs remain high in relation to conventional heating fuels such as natural gas and heating oil, and generally only warrant consideration for sites with no access to mains gas, and a need for constant heat production, unless combined with traditional facilities. CHP installations can improve economic viability by using heat off-take systems for use on adjacent sites and facilities. These are best designed in at initial installation as retro-fitting costs can be prohibitive. Also the existence of a local market for the waste products e.g. as fertiliser can significantly reduce running costs. However, unless ROCs are introduced for heat then commercial CHP development is unlikely to increase significantly. Biomass boilers for district heating, (where heat rather than energy is sold to consumers), are an option but currently these are uncommon in the UK. Local authorities could require new developments to consider the use of district heating, (particularly in thermally-efficient highdensity developments), or could mandate a minimum proportional of biomass heating provision. The most economically viable schemes at present use standard gas burners combined with solar (solar covering summer electrical needs, gas providing both electricity and heat in winter). Typically a developer would expect a 9 to 30-month programme to develop a project (i.e. secure planning consent and reach financial close), with a further 9 to 18-month programme for construction. These time-scales are of course dependent upon the scale of the project, the site location and the prevailing public opinion towards the proposal. 5.3.4 Power generation from waste Waste products such as chicken litter as used on a commercial basis as a successful feedstock, and trials are being conducted with other waste products such as used tyres. The digestion of farm slurry can produce a gas rich in methane, which has in the past been used on a very small scale to provide energy on the farmyard. It is possible, however, for slurry from several farms to be concentrated at a sewage-treatment works and there combined with sewage from the main drainage network before being subjected to digestion to produce bio-gas at an economically viable level. The energy produced can be in the form of heat as well as power. The main planning implications associated with such development include concern over pollutants, traffic generation, the visual impact of the digester tanks, gas holders and transmission lines and noise emissions. In order to be commercially viable, developments utilising waste products need to ensure longterm feedstock supply contracts. (Typically 50-75% of revenues are derived from gate fees). Most thermal technologies have limited fuel flexibility, and are unable to track fluctuations in feedstock quality and availability over the life of the project.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

26

The major public concern with the use of waste products as a feedstock is with emissions of pollutants into the atmosphere, with difficult planning applications being referred to Public Inquiry. Often Local Authority Waste Management Strategies preclude the use of incineration as a means of final disposal. Such costs and delays are a major disincentive for investors. 5.3.5 Transport fuels Bio-fuels will undoubtedly become an increasingly important transport fuel. Bio-diesel can be used alone, or blended with fossil-derived diesel. It can be used with no engine modifications and bio-diesel can even improve engine life due to increased lubrication. It can be delivered via the existing fuel infrastructure (e.g. Tesco currently offer a 5% blend). Bio-ethanol can be used as a supplement in petrol engines, but may require some engine modifications and development of the nation-wide fuel delivery infrastructure. The majority of feedstocks used for the production of bio-fuel and commodities traded worldwide and therefore influenced by international trade agreements, and hence commercial arrangements tend to be more complicated, particularly when considered against the typical project investment time-scales of 15-30 years. Currently imported feedstocks such as palm oil are more economically attractive than indigenous supplies (such as being used in the proposed Teesside facility), although a bio-diesel pilot plant exists in Ashford using waste cooking oil feedstock (benefiting from EU legislation forbidding the reuse of waste cooking oil in animal feed). Bio-fuels are more expensive to produce than fossil-derived fuels, but changes in the fuel duty and the increasing cost of a barrel of oil are reducing the margin. Support is also available for the establishment and growing of certain energy crops. This is significant since the economics of production are heavily influenced by transport costs, necessitating a local plentiful supply of feedstock. Major planning issues for fuel production facilities will involve feedstock and fuel transportation, storage requirements (visual impact, land use, safety etc.) and pollution control (such as environmental contamination). 5.3.6 EIA requirements All commercial biomass developments are likely to be subject to the need for Environmental Impact Assessments where situated within a 'sensitive area' or the area of the development exceeds 0.5 hectares. (Smaller thermal power station schemes would be considered eligible under Schedule 2, "industrial installations for the production of electricity, steam and hot water"). Where the process involves the collection, storage and processing of hazardous or nonhazardous wastes, proximity to controlled waters (within 100 metres) is a relevant consideration and likewise the collection and storage of combustible gases. The likelihood of significant effects will generally depend on the scale of the development and the nature of the potential impact in terms of discharges, emissions or odour. For installations, (including landfill sites), used for the deposit, recovery and/or disposal of household, industrial and/or commercial waste (as defined by the Controlled Waste Regulations 1992), EIA is more likely to be required where new capacity is created to hold more than 50,000 tonnes per year, or to hold waste on a site of 10 hectares or more.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

27

5.4 Water power


Whilst older installations are likely to comprise a dam and storage reservoir, new developments can be small in scale and utilise a natural pool, or head-pond, in order to supply a turbine via a conduit. Water power normally produces electricity and the turbine can be installed in a building the size of a domestic garage. Sites with less than a 2 m head tend to not to be costeffective, though pre-existing facilities such as at disused mills, especially when incorporated with on-site energy usage can make refurbishment schemes financially viable. While water channels and the buildings are likely to be visible, they are not necessarily detrimental to the landscape and can often be screened. Extensive civil engineering works tend not to be required for low-head schemes, where often the natural features of the watercourse are utilised, and problems of noise and traffic movements are normally minimal once construction is complete. Visual and ecosystem impacts are very much site-specific. For example the risk of interference with sensitive ecosystems or rare species is likely to be higher in national park or semiwilderness areas, and lower on existing weirs on lowland rivers. Input from wildlife of ecology experts may be required as part of an Environmental Impact Assessment. Renewable energy generated from pre-existing commercial hydro-schemes does not count towards the regional targets.

5.5 Solar power


Active solar systems are those which collect the suns radiation and transfer it in the form of heat to water or air. Photovoltaic systems convert the suns energy directly into electricity. Direct sunlight is not necessary to make these systems effective. Passive solar design uses a buildings form, fabric and orientation to capture, store and distribute solar energy with a consequent reduction in demand for additional heat and light. The installation of active solar systems usually involves fitting solar panels to the roof, photovoltaic cells incorporated into roof tiles or glazing, or a separate solar collector system in the grounds. The visual impact of such installations will vary depending upon their context but particular attention should be paid to their impact in Conservation Areas, on Listed Buildings and in other sensitive locations. This is a form of energy which can be generated at the point of use and is available everywhere, and also has only a limited impact in visual terms. Solar systems often fall within permitted development rights for homeowners (where for example a solar panel is more or less flush with an existing roof). However, for listed buildings, conservation areas, buildings in Areas of Outstanding Natural Beauty or National Parks or covered by Article 4 direction, blocks of flats, (or houses divided into flats), planning permission may well be required. Photovoltaic products may be more suitable in areas where visual amenity is crucial. Installations require maximum light and avoid possible shadows cast by adjacent buildings, trees or other obstructions. The visual amenity of installations is good. Active solar thermal collectors usually take the form of 3-4m collectors mounted on the roof, resembling dark roof lights, arranged in banks on large-scale commercial premises. Photovoltaic collectors can exist as panels on roofs or walls, or incorporated into the fabric of the building as external wall cladding, roofing systems, solar roof slates or built into glass facades or roofs.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

28

Heat pumps utilising solar heating of the ground are normally free from planning consents, but are subject to building regulations.

5.6 Landfill gas


Landfill gas is mainly a mixture of methane and carbon dioxide that can be used through combustion for heating and electricity generation. In order to exploit landfill gas, a suitable site must be available, which must be provided with a gas collection system and the necessary plant for energy generation. This type of energy source is only available in commercially viable quantities from extensive landfill sites. As waste is diverted away from landfill, this source of renewable energy is likely to drop away.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

29

6. Renewable Energy Development in Hertfordshire

6.1 The Potential for RE in Hertfordshire


The accompanying Renewable Energy Options Report, which has also been prepared by Entec, concludes that there is the technical potential within Hertfordshire to achieve the levels of renewable energy production proposed in the East of England Sustainable Development Round Table Study. However, achievement of the technical levels will be dependent upon a range of external factors, such as developer uptake, aviation objections (potentially on commercial wind projects) and consumer uptake. One of the most important factors influencing the uptake is commercial competitiveness (financial viability) and this is strongly influenced by much wider-ranging global political factors, national policy and regulations, grant schemes and the fundamental economic viability of the technologies. Many of these factors will be beyond the direct influence of stakeholders within Hertfordshire. However, for the more competitive renewable technologies, such as onshore wind, planning policy will remain the critical issue for attracting commercial developers. Strong regional and local level planning policies and increased public awareness can play a major part in attracting developers and influencing the deployment of renewable technologies in Hertfordshire.

6.2 Meeting the Targets


In order to meet the 2010 targets defined in the East of England Plan onshore wind must be encouraged, along with all other forms and scales of renewable energy schemes. In order to meet the 2020 targets, emerging technologies, such as biomass, will need to make a major impact. Due to the long initiation periods of many of these projects, effort must be expended now in order to win over public opinion and bring developments forward. Although requirements for renewable energy in new development will only make a marginal difference to the direct achievement of targets, it could have an impact on the public perception of renewable energy and the acceptability of new technologies. Urban authorities in particular may wish to concentrate efforts on small-scale, building-based embedded technologies such as solar, photovoltaic and small-scale wind solutions, with limited large-scale projects on brownfield sites where the opportunity arises. However, rural authorities may find projects that support the economy and promote employment more beneficial to their communities. The results of the assessment of renewable energy generation potential are set out in the accompanying Renewable Energy Options Report for Hertfordshire and are reproduced below for ease of reference.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

30

Table 6.1 Potential renewable energy production in Hertfordshire by 2010

Technology

Potential capacity (MW electrical)

Potential electrical output (GWeh/year)


Existing: 0.25 Possible: 25 Extended: 163

Potential total energy output (GWh/year)

CO2 reduction (tonnes CO2/year)

WIND Large Wind Turbines

Existing: 0.225 Possible: 10 Extended: 65

Existing: 0.25 Possible: 25 Extended: 163

110 10,800 70,100

BIOMASS Co-firing in large power plant Dedicated CHP facility Bio-diesel Bio-Ethanol Animal Slurries and Anaerobic Digestion Sewage sludge (90% dry solids) EFW MSW EFW Small scale biomass-heat facilities WATER : Hydro 2 4 14 N/A Low : 0.1 High : 2.0 WIND : Rooftop 14 30 104 N/A Low : 0.6 High : 12.3 Low : 0.3 High : 7 SOLAR ; Photo-Voltaic Low : 0.5 High : 12 SOLAR : Thermal/Passive 14 30 104 35 Low : 0.6 High : 12.3 Low : 0.3 High : 7 Low : 0.5 High : 12 Low : 2 High : 137 31 17 175 125 175 285 168,000 94,000 39,000 107,000 6,000 13,000 45,000 9,000 260 5,300 130 3,000 220 5,200 500 34,300

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

31

7. Local Planning Approach

7.1 The Vision


It is suggested that local planning authorities first consider whether the plan should start with a vision for the area that covers the subject of renewable energy. The vision for the Local Development Framework might be broad in terms of describing future aspirations for the area, but local planning authorities can decide just how specific they wish to be, including whether a vision for individual topics, such as renewable energy, might be an appropriate starting point. However, this will obviously depend upon whether a single vision can be agreed. Exactly how a local authority will approach the question of renewable energy will inevitably become a controversial subject if the planning authority contemplates encouraging or promoting such energy provision within their administrative area, as the Government is seeking to encourage. Encouraging wind power would inevitably be a possible option if a local authority were to be proactive in seeking to make a significant contribution to the provision of renewable energy sources, although controversy could equally apply to other forms of renewable energy, particularly where significant traffic and/or visual impacts may arise with such developments. In order for a local planning authority to test the context for drafting planning policies, it might be felt appropriate, through the initial community involvement stages of plan making, to invite views on what the community see as their overall vision for the subject. This could provide the authority with an idea of the extent of any consensus on what the community envisages and might accept within their own local area. The key words here are within their own local area. Whilst it is not difficult to get a general consensus on the virtues that renewable energy offers to society in general, it is a totally different consideration in how any one local community sees its role and what that community would be prepared to accept in its own back-yard. As a consequence, the choices that are available to each local community need to be articulated in a way in which everyone can understand and relate to. In particular, such choices need to be presented in the form of possible opportunities that the community and the local authority could either grasp, or reject. In this way, the concept of seeking views, through the community involvement process, on an agreed vision for the future, on a particular subject and for the particular area, might provide a more rewarding process than simply presenting the facts and overall national and regional ambitions. The most obvious element of a possible vision for many authorities might be how the community views any opportunities for larger-scale wind power in their area, but it could also include views on the approach to future residential and non-residential development in respect of energy conservation and generation, and the approach to agriculture in their area with regard to potential energy crops.

7.2 Sustainability and Plan Objectives


The Government published, in May 1999, the UK Strategy for Sustainable Development, entitled "A Better Quality of Life". The strategy stated that the Government wished to see

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

32

Sustainable Development Frameworks prepared and published in all the regions in England. The Strategy envisaged that the Frameworks would be adopted by each Regional Assembly and would set out the sustainable development principles that would need to be embodied in all Regional Strategies and Action Plans. The East of England Sustainable Development Framework sets out a vision for sustainable development in the region, and identifies its contribution to sustainable development at the national level. The East of England Sustainable Development Framework was produced in October 2001 by the Regional Assembly and the Sustainable Development Round Table. The Framework is a strategic document, aiming to influence the development of regional policy at a high level, rather than setting out a plan for action. The Framework is intended as a working document that will be updated as necessary to reflect progress, changing circumstances and new policy developments. The Regional Assembly states that the document should be seen as a framework, not a strategy, and, as such, it is intended that the Framework should not be seen as attempting to be prescriptive. Instead, the Framework should be seen as a template for guidance for others when preparing their own plans and strategies. The Framework has played a central part in the development of the Integrated Regional Strategy for the East of England. The Framework covers 21 separate issues and, in respect of the subject of energy, the Framework states: The national strategy is to use energy more efficiently, and progressively switch to alternatives to fossil fuel. The aim is to reduce CO and other emissions that cause climate change. Reliance on fossil fuel also has implications for security of supply, because of uncertainties of stocks and political and market changes. A precautionary approach is to assume that fuel costs will rise through market forces and the introduction of carbon levies. As a result, opportunities will emerge to develop renewable sources of energy and new energy technologies. Regional stakeholders have adopted a target of 14% of electricity to be produced from renewable energy sources by 2010 (currently renewable sources provide 0.45% of energy consumed in the region). The Framework considers that the regions strengths are: Positive support from key stakeholders and policymakers to assess potential for growth of renewable energy in region. East of England Energy Group formed to develop and diversify renewable energy potential. Detailed regional report showing potential for renewable energy by source and by county. A 'hi-tech' region with potential to develop and export new energy technologies. Some good innovative projects (e.g. large wind turbine at Swaffham, wood and chicken litter powered generators at Eye and Thetford, renewable energy storage depot at Barford). Growing number of local solutions (e.g. CHP installations).

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

33

Good offshore wind potential including existing distribution points (e.g. via nuclear power stations). Major offshore gas industry seeking to diversify, largely based in areas needing regeneration. Large areas of agriculture seeking to diversify, offering scope for energy crops. The Framework considers that the challenges facing the region and the country are: Reducing demand arising from economic and household growth. Encouraging efficient use of the rising number of energy consuming appliances (e.g. dish washers) resulting from increased prosperity. Encouraging energy saving when rising prosperity and falling real fuel prices mean it is not seen as a priority for many. Addressing the contribution of fuel cost to social deprivation. Ensuring that renewable energy installations, such as wind turbines, are acceptable in terms of their impacts upon communities, inland and coastal landscapes and habitats. Deciding upon the pros and cons of nuclear power generation, and energy from waste. The Framework considers that the key objectives for energy in the region are: To encourage more efficient uses of energy, including product design, manufacturing processes, transport, and behavioural changes. To promote awareness that the price of energy must reflect its environmental and social cost, so that through market forces and levies the price will rise. To support the offshore energy industry's diversification into renewable energy and other new energy market areas. To raise awareness of the potential of renewable energy to attract more investment. To encourage planning authorities to take a more positive attitude towards renewable energy schemes, home insulation, and local community renewable energy schemes. To encourage more efficient energy use, and identify and remedy areas of fuel poverty, in line with the UK Fuel Poverty Strategy. To develop, adopt and ensure the effective use of built development design guides tackling energy use, to provide homes and businesses with self-sufficient energy. To grow the 'green economy' of the region. To support low energy usage demonstration projects for home, work, and transport.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

34

A potential key role of any regions Sustainable Development Frameworks objectives is that provide a reference point for developing the plan objectives of Local Development Frameworks. The process is formalised through the Sustainability Appraisal / Strategic Environmental Assessment procedure that all development plans are now subject to and obliged to undertake. A compatibility assessment can be employed to test the development plans objectives against the regions sustainability objectives in order to refine and adapt the plan objectives to ensure that Local Development Frameworks are reflecting a genuine and robust form of sustainable development for their area. The refined objectives are then able not only to inform the process of preparing the policies for the plan, but can be used to refine and articulate the vision for the area and its land uses for the purposes of community involvement.

7.3 The Wider Context


In considering the local planning approach to renewable energy, it also has to be kept in mind that there will be a much wider range of what might be termed sustainability issues that will need to be addressed or taken into account. Climate change implications (e.g. flood risk) Energy use and efficiency in existing and new development Product developments in relation to energy conservation (e.g. with industrial and domestic appliances, vehicle and engine technology, etc) The introduction of more sustainable fuels for means of travel Information availability and education initiatives Fiscal policies and incentives (e.g. aimed at reducing carbon emissions, energy conservation measures, etc) Fuel poverty initiatives Complementary sustainable development actions, such as: Sustainable building design and construction Sustainable drainage schemes Dealing with waste Some recent examples of local authority approaches in terms of wider climate change and sustainable energy initiatives are set out below for information.

7.4 Woking Borough Council


In December 2002, Woking Borough Council's energy efficiency policy was replaced by the Climate Change Strategy for Woking, not just for Council buildings and transport, but for the Borough as a whole, shifting the focus from savings in KWh's of energy, to savings in tonnes of CO, as well as adapting to a changing climate. The key three principles of the Strategy are:

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

35

Adopting an overall target to reduce Woking's CO equivalent emissions by 80 per cent of its 1990 level by 2090 in steps of 10 per cent up to 2050 and 5 per cent from 2050 to 2090; Adopting the concept of an Environmental Footprint for the Borough which has as its base 1,060,000 tonnes of CO equivalent emissions of greenhouse gases; and Declaring itself Climate Neutral and setting up a Climate Change Fund. As part of a number of action plans, the Strategy adopts targets for purchasing 20 per cent of the Council's electrical energy requirements from renewable sources and 100 per cent of the Council's electrical and thermal energy requirements from sustainable energy (including CHP) sources by 2010-11. By 2002-03, the Council had already reduced CO equivalent emissions by 14.51 per cent of the whole of the Borough's CO emissions in 1990 through its own actions alone. In addition, the Council purchased 84.2 per cent of its own electrical and thermal energy requirements from local sustainable sources and 3.9 per cent of its own electrical energy requirements from local renewable sources. The Borough Council claims that Woking is believed to be the only UK authority to have so far adopted a comprehensive climate change strategy on a scale that is likely to meet The Royal Commission on Environmental pollution targets of 60% reductions of CO equivalent emissions by 2050 and 80% by 2100. The Council included the following policies in the Woking Borough Local Plan, which was adopted on 27 August 1999. Policy BE6: Energy ConservationThe Council will expect proposals for new development to take account of the need to conserve energy through appropriate location, design, layout and landscaping. Policy CUS8: Renewable EnergyProposals for the development of renewable energy resources will be considered favourably where there would be no material harm to the environment by reason of location, appearance, noise and traffic generation, nor result in the loss of land protected by other policies in the Plan. Policy CUS9: Combined Heat and PowerThe development of combined heat and power stations that meet both the operational demands of the technology and the environmental policies of the Local Plan will be permitted. In practice however, no developer has implemented any of these policies, other than the Council and its Public/Private joint venture Energy Services Company known as Thameswey.

7.5 Cornwall
In May 2005, all the local authorities in Cornwall and the Isles of Scilly Council achieved Beacon Council Status for Sustainable Energy. It was specifically awarded to Cornwall for the role that all the councils have played in the creation, development and delivery of the Public/Private sector Cornwall Sustainable Energy Partnership and the subsequent Energy Strategy for Cornwall. This is the first time this particular award has been given to any local

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

36

authority and recognises the local authorities as being at the leading edge in energy efficiency, fuel poverty and renewable energy programmes in the UK. The Energy Strategy for Cornwall, Action Today for a Sustainable Tomorrow, was launched by the Energy Minister in July 2004 and is also believed to be a first in the UK. No other county has produced a Sustainable Energy Strategy that it is also an Action Plan for energy efficiency and renewable energy. The plan is to be delivered by all the local authorities in Cornwall and 65 other public and private sector organisations. Achieving Beacon Council Status means that all Cornwall's local authorities will be involved a programme of national best practice dissemination. Over the next year a series of activities has been planned, utilising specific funding from the Office of the Deputy Prime Minister, to assist other Councils in achieving similar programmes. Many other councils across the UK have already expressed their wish to replicate the partnership work of the Cornish authorities and some, such as Devon, Orkney, Fife and Gwynedd are already developing a partnership approach following Cornwall's example. A brief overview of the local plan position in Cornwall is summarised below in order to provide a county-wise snap-shot of the renewable energy approach in planning policy terms in this Beacon Council area. 7.5.1 Cornwall Structure Plan Structure Plan Policies ENER 1 and 2 The Structure Plan recognises the potential from renewable energy resources in the county and is supportive in principle of their development, recognising they can only be exploited where they are found. The Plan also recognises that there is a balance to be struck between promoting renewable energy developments, which have undoubted wider environmental benefits, and any adverse effects that proposals may have for the local community and the environment. In respect of windfarms, Policy ENER2 of the Structure Plan highlights two key strategic concerns: The best landscapes should be kept free of windfarms. No one area should become so dominated by turbines that its overall character is fundamentally changed. The general approach in ENER2 dovetails with the Plans key landscape policy (ENV1), which applies the test of national interest and lack of alternative sites in respect of major developments in AONBs and consideration of the cumulative impact of development in all cases. 7.5.2 The District Local Plans Penwith The emerging Local Plan Deposit Draft follows the lead of ENER2 in setting out that proposals for renewable energy schemes will be permitted, provided that there is no adverse impact on the character of the surrounding area and that they are not likely to cause disturbance by noise, smell, dust, vibration or maintenance activities. Particular consideration is given to wind energy. The policies give strong protection to AONBs in respect of windfarms, but not explicit reference to cumulative impact.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

37

Kerrier - The emerging Plan follows the theme of the Structure Plan quite closely by permitting the development of renewable energy schemes, such as solar power, wind power, hydro-electric and biomass, except where the harmful environmental effects outweigh the wider environmental and resource benefits. Cumulative impact is specifically dealt with. The particular approach to the AONB is not specified in the renewable energy policies. Carrick Local Plan highlights that, to be truly sustainable, proposals for renewable energy must take into account national and county landscape designations and must contribute to the quality of life of local residents and to the areas attraction as a tourist destination. The Plan includes specific reference to the AONB and cumulative impact, but does not require the benefits of renewable energy to be balanced against any adverse effects. Restormel Local Plan relates in broad terms to Policy ENER2 of the Structure Plan. North Cornwall Local Plan deals with proposals for individual wind turbines and wind farms. However, there are no policies on other forms of renewable energy generation. The approach emphasises the cumulative impact issue. No reference in the policies is made to the benefits of renewable energy generation. Caradon Local Plan, Policy REN1 broadly follows the Structure Plan approach and gives specific consideration to proposals for wind turbines and hydro-electric power. These introduce a test of unacceptable impact in relation to specific features and the qualities of AONBs and other designated areas.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

38

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

39

8. Local Planning Policies

8.1 Local Planning Policies


In order for each local planning authority to consider in a structured and systematic way the types of policy and the level of detail that might be included in the Local Development Framework, five types of renewable energy policies are set out below for consideration. The five types of policy are set out in descending order of likely acceptability for inclusion in a plan, based in part that the five types of policy range from the general to the specific. When considering what policies might be most appropriate for the local authority area, regard should also be had to what represents a soundly worded, robust and well presented policy.

8.2 Good Practice


A summary of good practice pointers in preparing and wording policies in spatial plans has been set out in the Planning Officers Societys publication Policies for Spatial Plans: Consultation Draft, published in August 2004. The following guide is provided in the document on what represents both good and bad practice in approaching the presentation of policies and their wording. Spatial planning policies should be: Clear and precise without extraneous wording; Capable of providing a proper basis for planning decisions; Written to assist monitoring and review of their effectiveness and outputs; Related to an issue of local importance; Framed in positive terms where possible; Capable of being implemented or having an effect within the plan period; Consistent with national planning policy and in general conformity with the Regional Spatial Strategy; Related to the spatial vision and spatial objectives in the Core Strategy; and Included in a Development Plan Document if they involve strategic or significant local planning issues, or if they affect human rights. And they should: Clearly indicate circumstances that influence grant or refusal of planning permission; Contain criteria if they assist in applying the policies objectives;

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

40

Give spatial expression to the Community Strategy, Local Transport Plan and other relevant local strategies and initiatives; Generally reflect national planning guidance, but clarify where local circumstances justify a different approach; Distinguish clearly between the policy itself and the supporting reasoned justification; Provide the basis for further elaboration in a Supplementary Planning Document if necessary; and Explain how policies that conflict with them should be considered. Spatial planning policies should not be: Based upon local opinions that are not supported by robust evidence; Worded so flexibly so that they are difficult to apply in practice; Too rigid in operation due to too many criteria or details; At odds with the spatial vision and spatial objectives in the Core Strategy; and Worded in ways that go out of date quickly or do not assist monitoring and review. And they should not: Try to cover every possible eventuality that might occur; Use technical planning terms unless they are necessary for precise definition; Duplicate other planning documents, relevant strategies or legislation; Include unsupported statements of intent rather than measurable proposals; Contain details that should be in the reasoned justification; and Use double negatives and ambiguous wording such as normally or not normally.

8.3 The Assessment of Policies


Local planning authorities may also find useful the Department of Trade and Industrys criteria for assessing the way in which policies for renewable energy are presented in development plans, Supporting text of the plan outlines government policy on renewable energy and makes reference to planning policy guidance. Supporting text of the plan shows awareness of potential renewable resources in the Plan area and makes reference to a county / regional study where appropriate.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

41

Supporting text of the plan recognises the balance between potential benefits of renewable energy developments and any adverse environmental impacts that may arise. Policies express specific support or encouragement in principle for renewable energy proposals. Policies provide clear guidance on the circumstances in which renewable energy proposals will be permitted. Policies are phrased so that it is applicable to all renewable energy technologies. No technology is excluded unless fully justified. Policies address the development requirements of specific technologies. Policies refer to other policies in the plan. Policies contain no unrealistic expectations. The Cornwall Energy Study contains the following recommended checklist, which addresses the supporting text of development plans as well as the requirements of policies themselves in respect of renewable energy supplying electricity and heat to end users. Planning policy might include: Expressing positive support in principle for renewable energy development and the County target for electricity from renewable sources. Providing criteria on the circumstances in which renewable energy proposals will be permitted. Requiring new development to assess the potential for: ! ! ! renewable energy integration; the use of CHP; local energy distribution through district heating/cooling networks and local electricity grids.

Requiring the consideration of the social, environmental and economic benefits of the scheme at a national and local level. Supporting the re-machining of existing wind farms provided that general conditions for wind development are met. Referring to other relevant policies in the Plan and how renewable energy development can contribute to economic development. The supporting text in Local Plans should: Outline Government policy on renewable energy referring to the Energy White Papers national target to generate 10% of our electricity from renewables by 2010, the aspiration for 20% by 2020 and the national target for 10 GW of good quality CHP capacity by 2010. Outline the objectives of the UK Climate Change Programme and refer to the Energy White Paper objective to work towards a 60% reduction in carbon emissions by 2050.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

42

Make reference to national planning policy guidance (i.e. the revised PPS22). Set out the regional and county targets included in any RSS. Describe potential renewable energy resources in the Plan area. Highlight the need to balance the potential benefits of renewable energy, in terms of jobs, economic development and reduced carbon emissions with any adverse local environmental impacts that may arise. Refer to the scale of local environmental impacts that could be anticipated and that with some technologies, e.g. for wind power, that these impacts are time-limited because complete decommissioning and removal is a practical option.

8.4 A General Criteria-based Policy


8.4.1 Government Guidance PPS22 states that: Planning applications for renewable energy projects should be assessed against specific criteria set out in regional spatial strategies and local development documents. (Paragraph 6, PPS22, 2004) Criteria based policies should be set out in regional spatial strategies where these can be applied across a region, or across clearly identified sub-regional areas. These criteria should then be used to identify broad areas at the regional/sub-regional level where development of particular types of renewable energy may be considered appropriate. Other criteria based policies to reflect local circumstances should be set out by local planning authorities in their local development documents. Local planning authorities should, however, only focus on the key criteria that will be used to judge applications. More detailed issues may be appropriate to supplementary planning documents. (Paragraph 7, PPS22, 2004) Without any kind of criteria-based policy on renewable energy, a Local Development Framework is likely to be regarded as unsound by a planning inspector and therefore all such plans should include an appropriate form of wording in at least one policy. 8.4.2 Woking Borough Local Plan The Woking Borough Council included the following policy in the Woking Borough Local Plan, which was adopted on 27 August 1999. POLICY CUS8: RENEWABLE ENERGY - PROPOSALS FOR THE DEVELOPMENT OF RENEWABLE ENERGY RESOURCES WILL BE CONSIDERED FAVOURABLY WHERE THERE WOULD BE NO MATERIAL HARM TO THE ENVIRONMENT BY REASON OF LOCATION, APPEARANCE, NOISE AND TRAFFIC GENERATION, NOR RESULT IN THE LOSS OF LAND PROTECTED BY OTHER POLICIES IN THE PLAN. Only the Council and its Public/Private joint venture Energy Services Company, known as Thameswey, have so far been assessed against this policy.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

43

8.4.3 Penwith Local Plan Penwith Local Plan Deposit Draft 1998 contains the following similarly worded renewable energy policy: POLICY CS-8: PROPOSALS FOR RENEWABLE ENERGY SCHEMES WILL BE PERMITTED PROVIDED THAT: (i) THERE WOULD BE NO ADVERSE IMPACT ON THE CHARACTER OF THE SURROUNDING AREA AND (ii) THEY ARE NOT LIKELY TO CAUSE DISTURBANCE BY NOISE, SMELL, DUST, VIBRATION OR MAINTENANCE ACTIVITIES. WHERE PROPOSALS INVOLVE THE GENERATION OF ENERGY FROM WIND POWER THEY MUST NOT CONFLICT WITH POLICY CS-9. 8.4.4 Rochford District Local Plan Rochford District Replacement Local Plan, Second Deposit Draft, March 2004, refers within the wording on its renewable energy policy to areas of nature conservation and heritage interest, as well as other specific designated areas and any possible cumulative impact that may need to be considered. UT3 - REWNEWABLE ENERGY PROPOSALS FOR THE DEVELOPMENT OF RENEWABLE SOURCES OF ENERGY, OR PROPOSALS WHICH INCLUDE SOME ELEMENT OF RENEWABLE ENERGY, WILL BE ENCOURAGED, PARTICULARLY WHERE THERE ARE BENEFITS TO THE LOCAL COMMUNITY. RENEWABLE ENERGY PROPOSALS WILL BE PERMITTED PROVIDED THAT THE PROPOSED DEVELOPMENT WOULD NOT ADVERSELY AFFECT: I. THE SPECIAL CHARACTER OF THE COASTAL PROTECTION BELT, SPECIAL LANDSCAPE AREAS, AREAS OF ANCIENT LANDSCAPE OR SITES OF NATURE CONSERVATION (INCLUDING AVIAN FLYWAYS) OR HERITAGE CONSERVATION INTEREST; AND II. THE AMENITY OF NEARBY DWELLINGS OR RESIDENTIAL AREAS; THE DEVELOPMENT MUST NOT RESULT IN A SIGNIFICANT LEVEL OF VISUAL IMPACT AND PARTICULAR REGARD WILL BE HAD TO THE CUMULATIVE IMPACT OF EXISTING, PLANNED OR PROPOSED RENEWABLE ENERGY DEVELOPMENTS. PROPOSALS FOR DEVELOPMENT MUST BE ACCOMPANIED BY ADEQUATE INFORMATION TO INDICATE THE EXTENT OF POSSIBLE ENVIRONMENTAL EFFECTS AND HOW THEY CAN BE SATISFACTORILY MITIGATED. MINOR DOMESTIC RENEWABLE ENERGY SCHEMES ENCOURAGED PROVIDING THEY MEET CRITERIA I AND II. WILL BE

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

44

8.4.5 Caradon Local Plan Caradon Local Plan, adopted in 1999, contains the following criteria: POLICY REN1 PLANNING PROPOSALS FOR THE GENERATION OF ENERGY FROM NON-FOSSIL FUEL SOURCES WILL BE PERMITTED SUBJECT TO THE FOLLOWING CRITERIA: (i) THE PROPOSAL MUST NOT HAVE AN UNACCEPTABLE IMPACT ON THE CHARACTER AND APPEARANCE OF THE IMMEDIATE AND WIDER LANDSCAPE, AND OF AREAS OF NATURAL, CULTURAL, HISTORICAL OR ARCHITECTURAL INTEREST. (ii) THE PROPOSAL MUST NOT OVERSHADOW OVERBEARING EFFECT ON NEARBY HABITATIONS. OR HAVE AN

(iii) THE PROPOSAL MUST BE CAPABLE OF BEING OPERATED AND SERVICED WITH NO UNACCEPTABLE IMPACT TO THE AMENITY OF NEARBY HABITATION WITH REGARD TO NOISE, SMELL, DUST, VIBRATION, SMOKE OR OTHER AIR POLLUTION. (iv) THE PROPOSAL MUST NOT CREATE A THREAT TO ROAD SAFETY THROUGH TRAFFIC GENERATION. (v) THE PROPOSAL TAKEN WITH THE EFFECTS OF SIMILAR DEVELOPMENT NEARBY MUST NOT HAVE A MATERIALLY ADVERSE IMPACT ON THE INTERESTS IDENTIFIED IN (i) AND (iii) ABOVE. 8.4.6 Oldham Unitary Development Plan Oldham Metropolitan Borough Council Unitary Development Plan, First Deposit Draft 2001, has both a long list of criteria and a reference to considering the implications of any consequences that might arise with any decommissioning of the installation: NR3.1 RENEWABLE ENERGY DEVELOPMENTS WILL BE PERMITTED WHERE THE DEVELOPMENT AND ANY ANCILLARY FACILITIES OR BUILDINGS WOULD NOT CREATE A HAZARD OR NUISANCE THAT COULD NOT BE OVERCOME AND WOULD NOT HAVE AN UNACCEPTABLE IMPACT ON ANY OF THE FOLLOWING: A. RESIDENTIAL AMENITY AND HUMAN HEALTH; B. THE CHARACTER OR APPEARANCE OF THE SURROUNDING AREA; C. THE OPENNESS AND VISUAL AMENITY OF THE GREEN BELT; D. PUBLIC ACCESS TO THE COUNTRYSIDE; E. SITES DESIGNATED FOR THEIR NATURE CONSERVATION VALUE; F. THE BIODIVERSITY OF THE BOROUGH; G. SITES OR BUILDINGS OF CULTURAL, HISTORICAL OR ARCHAEOLOGICAL INTEREST; AND

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

45

H. GROUND AND SURFACE WATER QUALITY AND AIR QUALITY. PERMISSION WILL ONLY BE GRANTED IF ANY UNAVOIDABLE DAMAGE THAT WOULD BE CAUSED DURING INSTALLATION, OPERATION OR DECOMMISSIONING IS MINIMISED AND MITIGATED OR COMPENSATED FOR. APPLICATIONS MUST INDICATE HOW THIS WILL BE ACHIEVED. 8.4.7 London Borough of Merton The Merton Unitary Development Plan, adopted in October 2003, introduces the idea of weighing in the balance the benefits, which might be demonstrated and accepted as arising with a renewable energy proposal, against any harm that might arise from the development. The policy requires that the benefits demonstrably outweigh any harm that might be caused. POLICY PE.12: ENERGY GENERATION AND ENERGY SAVING PROPOSALS FOR DEVELOPMENT OF FACILITIES THAT GENERATE ENERGY LOCALLY, IN PARTICULAR RENEWABLE ENERGY AND THOSE THAT REDUCE THE USE OF ENERGY AND ITS TRANSMISSION, WILL BE PERMITTED PROVIDED THAT THERE IS NO DEMONSTRABLE HARM ON VISUAL OR RESIDENTIAL AMENITIES OR BY WAY OF POLLUTION GENERATION, OR IT CAN BE DEMONSTRATED THAT BENEFITS CONTRIBUTING TO DIVERSE AND SUSTAINABLE ENERGY SUPPLIES AND TO REDUCING GREENHOUSE EFFECTS WILL OUTWEIGH HARM ARISING FROM THE DEVELOPMENT.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

46

8.4.8 Recommended Policy Wording Checklist From the wording of the above policies, a summary checklist can be elicited in order to allow each local planning authority to consider when drawing up their general criteria-based policy. A General Criteria-based Policy Checklist for Renewable Energy Development Renewable energy development will be permitted Subject to: The impact on local amenities ! ! e.g. Landscape and visual impact; Noise; Traffic generation; Odour; Dust; Smoke and other emissions and pollutants; Vibration. The cumulative impact of existing and proposed developments

The impact on specific areas of acknowledged importance ! e.g. Areas of Outstanding Natural Beauty, areas of nature conservation importance, designated Conservation Areas, listed buildings and their settings, historic parks and gardens, sites of archaeological importance, Green Belt, etc.

Health and Safety ! ! ! ! Highway safety Human health Ground and surface water quality Air quality

Other proposals ! e.g. Not resulting in the loss of land protected and required by other land uses as defined in the plan

With a possible proviso of: Benefits outweighing the harm ! e.g. Where the benefits that would arise from a proposals would demonstrably outweigh any harm that might be caused

The above policy pre-supposes that the plan will define what constitutes renewable energy in respect of the interpretation and application of the policy. Local Planning Authorities also need to be careful should they seek to prescribe precise criteria in policies. Renewable energy technology is developing all the time and potential adverse impacts in relation to such matters as noise and amenity are likely to change. Thus, specific criteria, such as minimum separation or buffer distances, can be inappropriate in such policies. There are also no definitive distances contained or advised in Government guidance. As an example from the past, Oldham Metropolitan Borough Council originally drew on advice in the

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

47

document Conservation Issues in Local Plans, published by English Nature, English Heritage and the Countryside Agency. The authority included a buffer distance of 500 metres between wind turbines and sensitive land uses in its First Deposit UDP, which then resulted in suggestions ranging in terms of distances from half a mile to one and a half kilometres. It should also be remembered that a consistency check should be undertaken between the different policies in the plan in order to ensure that no internal contradictions or ambiguities arise between the wording in different policies. PPS22 states: Regional planning bodies and local planning authorities should ensure that such criteriabased policies are consistent with, or reinforced by, policies in plans on other issues against which renewable energy applications could be assessed. (Paragraph 6, PPS22, 2004)

8.5 A Policy for Renewable Energy in New Development


8.5.1 Government Guidance PPS22 states: Local planning authorities may include policies in local development documents that require a percentage of the energy to be used in new residential, commercial or industrial developments to come from on-site renewable energy developments. Such policies: (i) should ensure that the requirement to generate on-site renewable energy is only applied to developments where the installation of renewable energy generation equipment is viable, given the type of development proposed, its location, and design; (ii) should not be framed in such a way as to place an undue burden on developers, for example, by specifying that all energy to be used in a development should come from on-site renewable generation. (Paragraph 8, PPS22, 2004) Local planning authorities and developers should consider the opportunity for incorporating renewable energy projects in all new developments. Small scale renewable energy schemes utilising technologies such as solar panels, biomass heating, small scale wind turbines, photovoltaic cells and combined heat and power schemes can be incorporated both into new developments and some existing buildings. Local planning authorities should specifically encourage such schemes through positively expressed policies in local development documents. (Paragraph 18, PPS22, 2004) 8.5.2 Planning Officers Society In respect of some general advice about the wording of policies, the Planning Officers Societys publication Policies for Spatial Plans: Consultation Draft, August 2004, offers a form of model words and policy wording on the subject of seeking renewable energy in new development. An updated and amended form of the model wording is set out below, although this suggested wording omits specifically requiring a percentage of the energy to be used in new residential, commercial or industrial developments to come from on-site renewable energy developments.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

48

The LPA will follow advice in PPS22 on Renewable Energy. Applicants are advised that the LPA will require proposals for major developments to be accompanied by details of the measures taken for energy efficiency. The use of renewable energy will be encouraged, but any external equipment must be integrated with the design of the building and not harm the amenity of the surroundings. Applicants are advised to consult the Guide on Energy Conservation published by the LPA. Policy XX: Planning permission will only be granted where proposals seek the highest practicable energy efficiency through location, orientation, layout, and design. 8.5.3 Woking Borough Council Woking Borough Council included the following policy in the Woking Borough Local Plan, which was adopted on 27 August 1999 and which pre-dates, although is very similar to, the Planning Officers Societys suggested wording. POLICY BE6: ENERGY CONSERVATION - THE COUNCIL WILL EXPECT PROPOSALS FOR NEW DEVELOPMENT TO TAKE ACCOUNT OF THE NEED TO CONSERVE ENERGY THROUGH APPROPRIATE LOCATION, DESIGN, LAYOUT AND LANDSCAPING. 8.5.4 London Borough of Merton Merton Unitary Development Plan (UDP), adopted October 2003, contains a general policy on the use of alternative sources of energy, including solar and wind energy, and a specific policy on the percentage of the energy that will be required to be used in new residential, commercial or industrial developments from on-site renewable energy developments. Legal opinions were necessary before the London Borough of Merton Unitary Development Plan could be adopted in respect of its policy in the plan that established a target of 10% of building energy needs to be met from renewable sources on site. POLICY BE.25: SUSTAINABLE DEVELOPMENT THE COUNCIL WILL ENCOURAGE CONSERVATION OF SCARCE OR DIMINISHING NATURAL RESOURCES, THE USE OF SUSTAINABLE AND/OR RECYCLED BUILDING MATERIALS, ENERGY AND WATER EFFICIENT BUILDING CONSTRUCTION AND SERVICES, USE OF ALTERNATIVE SOURCES OF ENERGY, INCLUDING SOLAR AND WIND ENERGY, AND THE MINIMISATION OF WASTE IN THE DEVELOPMENT PROCESS. WHERE POSSIBLE, REDUNDANT OR UNDER UTILISED BUILDINGS, WHICH CONTRIBUTE TO AREA QUALITY, SHOULD BE RETAINED AND RE-USED. POLICY PE.13: ENERGY EFFICIENT DESIGN AND USE OF MATERIALS THE COUNCIL WILL ENCOURAGE THE ENERGY EFFICIENT DESIGN OF BUILDINGS AND THEIR LAYOUT AND ORIENTATION ON SITE. ALL NEW NON-RESIDENTIAL DEVELOPMENT ABOVE A THRESHOLD OF 1,000 SQM WILL BE EXPECTED TO INCORPORATE RENEWABLE ENERGY PRODUCTION EQUIPMENT TO PROVIDE AT LEAST 10% OF PREDICTED ENERGY REQUIREMENTS. THE USE OF SUSTAINABLE

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

49

BUILDING MATERIALS AND THE RE-USE OF MATERIALS WILL ALSO BE ENCOURAGED, AS WILL THE USE OF RECYCLED AGGREGATES IN THE CONSTRUCTION OF BUILDINGS. THIS WILL BE SUBJECT TO THE IMPACT ON THE AMENITY OF THE LOCAL ENVIRONMENT, TAKING INTO ACCOUNT THE EXISTING CHARACTER OF THE AREA. The UDP explains that the expectation in the policy that renewable energy production equipment will be incorporated in new developments relates only to non-residential developments (i.e. those outside the C category of use class). However, the authority seeks to apply the policy, in terms of encouraging energy efficient design, to all new development. The Council is concerned to ensure that development is designed to utilise renewable energy sources, which means, for the purpose of this policy, incorporating photovoltaic installations and solar-powered or geo-thermal water heating systems, and utilising energy crops and biomass, although energy from domestic or industrial waste is not considered appropriate. One of the difficulties in applying such a policy is acknowledged in the Merton UDP: Some elements of this policy are outside the control of land use planning. However, the Council wishes to encourage their development in the interests of sustainability. The Councils Supplementary Planning Guidance Note for Sustainable Development provides further guidance on this subject. (Paragraph 4.170, Merton UDP, 2003) The draft plans of Croydon, Ealing, Waltham Forest, Bromley, Barking and Dagenham, North Devon, Sefton, Westminster and Oldham Councils also include similar proposals. 8.5.5 Oldham Metropolitan Borough Council Oldham Metropolitan Borough Council is in the process of introducing a renewable energy requirement for new development. The policies for renewable energy in Oldhams First Deposit Draft Replacement Unitary Development Plan (RUDP) changed substantially at the Revised Deposit Stage. The policies were then further amended as a result of proposed pre-inquiry changes in order to respond to the new national policy context on renewable energy, which has evolved and changed over the same period as the RUDP process. Oldham originally included just two Part 2 policies in its UDP: NR3.1, a criteria based policy relating to all renewable energy technologies, including wind; and NR3.2, a policy containing additional criteria to be considered in relation to wind turbines. Oldhams RUDP new policy (NR3.3) is a new additional policy requiring new development to incorporate renewable energy, with the intention of exploiting solar water heating, photovoltaics and other micro-scale renewables in both residential and non-residential new buildings. The requirement, for 10% of total predicted energy requirements to be provided from renewable energy sources, is restricted in the policy to residential developments comprising 10 or more units, and to non-residential developments exceeding 1,000m gross floorspace. This threshold was included because it was considered impractical to apply the policy to all developments. Oldham considered that there was a need to balance the benefits in terms of reducing CO emissions against the initial capital costs it could add to developments. Larger developments,

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

50

which are more likely to have a heavier demand for energy, are better placed to benefit from any possible economies of scale. In addition, Oldham felt that development control negotiations on such a requirement for every new building development would inevitably lengthen the time it would take to deal with planning applications and adversely affect its Best Value indicators. Oldham explains that 10% was specified because it reflects the national renewable energy target for the year 2010, which is broadly equivalent to the Replacement Unitary Development Plan period. In addition, the introduction of a new policy requires care to be taken to pitch the requirement at a level that would avoid stifling new development, particularly new housing and in housing renewal areas. The 2020 target referred to in the new policy may be for a future review of the plan once there is monitoring information that is available as to the effectiveness of the new policy. Oldham makes clear that energy efficiency measures will not be counted towards the 10% renewable energy requirement and total, although of course energy efficient measures will still be expected in new developments in order to help reduce the overall energy requirement of the development. 8.5.6 Recommended Policy Wording Checklist From the wording of the above policies, a summary checklist can be elicited in order to allow each local planning authority to consider when drawing up their local development documents. One consideration that none of the above plans explicitly makes clear is an acknowledgement that certain requirements might run counter and prejudice other aims and objectives of the plan. A case in point could be affordable housing, where housing associations in particular may have viability issues where the cost of providing the affordable housing cannot be fully covered by the projected rent income and grants that would be associated with the housing. Requirements in such circumstances may need to be negotiated and applied in a sensitive way, having regard to other desirable objectives.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

51

A Policy for Renewable Energy in New Development A percentage (to be specified) of the energy to be used in new residential, commercial or industrial developments will be required to come from on-site renewable energy sources. Subject to: The type, size and scale of development ! ! Specify the land use(s) to be covered by the policy (e.g. dwellinghouses under Use Class C3; business, general industrial and storage/distribution under Use Class B; etc) Specify, if necessary, a threshold above which the requirements of the policy are to apply (e.g. residential development comprising x or more units; commercial or industrial developments exceeding x square metres gross floorspace; etc). If a threshold is adopted, think whether a statement should be included about all development, which might point out that all relevant proposals will be encouraged and supported to maximise energy conversation measures and incorporate appropriate designs and specifications, including renewable energy installations, in their proposals wherever appropriate.

Viability ! In order to provide some flexibility where particular circumstances need to be taken into account, it might be necessary to make clear that the requirement in the policy is subject, to the proposals being viable (having regard to the type of development proposed, its location, and design). It might also be prudent to make explicit that any policy requirement would be subject to not prejudicing the attainment of other desirable objectives in the plan (e.g. affordable housing; development of a contaminated site; regeneration objectives; etc).

In addition: Energy Conservation in general ! Make clear that whilst energy efficiency measures in a proposal will not be counted towards the specified percentage renewable energy requirement and total, energy efficient measures will still be expected in new developments and the authority will seek the highest practicable energy efficiency and sustainable form of construction in the design of all residential, commercial or industrial buildings.

One important implication of the above type of policy that authorities may want to carefully consider is respect of imposing these requirements on employment development. One consequence could be for developers of offices and business development to decide to move out of the authoritys district to areas where no such requirement is imposed. This might be overcome, however, if there is a common approach and common policies across a number of adjacent authorities, which is something that might be coordinated at county and regional levels, including possibly using clear policies in the Regional Spatial Strategy.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

52

Besides encouraging renewable energy in development, local planning authorities will also be aware that the design of buildings, including the incorporation of energy conservation and efficiency measures, has a significant effect on energy consumption. In addition, the use of recycled materials in the construction of buildings can also contribute to the efficient use of existing resources, whilst the use of materials from sustainable sources, such as from softwoods from sustainably-farmed forests, also contributes to a more sustainable form of development. 8.5.7 South East Plan Opinion Poll When considering whether to include, or not, a specific planning policy on new development in relation to energy use, authorities may find interesting the results of the recent opinion poll conducted by MORI on behalf of the South East England Regional Assembly as part of the drafting of the Regional Spatial Strategy. The results were based on 2,003 face-to-face interviews conducted between 6 January and 23 March 2005. (See http://www.southeastra.gov.uk/southeastplan/consultation/mori_wave_3-final_report-may_2005.pdf )

Table 8.1 South East Plan MORI Poll


Very important Reducing the amount of rubbish sent to landfill Making buildings more efficient in their use of energy and water Building new water reservoirs to help avoid water shortage Protecting and improving wildlife habitats Increasing renewable energy generation, for example generate energy from wind, the sun and wood Reducing air pollution Reducing the number of homes that are at risk of flooding 53% Fairly important 38% Not very important 5% Not at all important 1% Dont know 3%

58%

37%

3%

1%

2%

42%

41%

11%

1%

5%

54%

38%

6%

1%

1%

49%

37%

9%

2%

3%

63% 50%

32% 34%

4% 9%

1% 3%

1% 3%

N.B. Where results do not add up to 100%, this is due to computer rounding or multiple answers

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

53

The results indicate, unsurprisingly, that all 7 quality of the environment issues were considered very or fairly important by the great majority of those interviewed. Making buildings more efficient in their use of energy and water however received the second highest percentage (58%) of very important responses and the highest percentage (95%) of combined very or fairly important responses of the 7 separate issues. Making buildings more efficient in their use of energy and water was also seen as marginally more important than increasing renewable energy generation, although 86% still thought this to be a very or fairly important issue.

8.6 A Policy Supporting Small-scale Renewable Energy


8.6.1 Government Guidance PPS22 points out that: (vi) Small-scale projects can provide a limited but valuable contribution to overall outputs of renewable energy and to meeting energy needs both locally and nationally. Planning authorities should not therefore reject planning applications simply because the level of output is small. (Paragraph 1(vi), PPS22, 2004) No specific examples have been found of a separate policy for such development (other than the policies for renewable energy in connection with new residential, commercial and industrial development). However, the specific promotion of smaller-scale developments, particularly linked to local community initiatives, could be contemplated. 8.6.2 Community Involvement Government guidance encourages fostering community involvement in the hope of achieving greater acceptance by the public of renewable energy developments. Local authorities might consider whether spatial policies should complement initiatives to encourage such involvement if this was thought to be appropriate. (vii) Local planning authorities, regional stakeholders and Local Strategic Partnerships should foster community involvement in renewable energy projects and seek to promote knowledge of and greater acceptance by the public of prospective renewable energy developments that are appropriately located. Developers of renewable energy projects should engage in active consultation and discussion with local communities at an early stage in the planning process, and before any planning application is formally submitted. (Paragraph 1(vii), PPS22, 2004) Of course production, including energy production, will tend to be more efficiently operated at a larger scale than at the smaller scale. It could therefore be said that it might be preferable for appropriate sites and proposals to be brought forward for the efficient use of the relevant technology, rather than to encourage lots of small-scale developments, which may be uneconomic in the long run. The scale at which the different technologies are viable and economic is also subject to rapid change, as technology evolves and markets change.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

54

8.6.3 Community-based Projects The subject requires careful thought on what might reasonably constitute community-based and small-scale proposals. Previous examples of some form of local involvement have been to include local people on the management board of the company that owns a wind turbine. A particular community-based initiative in the East of England is the Community Renewables Initiative (CRI). This is an initiative by the Countryside Agency, using funding from the Department of Trade and Industry, which supports 10 local support teams throughout England that each provide advice and support for the development of community-based renewable energy projects. CRI-East (www.cri-east.org.uk) is the partnership for the East of England Region, which includes the National Energy Foundation (NEF), Peterborough Environmental City Trust (PECT) and Writtle College (Tel: 0845 120 1516 or E-mail: info@cri-east.org.uk). At a former airfield site at Podington in Bedfordshire, local residents have recently been invited to take a stake in the ownership of part of a proposed wind farm development. The developers, Nuon, reached an agreement with a wind energy co-operative, Energy4All, in order to enable local residents to be given the opportunity to own a part of the scheme. (For information on the project go to http://www.energy4all.co.uk/Pages/Airfield.htm). Interestingly, a Department of Trade and Industry survey in August 2003, entitled Attitudes and Knowledge of Renewable Energy amongst the General Public, found that 64% of respondents agreed that renewable energy would be acceptable if compensation were offered to the local community, such as investment in community projects.

8.7 Policies on particular types of Renewable Energy


8.7.1 Government Guidance A number of local planning authorities have a specific policy on a particular form of renewable energy; most notably wind power and wind farms. The need for such a specific policy appears to arise where a local planning authority is faced with specific proposals and where, on balance, that authority feel that is necessary/helpful to have a specific set of criteria for a particular type of renewable energy development. The advantage of such a policy may also be to help provide a more complete and detailed list of key criteria that often arises with the particular type of renewable energy. However, the emphasis in Government guidance to include a criteria-based policy on renewable energy will mean that there will be little or no distinction in most sets of policies between the different scale and types of renewable energy development. Whilst the local planning authorities in Hertfordshire might not consider that additional planning policies are required, for completeness, the following examples are documented in this report. 8.7.2 Penwith Local Plan Penwith Local Plan Deposit Draft 1998 contains the following renewable energy policy relating to wind farms and wind turbines:

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

55

POLICY CS-9: PROPOSALS FOR INDIVIDUAL WIND TURBINES, GROUPS OF TURBINES OR WIND FARMS WILL BE PERMITTED PROVIDED THAT:(i) THEY MEET THE REQUIREMENTS OF POLICY CS-8; (ii) THEY WOULD NOT POSE A RISK TO PUBLIC SAFETY OR CAUSE DISTURBANCE BY SHADOW FLICKER, REFLECTED LIGHT OR INTERFERENCE WITH TELECOMMUNICATION RECEPTION; AND (iii) MEASURES TO ENSURE THE REMOVAL OF INSTALLATIONS, SHOULD THEY CEASE TO OPERATE, AND THE RESTORATION OF THE SITE CAN BE SECURED THROUGH THE USE OF A PLANNING OBLIGATION. WITHIN THE AREA OF OUTSTANDING NATURAL BEAUTY AND HERITAGE COAST SUCH PROPOSALS WILL NOT BE PERMITTED UNLESS THEY ARE FOR SMALL SCALE, INDIVIDUAL TURBINES LOCATED IN OR ADJACENT TO AN EXISTING COMPLEX WHICH WOULD HAVE NO APPRECIABLE IMPACT ON THE DISTINCTIVE CHARACTER OF THE LANDSCAPE. 8.7.3 Oldham Unitary Development Plan Oldham Metropolitan Borough Council Unitary Development Plan, First Deposit Draft 2001, states: NR3.2 THE DEVELOPMENT OF WIND TURBINES WILL BE PERMITTED, PROVIDED THAT ALL THE FOLLOWING CRITERIA ARE SATISFIED: A. THE PROPOSED DEVELOPMENT WILL NOT CAUSE UNACCEPTABLE HARM TO ANY OF THE FOLLOWING: I) THE LANDSCAPE, THROUGH THE NUMBER, SCALE, SIZE AND SITING OF TURBINES, IMPACT ON THE SKYLINE, CUMULATIVE IMPACT OR THE NEED FOR NEW POWER LINES FOR CONNECTION TO THE ELECTRICITY SUPPLY GRID; II) HIGHWAY SAFETY; OR III) EXISTING TRANSMITTING OR RECEIVING SYSTEMS; B. THE PROPOSED DEVELOPMENT WILL NOT LEAD TO SIGNIFICANT NUISANCE TO THE PUBLIC ARISING FROM NOISE, SHADOW FLICKER, ELECTROMAGNETIC INTERFERENCE OR REFLECTED LIGHT; C. IN THE CASE OF PROPOSALS WITHIN OR HAVING AN IMPACT ON HABITATS OF INTERNATIONAL OR NATIONAL IMPORTANCE OR ADJACENT TO THE PEAK DISTRICT NATIONAL PARK, THE APPLICANT CAN SHOW THAT THERE IS NO OTHER SUITABLE SITE AND THAT ANY HARM TO THE HABITAT OR TO THE OBJECTIVES OF

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

56

THE NATIONAL PARK LIKELY TO BE CAUSED BY THE PROPOSED DEVELOPMENT WOULD NOT BE SIGNIFICANT; D. THE PROPOSED DEVELOPMENT WOULD BE AT LEAST 500M FROM ANY SENSITIVE EXISTING LAND USE, FOR EXAMPLE HOUSING, SCHOOLS OR HOSPITALS, OTHER THAN BY THE EXPRESS AGREEMENT OF ALL THE RELEVANT PARTIES; E. THE PROPOSED DEVELOPMENT ACCORDS WITH THE RENEWABLE ENERGY POLICY NR3.1; AND F. REDUNDANT TURBINES, PLANT, TRANSMISSION LINES AND ACCESS ROADS WILL BE REMOVED AND THE SITES RESTORED. 8.7.4 Caradon Local Plan Caradon Local Plan adopted 1999 contains specific policies on wind and hydro power. POLICY REN2 IN AONBs, HC, SSSIs, NNRs, SAM AND BEST AND MOST VERSATILE AGRICULTURAL LAND, WIND TURBINES AND WIND FARMS WILL ONLY BE PERMITTED IF THE PROPOSAL WOULD NOT HAVE AN UNACCEPTABLE IMPACT ON THE SPECIFIC FEATURES OR QUALITIES WHICH JUSTIFIED SUCH DESIGNATION. IN OTHER AREAS, WIND TURBINES AND WIND FARMS WILL ONLY BE PERMITTED IF THE PROPOSAL WOULD NOT CAUSE UNACCEPTABLE DAMAGE TO AMENITY, LANDSCAPE, SCIENTIFIC, ARCHAEOLOGICAL NATURE CONSERVATION OR HISTORIC INTERESTS, AND THERE IS NO ADVERSE IMPACT ON NEARBY LAND FALLING WITHIN THE DESIGNATIONS GIVEN IN THE ABOVE PARAGRAPH. IN ALL CASES, PROPOSALS MUST COMPLY WITH THE CRITERIA SET OUT IN POLICY REN1, AND TO THE FOLLOWING: (i) THE DEVELOPMENT MUST NOT UNACCEPTABLE DETRACT FROM THE VISUAL AMENITY OF LANDSCAPE THAT MAKE AN IMPORTANT CONTRIBUTION TO THE SETTING OF TOWNS OR VILLAGES; (ii) THE DEVELOPMENT WILL NOT UNACCEPTABLY AFFECT THE AMENITIES OF NEIGHBOURING PROPERTIES BY REASON OF NOISE EMISSION, VISUAL DOMINANCE, SHADOW FLICKER OR REFLECED LIGHT. (iii) THE DEVELOPMENT MUST NOT CAUSE ELECTROMAGNETIC DISTURBANCE TO TELECOMMUNICATIONS. POLICY REN3 SMALL SCALE HYDRO POWER SCHEMES WILL BE PERMITTED SUBJECT TO THE GENERAL CRITERIA SET OUT IN POLICY REN1 AND TO THE FOLLOWING CRITERIA:

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

57

(i) ANY BUILDINGS REQUIRED CONSTRUCTIONS AND DESIGN.

SHOULD

BE

OF

TRADITIONAL

(ii) PIPES AND PENSTOCK SHOULD BE BURIED WHEREVER POSSIBLE. (iii) TURBINE GENERATORS MUST NOT CAUSE NOISE NUISANCE TO NEARBY PROPERTIES. (iv) TRANSMISSION LINES MUST BE LOCATED SYMPATHETICALLY WITH THE LOCAL LANDSCAPE. 8.7.5 Recommended Policy Wording Checklist From the wording of the above policies, a summary checklist can be elicited for reference by each local planning authority when preparing any local development document, if it was ever to be thought desirable or justified to include a separate policy for a particular type of renewable energy development.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

58

A Policy for a Particular Type of Renewable Energy Development Renewable energy development (in the form of .) will be permitted Subject to: The impact on local amenities ! ! ! ! Those key criteria in the general criteria-based policy that would be of relevance to the particular type of renewable energy. Any other key criteria applicable to the particular subject (e.g. shadow flicker, transmitter signal interference) Taking into account the need for new power lines where this could be an issue (e.g. development in sensitive and protected landscapes) The cumulative impact of existing and proposed developments where this situation needs to be taken into account (e.g. with wind farms)

The impact on specific areas of acknowledged importance ! e.g. Areas of Outstanding Natural Beauty, areas of nature conservation importance, designated Conservation Areas, listed buildings and their settings, historic parks and gardens, sites of archaeological importance, Green Belt, etc.

Health and Safety ! ! ! ! Highway safety Human health Ground and surface water quality Air quality (where relevant)

Eventual removal (e.g. where the policy deals with wind turbines) ! An agreement on the measures for the removal of installations

8.8 Policies that promote a form of Renewable Energy in an Area


8.8.1 Government Guidance The publication of revised PPS22 in 2004 changed the context for policies that referred to specific areas. Instead of national guidance calling for the identification of areas of search, the advice is that local planning authorities include criteria-based policies in Local Development Frameworks.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

59

Criteria based policies should be set out in regional spatial strategies where these can be applied across a region, or across clearly identified sub-regional areas. These criteria should then be used to identify broad areas at the regional/sub-regional level where development of particular types of renewable energy may be considered appropriate. (See paragraph 7, of PPS22, 2004) PPS22 has therefore moved away from an approach based on areas of search at the local level and, instead, the task of identifying broad areas where the development of particular types of renewable energy may be considered appropriate falls to the Regional Spatial Strategy. Government advice is that more detailed issues may be appropriate for Supplementary Planning Documents and that specific sites should only be included in plans in special circumstances. Local planning authorities should only allocate specific sites for renewable energy in plans where a developer has already indicated an interest in the site, has confirmed that the site is viable, and that it will be brought forward during the plan period. (See paragraph 6, of PPS22, 2004) Oldham is an authority where its Unitary Development Plan contained a policy on wind power with areas of search. However, the Council now intends to delete these areas because they cover areas valued for their landscape and/or recreational use. The Councils aim in identifying the areas of search was to point potential wind farm applicants to those parts of the Borough where the evidence suggested that wind speeds were fastest and where, relative to other areas, there were somewhat fewer policy constraints, although there were still criteria that would have to be satisfied. The approach, however, did not exclude wind farm developments proposed outside the areas of search. The original reason for identifying the areas of search was to try and avoid some of the initial filtering stages that applicants might have gone through in identifying potential sites. Whilst it is clear that a policy to promote a particular form of renewable energy in a specific area would not be appropriate in the Local Development Framework of the development plan, there may still be a case for considering, at the regional or sub-regional level, whether any broad areas should be identified where development of particular types of renewable energy may be considered appropriate. 8.8.2 Regional and Sub-Regional Considerations As a possible starting point, Figure 5.1 in the accompanying study report identifies an area as potentially attractive for wind farm development in the north-eastern area of Hertfordshire. However, whether this and any other areas adjacent or outside the county in this relatively small part of the region might be appropriate and justified for applying criteria to be used to identify a broad area at the regional/sub-regional level would need to be separately assessed and agreed at the regional level.

8.9 SMART Policies


In conclusion, local planning authorities may wish to consider how SMART their policies are in Local Development Frameworks, in terms of whether each policy is Specific, able to be Monitored, Appropriate, Realistic and Time-related. PPS22 refers to targets in the Regional Spatial Strategy, with the possibility, where appropriate, for these regional targets to be disaggregated into sub-regional targets. This indicates that a

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

60

close liaison between regional and local levels of planning will be required if planning policies are to be monitored with a view to assessing their appropriateness in delivering, or helping to deliver, the desired outcomes within the prescribed time periods. In particular, clear feedback will be required through effective monitoring if the planning policies are to properly respond to the evolving circumstances.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

61

9. Planning Applications

9.1 Planning Applications


Planning applications will range from individual householders seeking permission to install domestic-scale equipment and installations, to major development proposals that are designed, for example, to generate many megawatts of electricity. PPS22 states: 18. Local planning authorities and developers should consider the opportunity for incorporating renewable energy projects in all new developments. Small scale renewable energy schemes utilising technologies such as solar panels, biomass heating, small scale wind turbines, photovoltaic cells and combined heat and power schemes can be incorporated both into new developments and some existing buildings. Local planning authorities should specifically encourage such schemes through positively expressed policies in local development documents. (Paragraph 18, PPS22, 2004) Whilst PPS22 uses the diplomatic language of encourage in respect of dealing with planning applications, the real question is one of requiring such measures and imposing such requirements on applicants and developers. Such requirements are however more effectively introduced if co-ordinated across local planning authorities, both to enable experience to be shared and help create a level playing field for applicants and developers across the wider area. If local planning authorities find that support is forthcoming via both the examination on local development documents and appeal decisions, a more robust approach and greater certainty can be offered in the development control system. Where the question is one of whether a particular development should be permitted or not, the limitations of judging individual planning applications against renewable energy planning policies must be recognised. For example, whilst many planning considerations can be the subject of relatively objective measurements and judgements, a considerable degree of subjective judgement is required, both in terms of the relative impact that a particular proposal will have on such things as amenity and visual impact, and also in terms of the weight that should be properly accorded to the different and often varied considerations that may be relevant. The emphasis on community involvement in plan-making today is likely to reinforce this fact. Section 36 of the Electricity Act 1989 requires developers to obtain a consent from the Secretary of State for Trade and Industry for the construction, extension or operation of a generating station of a capacity over 50 MW onshore (or 1 MW and over offshore). The Department for Trade and Industry also administers development consents for overhead lines and associated permissions (necessary wayleaves, compulsory purchase orders) in England and Wales. Section 36 (power stations) and section 37 (overhead lines) are comprehensive procedures in which the views of the local planning authority, local people, statutory bodies, such as the Environment Agency, Countryside Agency and English Nature, and other interested parties are

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

62

involved in the decision making process. All applications are routed via the local planning authority and therefore appear on the local planning register. In certain circumstances, a public inquiry may be called before the Secretary of State makes a decision.

9.2 Housing Developments


In the case of housing development, the energy requirement for a year for a household of two adults and two children can amount to about 23 megawatt-hours (MWh), which is made up of about 5.5 MWh of electricity (approximately a quarter of the total) and about 17.5 MWh of energy for heating and hot water (approximately three-quarters of the total). The DTI estimate that the average annual electricity consumption (excluding gas, heating oil, etc) of a household in the UK is 4.7 MWh. Local planning authorities have become familiar with the concept of EcoHomes and many now seek an EcoHomes excellent rating (i.e. 70 out of 100 possible points) in connection with residential development. EcoHomes and BREEAM (the Building Research Establishments Environmental Assessment Method) were launched in 1990 and are run by Building Research Establishment Ltd. EcoHomes balances environmental performance with the need for a high quality of life and a safe and healthy internal environment. The issues assessed are grouped into seven categories: Energy Water Pollution Materials Transport Ecology and Land Use Health and Well-Being However, certain questions arise with regard to dealing with individual residential development planning applications and seeking to encourage/require applicants to incorporate appropriate measures in their planning application proposals. What are the implications in practice for energy efficiency initiatives when promoting renewable energy? The basic objective is to reduce carbon emissions, but could requirements to achieve, say, 10% of energy consumption from renewable sources begin to work against maximising energy efficiency in developments? For example, by increasing renewable energy investment in new developments, would developers start to compensate by not maximising energy efficiency measures in the scheme? Policies will need to be carefully constructed to ensure clarity of purpose and ensure desirable outcomes. How are policies to be interpreted (and enforced)? For example, obtaining an EcoHomes credit is based on at least 10% of either the heat (space and hot water) demand, or 10% of the non-heating electrical demand, or 5% of total energy demand, being supplied from local renewable energy sources. To complicate

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

63

matters, electricity from a local (i.e. not National Grid) renewable source, which has been designed to supply the building directly, may be included in the calculations as if it were generated within the building. In addition, in order to measure and verify this requirement, an accredited SAP assessor is needed. Planning policies will need to have close regard to industry standards and recommendations in order to be effective and enforceable. On what would any percentage contribution from renewable energy be based and how would the total estimated energy use for a particular proposal be calculated and agreed? Whilst standard formulae might provide estimates of energy use in relation to floorspace figures, this could easily lead to complications and difficulties for the development control system and for applicants in the absence of clear guidelines and advice.

9.3 Development Control Issues


The issues that will arise at the planning application stage will include: The extent of the information needed to accompany a particular planning application; Pre-application procedures and consultation; Whether an Environmental Impact Assessment is required; Issues of landscape and visual impact, including possible cumulative effects; How possible wider environmental, economic and social benefits should be demonstrated and considered; and The relationship to the development plan and what material considerations also need to be considered. Local planning authorities will need to take into account the cumulative impact of existing and proposed wind generation development in a particular area where this is regarded as a material consideration. (See Paragraph 21, PPS22, 2004) As set out in PPS22, local planning authorities will need to consider such subjects as the impact on amenity, landscape and visual impact, noise, odour, highway safety, and traffic. In relation to landscape and visual impact: Proposed developments should be assessed using objective descriptive material and analysis wherever possible even though the final decision on the visual and landscape effects will be, to some extent, one made by professional judgement. (See Paragraph 19, PPS22, 2004) PPS22 makes it clear that it is the responsibility of applicants and developers to address any potential impacts in relation to radar and aviation in an area. The applicant needs to take into account the guidance from the Civil Aviation Authority, the Ministry of Defence and the Department for Transport. Regard should also be had to the legislative requirements on separation distances. It is the responsibility of the applicant to resolve these issues, if they apply, before a planning application is submitted and it is for the local planning authority to

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

64

simply satisfy themselves that such issues have been addressed before considering the planning application. (See Paragraph 25, PPS22, 2004) Developers of renewable energy projects should engage in active consultation and discussion with local communities at an early stage in the planning process, and before any planning application is formally submitted. (See Paragraph 1(vii), PPS22, 2004) Front-loading (in plan preparation and planning application consultations) is where the local community is informed and involved in the subject, issues and proposals in advance and prior to the consideration of any individual planning applications. The formal arrangements for carrying this out in each local planning authority will be set out in the Statement of Community Involvement, although the procedures may require adaptation for a particular planning application.

9.4 Environmental Impact Assessments


9.4.1 The Environmental Statement European law, interpreted through UK planning legislation, requires that the impact on the environment of certain kinds of development must be thoroughly assessed before planning consent can be granted. Those projects "which are likely to have a significant effect on the environment by virtue ... of their nature, size or location shall be subject to an assessment of those effects ..." will require the submission of an Environmental Statement with a planning application. The Environmental Statement draws together, in a systematic way, expert quantitative analysis and qualitative assessment of a project's environmental effects and sets out the scope for modifying or mitigating those environmental effects. The effects on human beings, flora, fauna, soil, water, air, climate, the landscape, and the interaction between any of the foregoing are normally examined, as well as the effects on the cultural heritage and material assets. Consideration also needs to be given to: the use of natural resources the emission of pollutants the creation of nuisances the elimination of waste When considering applications for the development of renewable energy projects, it will also be necessary to consider the associated environmental benefit of the scheme in preventing the burning of fossil fuels and preventing the emission of further greenhouse gases. 9.4.2 Schedule 1 development The following renewable energy developments would fall under the definition of Schedule 1 development, for which EIA is mandatory: Any combustion installations with a heat output of 300 megawatts or more; Any bio-fuel processing installation where manufacture is on an industrial scale using chemical conversion processes;

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

65

Bio-fuel storage installations with a capacity of 200,000 tonnes or more; Bio-mass installations using non-hazardous waste products as feedstock with a capacity exceeding 100 tonnes per day; Bio-mass installations using hazardous waste products as feedstock [It is unlikely that renewable energy installations of this size are likely to be built in the UK in the near future. Most bio-mass and bio-fuel facilities are likely to be of a smaller scale]. 9.4.3 Schedule 2 development The following renewable energy developments would fall under the definition of Schedule 2 development, for which EIA is mandatory: Major developments which are of more than local importance; Developments which are proposed for particularly environmentally sensitive or vulnerable locations; Developments with unusually complex and potentially hazardous environmental effects; For example: Industrial installations for the production of electricity, steam and hot water where the development exceeds 0.5 hectare. Industrial installations for carrying gas, steam and hot water, where the area of works exceeds 1 hectare. New energy industry building deposit or structure sited within 100 m of any controlled waters. Installations for hydroelectric energy production with a generating capacity of over 500kW [Note: EIAs are required as part of an application for an abstraction license for hydroelectric plant.] The Government has stated that proposals for wind power development may require to submit an Environmental Statement: When development is within, or within 2km of a National Park, Area of Outstanding Natural Beauty, Heritage Coast ,or Site of Special Scientific Interest; or Where the development consists of more than 2 wind turbines, or the hub height of the turbine exceeds 15 m., or has a total capacity exceeding 5MW. It is important to note that the above examples are considered illustrative only. Moreover, projects can be described in different ways, so it is important to consider carefully the scope and purpose of the project and not just its description. Each project should be screened for whether the proposals would have a significant impact on the environment.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

66

9.5 London Renewables advice to Planning Authorities


London Renewables has prepared two summary documents (for planners and for developers) that highlight some key issues for each group. One of the questions referred to in the document for planners offers the following answers to the question how can planning departments be more specific about what they want with regard to renewable energy in developments? Refer to the regional plan's energy policies for the detail on the region's expectations of local planning authority policies. Be clear about (and advertise as appropriate) the technologies that local authorities wish to introduce, where and why (e.g. does the local authority wish to promote wind energy above solar energy given the areas topography?). The most appropriate tool for achieving this is Supplementary Planning Documents (SPD). The aims and objectives for renewable energy within the local authority area should be made explicit. The local planning authority should be clear about (and advertise as appropriate) how it aims to achieve the renewable energy targets set and over what time period. This is a function of the review, preparation and monitoring of the Local Development Framework and the accompanying public consultation mechanisms. Draw peoples attention to good and bad practice using case studies. London Boroughs should require major developments to generate a proportion of the electricity or heat from on-site renewable energy sources. (The mayor expects a target of at least 10% where feasible.) (London Renewables was set up in 2003 and is an independent body comprising representatives of the Greater London Authority, the Association of London Government, Imperial College London, Government Office London, London First, London Sustainability Exchange, London Development Agency, Solarcentury, EDF Energy, Creative Environmental Networks, Renewable Power Association, and the London Environment Coordinators Forum. London Renewables programme aims to increase the amount of renewable energy technologies used in new development, with the aim of enabling London to meet its renewable energy targets as set in the Mayor's Energy Strategy.)

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

67

10. Monitoring

10.1 Monitoring Renewable Energy Targets


In order to put in place strategic energy policies, authorities will need to have a clear understanding of energy usage in their areas in order to set clear baselines and be able to track progress against effective targets. 10.1.1 East of England Plan The East of England Plan offers the following indicators for monitoring purposes.

Table 11.1 East of England Plan Indicators

Indicator No.
49 50 51

Indicator

Collection cycle
Annual Annual Annual

Proportion of regions energy met from renewable energy (10%, 17%) Renewable energy generating capacity by county - national core indicator (N.B. generating capacity is defined as installed and operational) Number of authorities with policies in place (i.e. the inclusion of policies to promote energy efficiency / renewable energy in local development documents)

10.1.2 East of England Sustainable Development Framework The East of England Sustainable Development Framework, published in October 2001 by the East of England Regional Assembly and the East of England Sustainable Development Round Table, offered the following indicators for monitoring in the form of high-level objectives. The Framework explains that these indicators could be used to measure progress towards a more sustainable region. Following the consultation exercise on the document, it was decided by the Regional Assembly and Round Table to omit specific targets, as these were seen to be too prescriptive for a framework document. The Regional Assembly and Round Table consider that it is for users of this Framework to decide on their own targets, as appropriate to their particular strategies or work programmes, and to use these indicators as a guideline only. In respect of one of the general High-level objectives, which refers to the need to reduce the consumption of fossil fuels, the Framework offers the following indicators for possible monitoring purposes: Output of greenhouse gas and particularly CO Weather-related insurance claims Regional energy consumption compared with population and GDP

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

68

Energy use per household Proportion of electricity generated from renewable sources Economic health and prospects of energy industry, including off-shore Proportion of total travel which is by car Transport's share of region's CO emissions Freight transport: tonne/miles and empty lorry miles Air quality improvements measured against related illnesses Tourism by mode of transport The Framework document does not explain just how exactly such information can be collected and monitored, which is presumably a matter for the Regional Assembly. However, the Framework document does point out and acknowledge that building a comprehensive picture of regional activity is still a challenge, and there are many gaps in data. Networks are still incomplete and organisations are still learning about each other and identifying the benefits of cross-regional working. The sustainable development strategic framework, launched by the Government in 2005, sets out a set of 68 national indicators to track sustainable development priorities. These will be published by the Department of Trade and Industry in June 2005. (For more details see http://www.sustainable-development.gov.uk/performance/indicators-home.htm) Work is also underway by the Department of Trade and Industry to collect energy consumption statistical data at regional and local levels (i.e. down to individual local authority area). The latest information is available from http://www.dti.gov.uk/energy/inform/energy_trends/elec2003nuts4regionsexp.xls http://www.dti.gov.uk/energy/inform/regional_energy/index.shtml This website also contains details of the work that has begun on collecting regional and local data on transport fuel consumption. 10.1.3 Monitoring in the South East Region South East England Renewable Energy Statistics (http://www.see-stats.org) is a project that commenced in April 2003 by TV Energy on behalf of the South East of England Renewable Energy Partnership, led by the Government Office for the South East. The project will monitor renewable energy schemes in the region, starting with the Thames Valley and Surrey sub-region and then rolling out across the rest of the sub-regions of Hampshire and the Isle of Wight, East and West Sussex, and Kent. It is intended that the scheme will provide information about individual renewable energy projects, including their status, location, specification, electricity output, numbers employed, and environmental impacts. The project will also indicate how much renewable energy the region is generating and using from renewable sources, including a comparison against the regional targets.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

69

10.1.4 Monitoring Nationally A project called RESTATS, the Renewable Energy Statistics database, is an ongoing study, being undertaken by Future Energy Solutions on behalf of the Department of Trade and Industry, to provide information on all relevant renewable energy sources in the UK. The collection of renewable energy statistics began in 1989 and the study was initially supported by the Statistical Office of the European Communities (Eurostat), whose objective was to encourage the collection of renewable energy statistics, in a standardised form, across all EU Member States. The project identified all relevant renewable energy sources and, where possible, information was collected on the amounts of energy derived from each. The database now contains 15 years of data from 1989 to 2003. The results of the survey are published annually in the Digest of UK Energy Statistics and RESTATS currently holds information on heat and electricity generated from all the following sources: Biofuels, including the combustion of biomass and wastes, gas from landfill sites and digestion processes. Hydro-electricity, both large and small-scale. Wave power. Wind turbines and wind-farms - onshore and offshore. Solar - active solar heating and photovoltaics. Geothermal aquifers.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

70

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

71

11. The Options for Planning


The options for the planning system in Hertfordshire are set out below in terms of three broad basis on which the planning system might engage in the future in the promotion of renewable energy; business as usual; what is possible; and extending the case for renewables. This last option provides the basis for blue sky thinking by the local authorities, in particular, which might provide a convenient way of kicking off the Local Development Frameworks that are due to prepared over the next few years.

11.1 Business as Usual


Appendix 1 indicates a paucity of proposals and a low level of apparent interest by both potential developers and existing residents and businesses. At the present time, renewable energy sources provide only about 0.45% of energy consumed in the region. This compares to a regional target, by 2010, of 14% of electricity to be produced from renewable energy sources within the region. Business as usual is not considered to be an option if Hertfordshire and the East of England intend to move towards, yet alone reach, their own targets.

11.2 What is Possible


The accompanying Renewable Energy Options Report concludes that there is the technical potential within Hertfordshire to achieve the levels of renewable energy production proposed in the East of England Sustainable Development Round Table Study. Strong regional and local level planning policies and increased public awareness can play a major part in attracting developers and influencing the deployment of renewable technologies in Hertfordshire, although this will only be just one aspect of any developers consideration when deciding where to locate. In order to meet the targets defined in the East of England Plan and by 2010, onshore wind would need to be actively encouraged and supported by the local authorities, along with all other forms of renewable energy schemes. The accompanying Renewable Options Report suggests that 10MW of wind energy might be possible (see Table 5.5 in the Options Report), which would amount to about 5 additional large turbines in the county. In the context of the positive push by the Government towards renewable energy, as expressed in PPS22, some might say that this should be regarded as the minimum that the county as a whole should aim for over the next few years. In order to meet the 2020 targets, emerging technologies, such as biomass, will also need to make a major impact. Due to the long initiation periods of many of these projects, effort must be expended now in order to win over public opinion and bring developments forward for the future. The accompanying Renewable Options Report suggests that domestic solar thermal energy might have the greatest potential for penetrating the residential market (see Table 5.14 in the

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

72

Options Report). The Options Report suggests that the promotion of current grant schemes might achieve installation in 0.01% of existing dwellinghouses, whilst reliance on guidance only, via for example Supplementary Planning Documents, might only achieve installation in 5% of new dwellinghouses. Extended promotion and additional financial support for existing householders might increase this to 0.04% for existing dwellinghouses, whilst financial support for builders of new homes might achieve installation in 10% of new dwellinghouses. The scenarios for domestic solar photovoltaic and domestic roof-top wind turbine installations in dwellinghouses predicts an even lower potential penetration of the market (see Tables 5.11 and 5.12 in the Options Report), whilst the prediction for commercial solar photovoltaic installation is also very low (see Table 5.13 in the Options Report). Policy ENV8 in the draft Regional Plan currently seeks local development documents to require all developments above the same threshold to incorporate equipment for renewable power generation so as to provide at least 10% of their predicted energy requirements. In the case of new residential development, for example, the threshold is above 50 dwellings. It is unknown as yet how such an approach might be incorporated into Local Development Frameworks, following any examination in to such policies, and how such an approach would operate in practice in the development control system. There is a danger that the normal approach to seeking planning requirements for renewable energy in new development may still only make a marginal contribution towards the targets, although greater public familiarity and involvement with domestic-scale renewable energy installations could help play a role in achieving greater acceptance of renewable energy technologies in residential development by both developers and the public. However, the local authorities may wish to consider a more radical approach to the question of insisting that renewable energy be incorporated in new development, particularly with the advent of the first round of Local Development Frameworks and the scale of housing development currently being promoted in the growth areas under the Sustainable Communities Plan.

11.3 Extending the Case for Renewables


Some suggested high-level thoughts are set out below with the aim of both providing a basis for considering some radical changes in the role that planning may take in the future process, as well providing an indication of potential subjects for further research. 11.3.1 Renewable energy requirements for new development Section 8.5 of this report deals with the issue of putting in place an appropriate planning policy in respect of renewable energy in new development. The planning system has already lost the opportunity to embed renewable energy in those proposals that have an outstanding planning permission. The planning system will also lose the opportunity to embed renewable energy in those proposals that come forward for consideration prior to significant weight being able to be given to new policies in the Regional Spatial Strategy and the Local Development Frameworks. Under the present draft Regional Plan policy (ENV8), the planning system will also forgo the opportunity to embed renewable energy in those proposals under a certain size (currently up to 50 dwellings for residential development). The draft East of England Plan is currently proposing some 478,000 new homes in the region over a twenty-year period from 2001 to 2021, of which nearly 60,000 dwellings had already been built between 2001 and 2004. In addition, , more than half of the balance of about 418,000

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

73

dwellings already have planning permission, or are allocated in existing development plans. However, the draft East of England Plan currently rejects the need for a further 18,000 dwellings requested by the Government. The Panels Report, on the Examination in Public later this year, is not anticipated until early 2006. The proposed distribution of dwellings within Hertfordshire, as set out under Policy H1 in the draft plan, is set out below in Table 11.1.

Table 11.1 Proposed New Dwellings 2001-2021, Draft East of England Plan, Dec 2004

Annual Average
Hertfordshire Broxbourne Dacorum East Hertfordshire Hertsmere North Hertfordshire St Albans Stevenage Three Rivers Watford Welwyn Hatfield 3,980 255 315 1,040 210 790 350 320 180 230 290

Total 79,600 5100 6,300 20,800 4,200 15,800 7,000 6,400 3,600 4,600 5,800

11.3.2 The Contribution from New Housing Development For the purposes of an assessment on the contribution that new housing development might be able to make, at least in theory, Table 11.2 overleaf sets out a very approximate calculation of the number of new dwellings that might be made the subject of a new planning policy requiring renewable energy sources to be included in the proposals.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

74

Table 11.2 Estimated Number of Dwellings Requiring Planning Permission after 2008
Total dwellings proposed Dwellings built 2001-2004 Dwellings with Outstanding Planning Permission (OPP) as at April 2004 Dwellings assumed to be built prior to Inspectors Binding LDF Report (less OPP to avoid doublecounting) Dwellings assumed to be permitted from 2004 to 2008 prior to when a new RE policy is assumed to be agreed for the development plan Max. no. of dwellings that might be subject of new LDF policy on RE by 2021 based on EoE draft Plan = 79,600 dwellings 2001-2021 = 9,376 dwellings = 9,938 dwellings = (12,648 - 9,938) dwellings = 2,710 dwellings = 15,920 dwellings

= 79,600 - 9,376 - 9,938 2,718 15,920 dwellings = 41,656 dwellings

It has been assumed that the binding Inspectors Reports on most of the LDFs will have been published by 2008. It has also been assumed that the number of dwellings that will be built from 2004 to 2008 will be 4 years x 3,162 dwellings (which represents the mid-point between the annual average of 2,344 dwellings built over the last 4 years and the Draft EoE Plan annual target of 3,980 dwellings. A certain number of additional dwellings will be permitted between 2004 and when a new RE policy is in the development plan (assumed as 2008) which will not be the subject of such a requirement. The Draft EoE annual target of 3,980 dwellings has been used for the purposes of calculation. N.B. LPAs are likely to be able to require RE in new development before 2008 under regional Policy ENV8 once the Panels Report has been published.

This would represent an average annual build rate of about 3,500 dwellings over the period 2009-2021. The Greater London Authority is pioneering an approach requiring developments over a certain size to provide at least 10% of their total energy use from local renewable sources. If a similar approach was to be taken in Hertfordshire for all new housing developments, the annual renewable energy generation would increase by about 5.5 GWh every year, whilst some 66 GWh per year of fossil-derived energy would be displaced by 2021. The detailed calculations for deriving these estimates are set out in Section 5.4.2.2 of the accompanying renewable Energy Options Report for Hertfordshire. The report examines different rates of deployment, besides the 10% displacement scenario, in order to illustrate a low scenario of 5% and an extended case displacement of 20% of fossil-derived energy consumption. However, it should be noted that all the deployment rates, even the low scenario of 5%, are significantly above the rates currently being achieved. A major barrier to deployment is cost and the domestic sector still requires a much greater quantity of products to be taken up by consumers in order to help reduce unit prices. The introduction of appropriate planning policies, or other regulatory measures, has the potential to increase deployment rates, but it will also result in increased costs for developers and ultimately the owners of such properties, at least during the early stages of any major shift in policy. 11.3.3 The Implications of a New Policy However, such a planning policy raises at least two fundamental points if it was to be seriously proposed:

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

75

Any one local planning authority pursuing such a policy, would want, and probably need, a similar approach to be taken by other authorities, not only across the county, but also possibly a region or the UK; Local Planning Authorities will also need clear Government support and guidance, not least of all to ensure that Planning Inspectors at LDF Examinations and at planning application appeals agree with and support such a policy. As a first step in the current planning system, the local authorities would need to think in particular about seeking to remove, or at least modify, in Policy ENV8, sub-paragraph (c), of the draft East of England Plan the words above the same threshold, in order to ensure that a regional policy allows local development documents to require all developments (or at least all residential development) to incorporate equipment for renewable power generation so as to provide at least 10% of their predicted energy requirements. If statistics could be obtained for the proportion of dwellings that might be given planning permission in the future on sites of more than 50 dwellings, then a potential renewable energy contribution could also be calculated in respect of the existing wording in draft Policy ENV8. This would provide a guide on whether the difference (between applying the policy to large sites only, compared to all sites) is significant and therefore whether it would be appropriate for the wording in Policy ENV8 to be re-considered. Even a 100% policy requirement for the incorporation of renewable energy in new dwellings would undoubtedly mean that not all dwellinghouses requiring planning permission would end up including renewable energy installations. Section 9.2 on housing developments, for example, sets out the complications in assessing planning applications, including the EcoHomes credit system and its definitions and standards. Also, many, if not most, listed buildings, the subject of a planning application for alteration or change of use to a dwellinghouse, may not be appropriate for such a policy, bearing in mind the need to have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses. There could also be an issue with affordable housing, where the cost of building and fitting out such accommodation may need to be taken into account, bearing in mind the objective of providing such accommodation. However, the application of renewable energy as a requirement to virtually all new development, particularly for residential development, appears to offer an opportunity that should be seriously considered if there is a serious intent to meet renewable energy targets at the regional and county levels. 11.3.4 Sustainable Buildings Such an approach as that described above, however, will need to take into account the national context for seeking to raise standards and requirements in new development with a view to creating more sustainable buildings. The Government announced in July 2004 the intent for the Sustainable Buildings Task Group to prepare a new Code for Sustainable Buildings for the building industry, which will contribute to cutting greenhouse gas emissions. With nearly 50% of CO emissions in the UK arising from building, maintaining and occupying buildings, and with housing alone accounting for around 25% of greenhouse gas emissions, the new code will aim to establish higher standards for energy and water efficiency, as well as waste and the use of materials.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

76

The Code intention is for the Code to be complete by the end of 2005, in order to enable a national rollout by early 2006. Demonstration schemes, in order to carry out a full regulatory impact assessment and economic appraisal, will form part of the process, including development in the Thames Gateway. An outline of the Code for Sustainable Building, as published by ODPM in January 2005, is set out in Appendix 5. From 2006, new Building Regulations will require a 25% reduction in energy consumption in new buildings. The Sustainable Buildings Task Group recommended in May 2004 that the Code for Sustainable Building be based on the Building Research Establishments Environmental Assessment Method (BREEAM) and incorporate clearly specified minimum standards on the key resource efficiency criteria of energy and water efficiency, and in respect of waste and the use of materials. The Group also recommended that the Government urgently produces a best practice guide for delivering sustainable buildings to accompany Planning Policy Statement 1 (PPS1) on Creating Sustainable Communities. An extract from the Groups report in respect of planning and Planning Policy Statement 1 is set in Appendix 6. (See the DTI web site at http://www.dti.gov.uk/construction/sustain/sbtg.htm ) The Energy Saving Trust is hopeful that a single and consistent national code will encourage the construction industry to make energy efficiency a priority, but point out that energy efficiency standards under the Code for Sustainable Buildings will need to be significantly higher than Building Regulations in order to achieve truly sustainable buildings. 11.3.5 Combined Heat and Power There may also be a role for Combined Heat and Power Schemes. The Combined Heat and Power Association claims that this form of generation not only produces less carbon dioxide than other ways of providing heat and power, but could enable the UK to achieve one third of its international commitments to reducing carbon dioxide emissions if the level of CHP was increased to the Government's target of 10,000 MW. The basic elements of a CHP plant comprise one or more sources (not necessarily a renewable resource) usually driving electrical generators, where the heat generated in the process is utilised via suitable heat recovery equipment for a variety of purposes, including industrial processes, community heating and space heating. The Combined Heat and Power Association claims that there were over 1,100 CHP installation sites in the UK in 2001, of which about 85% of sites in the leisure, hotel and health sectors. Only 55 sites in 2001 (5%) were residential group heating schemes (See http://www.chpa.co.uk). There may be a role for this form of heating and power supply in connection with the larger scale housing and mixed developments that are likely to need to be considered for the growth areas under the Sustainable Communities Plan. There may also be a role if any local authority is a significant land owner where such development takes place. Of possible interest to local authorities is the Private Finance Initiative (PFI), which has provided the public sector with an alternative route to the procurement of new capital assets required to deliver public services. The advantages of the PFI route are that the cost of an asset may be spread over a considerable period of time, which in turn may result in cost savings over the life of the project that can attract interest from lenders, institutional investors and insurers. This flexibility has stimulated interest in more ambitious capital projects, for example, resulting in PFI-based CHP projects in Manchester and in London at Tower Hamlets (See for example http://www.thecarbontrust.co.uk/energy/pages/home.asp).

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

77

Combined heat and power is a subject beyond the remit of this project, but it may be a subject that the local authorities should research in detail in due course if it is considered that there may be future opportunities that the authorities would want to take advantage of and explore. 11.3.6 Community Heating A community heating scheme provides heat from a central source to more than one building or dwelling via a network of heat mains. Heat can be supplied to the scheme utilising the waste heat from power generation (i.e. Combined Heat and Power), from conventional boilers, or from renewable-fired boilers. A community heating scheme may also provide the facility of cooling (or chilled water) for air conditioning via an absorption chilling plant. The Carbon Trust and the Energy Saving Trust published a guide in December 2004 entitled Community Heating for Planners and Developers: A Guide to Delivering Sustainable Communities using Combined Heat and Power and Renewables. This guide is written for all those involved in the planning and development process and applies to all types of buildings within the built environment, including dwellings, commercial and public sector buildings, and industrial buildings. (See http://www.est.org.uk/communityenergy/guidance/chpd.cfm ) The appropriateness of community heating for any given development needs to be specifically examined and the guidance recommends that this should ideally be based on Treasury Green Book Guidance in the case of evaluating public sector investment. There is particular focus in the guidance on the energy requirements of dense areas of development as envisaged in the Governments Sustainable Community Plan. Community heating has suffered from a poor image based on the experience of outdated technologies and systems that have not been adequately maintained. However, in appropriate developments, especially dense urban developments, the guide points out that well-configured modern systems, such as those common in Scandinavia, offer one of the most effective ways to reduce the carbon emissions of buildings. The guidance acknowledges that up-front costs are higher than other options, but points out that community heating schemes can often offer the least whole life cost option and points to several examples of newly installed community heating with CHP and renewables in new build and refurbished private housing schemes in the UK. The guide claims that surveys show that residents are more than content with the schemes. The Guidance considers that regional and local planning authorities have the opportunity to request developers to consider community heating as part of the planning and design of their construction projects. However, community heating schemes below 300 or 400 dwellings are unlikely to be cost effective to a commercial developer where there is little or no housing association funding. Smaller schemes have to date only proven cost effective where public sector discount rates and project lifetimes of over 20 years are used, for example, where a project has significant registered social landlord involvement and the scheme uses Treasury rules for the evaluation of the investment. The density of development will also be a consideration, with new developments of 55 dwellings per hectare and above more likely to be cost effective. Community heating tends to be cost effective in dwellings with few external walls, where the heat demand is dense. Smaller-scale Combined Heating and Power is less likely to be cost effective in such applications because it would be unlikely to operate for long enough. A report on the potential for community heating and CHP can be downloaded from the Energy Saving

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

78

Trust website at www.est.org.uk/communityenergy including descriptions of working examples at Greenwich Millennium Village and at Southampton. Like combined heat and power, community heating is a subject beyond the remit of this project, but it may be a subject that the local authorities should research in detail in due course if it is considered that there may be future opportunities that the authorities would want to take advantage of and explore. One of the most obvious opportunities is likely to be large-scale housing development proposed in the growth areas, which the local authorities may want to investigate and promote in relation to specific sites and proposals. 11.3.7 Promoting Wind Energy In order to meet the targets defined in the East of England Plan and by 2010, onshore wind would need to be actively encouraged and supported by the local authorities, along with all other forms of renewable energy schemes. The accompanying Renewable Options Report suggests that wind energy in Hertfordshire could potentially provide enough electricity to meet the entire target figure of 153GWh that is suggested in the East of England Sustainable Development Round Table Study (See section 1.3). In order to generate this amount of electricity, it is estimated that just over 65MW of wind energy capacity would need to be installed in Hertfordshire, which is equivalent to around 30 large modern wind turbines. This might, in theory, be achieved in the form of 3 to 4 medium-scale wind farms. The question for the local authorities will be whether the community is willing to extend ambitions from about 5 additional wind turbines to around 30. However, such an attainment could have the potential of avoiding the emission of about 70,000 tonnes of carbon dioxide per year. The local authorities should specifically consider the need for planning policies to promote the development of such a scale of wind energy and to direct potential developers to specific parts of the county that may be considered most appropriate, if those authorities intend to help meet the regional targets. Because of the advice in PPS22 against identifying broad areas in local development documents (see section 8.8 of this report), any attempts to indicate preferred areas and to direct developers to what might be considered the most appropriate locations in the county would need to be considered via Supplementary Planning Documents. 11.3.8 Energy Consumption Statements Sub-paragraph (b) of Policy ENV8 of the draft East of England Plan states that local development documents will contain policies that require energy consumption statements for development proposals. These statements are to apply to proposals above a threshold of 1,000 sq m, or 50 dwellings, in order to ensure that the technical, environmental and economic feasibility of alternative systems is considered and is taken into account before construction starts. It is not clear what the energy consumption statements involve, other than the feasibility of alternative systems. Local planning authorities may want to consider going further. The Carbon Trust/Energy Saving Trust guide Community Heating for Planners and Developers: A Guide to Delivering Sustainable Communities using Combined Heat and Power and Renewables provides an example of what they term an option appraisal, which specifically seeks written evidence on an examination of the options for different heating and power

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

79

systems. An example from the guide of the outline content of an option appraisal is set out as follows: 1. Executive summary This part of the report should summarise the financial and environmental benefits of each of the space heating, domestic hot water and electricity generating systems and make a recommendation based on the results. 2. Introduction An indication of the customer, the consultant engineer (who may be the author of the report) and the scope and objectives of the work. Provision of a map of the site and surrounding areas and a description of the proposals. 3. The site, current heating, hot water and electrical systems, services and estimation of heat demand Where applicable, a description of the building and its current services, also outlining the customers likely to be served in early and later phases. Adjacent sites and customers who may be considered for later phased connection. 4. Heating, hot water and electricity options A description of all suitable options considered. Assessment procedures (including carbon reduction). The proposed community heating and embedded generation scheme. The alternative scheme(s) such as electric storage heating, individual gas boilers, or no change to the existing provision of energy. 5. Whole life costing of the main options An analysis showing the net present cost of each alternative using Treasury Green Book Guidance methodology. An analysis showing the net present value of alternatives at commercial rates of discount and project life to determine the attractiveness to a developer. 6. Conclusions State which is lowest whole life cost heating option. State whether or not it is technically practical and feasible to pursue this option. In view of the above, state which option it is recommended to pursue.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

80

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 1 Recent Renewable Energy Planning Applications in Hertfordshire


Local Planning Authority Broxbourne Borough Council Dacorum Borough Council Summary of recent planning applications received
Currently receive about 1 or 2 solar panel applications per year, which are generally approved. No other energy schemes coming forward at present. Occasionally receive photovoltaics applications, which generally are accepted. One enquiry has been received for a wind turbine at a local school, although no formal application has yet been submitted. Supplementary Plan Guidance is being adopted (June 2005) to promote renewable energy usage. Sustainability policies feature in the Local Plan (adopted 2004), although there are no mandatory requirements. A few solar panels applications have been processed and an application received for an ecohouse. (Applications are generally accepted for solar panels, although one on a listed building was refused). The authority has also received an application for a mast for wind speed trials. Currently receive about 1 or 2 solar panel applications per year, which are usually approved. No other energy schemes coming forward at present. Only one application received in recent years, which was an anemometer for wind speed trials, prior to a possible six-turbine wind farm. Various aviation bodies had no objections, but the Parish Council strongly opposed and the application was refused, contrary to the Officer recommendation, for adversely affecting the character and appearance of the area. Currently receive about 1 or 2 solar panel applications per year, which are generally permitted where they are not in a Conservation Area, although the latest application was refused for that reason. No other energy schemes coming forward at present. Not a single enquiry within the last 3 years.

East Hertfordshire District Council

Hertsmere Borough Council North Herts District Council

St. Albans City & District Council Stevenage Borough Council Three Rivers District Council Watford Borough Council

Very little activity to report.

No applications received.

Welwyn Hatfield District Council

Six applications for domestic solar panels during the last few years, mostly within Welwyn Conservation Area. Two applications were refused (for design and siting in a Conservation Area reasons); another was approved by the Councillors against Officer recommendations; two cases involve panels erected without permission, one of which is subject to enforcement. Guidance is currently being produced on renewable energy. No other renewable energy schemes coming forward at present.

Source: Telephone survey by Entec UK Ltd of each local planning authority during May 2005.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 2 Examples of Renewable Energy Schemes

Wind Turbines
Turbine details UKs tallest wind turbine Location Swaffham, Norfolk http://www.ecotech.org.uk/ Supplier / Developer Ecotech Local Planning Authority Breckland District Council

Proposed single Enercon E66 turbine Hub ht. 85m Rotor diameter 70m

2MW

Green Park, next to J.11 M4, Reading

Ecotricity

Wokingham District Council

Proposed 5 x 1.3 MW Bonus turbines Proposed 12 x 2MW turbines

Westmill Farm, Watchfield

Highworth

Road,

Baywind

Vale of White Horse District Council Huntingdonshire District Council

Red Tile Farm, Warboys, Huntingdonshire

Wind Prospects

N.B. In addition to the above, Your Energy applied in August 2004 for 16 x 2MW turbines to South Cambridgeshire District Council at roadside services on the A14 near the villages of Conington and Boxworth (between Huntingdon and Cambridge). N.B. The existing turbine at the RES offices at Kings Langley, Hertfordshire, is only a 0.225MW turbine.

Sources of Further Information on Wind Turbines A full list of wind farms currently operating can be obtained from http://www.bwea.com/map/list.html Small-scale turbines not grid connected available from http://www.bwea.com/map/singles.html Wind energy projects under construction in 2005 is available from http://www.bwea.com/map/2005.html Wind energy sample photographs are available from http://www.bwea.com/media/photo/index.html

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Biomass Projects
Biomass type Waste tyres Address Four Ashes Industrial Estate, South Staffordshire http://www.eprl.co.uk/dev elopments/four_ashes.html Thetford Power Station, Mundford Road, Thetford, Norfolk http://www.eprl.co.uk/asse ts/thetford/overview.html Eye Power Station, Oaksmere Business Park, Eye, Suffolk http://www.eprl.co.uk/asse ts/eye/overview.html Straw burning Ely Power Station http://www.eprl.co.uk/asse ts/ely/detail.html Glanford Power Station, Flixborough Industrial Estate, Scunthorpe, North Lincolnshire http://www.eprl.co.uk/asse ts/glanford/overview.html Norbury Park Workshop, Mickleham, Surrey http://tvenergy.co.uk/pdfs/ case-study-norburypark_draft2.pdf Wood burner Tanners Hatch Youth Hostel, Ranmore Road, Dorking, Surrey http://tvenergy.co.uk/pdfs/t anners-hatch.pdf Youth Hostel Association Mole Valley District Council EPRL East Cambridgeshire District Council North Council Lincolnshire Supplier/Developer EPRL Local Planning Authority South Staffordshire District Council

Chicken litter (feathers, horse bedding, agricultural resides)

EPRL

Breckland District Council.

Meat and Bone Meal

EPRL

Wood boiler

Surrey County Council / Surrey Wildlife Trust

Mole Valley District Council

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Biofuels
Biofuel type Bio-fuel manufacturers Address Biofuel.org.uk, Cambridge http://www.biodiesel.org.uk/ Global Commodities, Shipdham, Norfolk (looking to expand, possible Kings Lynn site) http://www.globeco.co.uk/ default.htm Greenergy current plant at BIP (Oldbury) Ltd in the West Midlands New plant under construction at Immingham http://www.greenergy.co.u k/company/biodiesel_plant /index.html Small-scale Bio-diesel manufacturer (waste cooking oil feedstock) Aeolus, 1 The Weald, Ashford, Kent dteal@aeolus.worldonline. co.uk Aeolus Ashford Borough Council Supplier/Developer Biofuel.org.uk Local Planning Authority Cambridge City Council

Biodiesel from rape seed feedstock

Global Commodities

Breckland District Council

Large-scale Biodiesel manufacturer (rape seed feedstock)

Greenergy

Sandwell Metropolitan Borough Council

Sources of Further Information on Biofuels Information on biodiesel from fresh and waste vegetable oil, using oscillatory flow technology developed at the University of Cambridge Department of Chemical Engineering, is available from http://www.bio-diesel.org.uk/

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Solar/Water/Mixed-schemes
Renewable energy type Solar panels + Wind Charger Demonstrator site. Address Reading International Solidarity Centre http://tvenergy.co.uk/pdfs/ risc.pdf Alpine Close, Greenfields, Maidenhead http://tvenergy.co.uk/pdfs/ rbwm.pdf Small scale wind + Solar PV Leckford Estate, Hampshire http://tvenergy.co.uk/pdfs/l eckford.pdf turbineSustainable and energy efficient visitor facility, Egg Farm, Kings Langley, Herts. http://tvenergy.co.uk/pdfs/ res-egg-farm-casestudy.pdf Solar panels + wind turbine Brill School, Brill, Buckinghamshire http://tvenergy.co.uk/pdfs/ Brill%20Case%20Study.p df Parsons Green, Guildford, Surrey http://tvenergy.co.uk/pdfs/ parsons-green.pdf Bracknell Town Centre http://tvenergy.co.uk/proje cts.htm#BIOCOGEN Brill School Buckinghamshire Council Waitrose PLC Test Valley District Council Maidenhead and district housing association Royal Borough of Maidenhead and Windsor Supplier/Developer Sustainable Energy Alliance Local Planning Authority Reading Borough Council

Solar domestic PV installation

Wind, Miscanthus planting, heat store, solar panels

RES

Three Rivers District Council

PV Roof tiles

Apex Housing Association

Guildford Council

Borough

Proposed project: District heating, integrated photovoltaics, small-scale wind turbines, biomass anaeobic digestion Small-scale hydro

Bracknell Forest Council

River Mole, Betchworth Estate, Betchworth, Surrey http://tvenergy.co.uk/pdfs/ betchworth-estate.pdf

Betchworth Estate

Mole Valley Council

District

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 3 Public attitudes to Renewable Energy


Wind Turbines
Region Poll Date Results

Devon

MORI

November 2004

! ! !

Vast majority of Devon residents support the use of renewable energy (86%) and only a small proportion oppose it (2%). Support for renewable energy is reflected in high levels of support for wind power (76%) and biomass power (67%). Almost half of respondents have no strong feelings about the way wind farms look (47%) and the remainder, who expressed an opinion, are evenly split; a similar proportion say they like them as don't like them (28% v 24% respectively). Rural residents are more likely to oppose the use of wind power than urban residents (18% compared to 13% overall), although opposition in rural areas remains lower than one in five.

http://www.mori.com/polls/2004/regensw.shtml London London Renewables Study December 2003 ! ! ! ! Three quarters of Londoners have said they would be in favour of solar panels in their local area. Nearly 50% said they would pay more for green electricity. 84% of stakeholders consider it important that local authorities use planning powers to secure renewable energy in new buildings. 59% of stakeholders consider commercial house builders as an important group to help meet renewable targets.

http://www.london.gov.uk/mayor/environment/energy/renew_resources.jsp England DTI Renewables Study August 2003 ! ! Over 90% of the general public felt that renewable energy was a good idea, whilst only 1% described renewable energy as a bad idea. Over 90% of the general public sample agreed that the Government should encourage the use of renewable energy and there was virtually no disagreement with this statement. Under half of respondents agreed that individual households should contribute to the cost of increased use of renewable energy. 64% of respondents agreed that renewable energy would be acceptable if compensation were offered to the local community, such as investment in community projects. Almost two-thirds would be happy to have a clean renewable energy generating station built in their area.

! !

http://www.dti.gov.uk/renewables/policy/nationalreport.pdf

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 4 Renewable Energy in an AONB


As an example of planning guidance on renewable energy proposals in an Area of Outstanding Natural Beauty, the Position Statement of the Blackdown Hills Rural Partnership on Wind Energy, as published in June 2004, is set below for information. (See http://www.blackdownhills.net/planning.htm)
The need to address climate change and reduce carbon emissions, alongside a diminishing finite supply of fossil fuels, is widely acknowledged. The consequences of climatic change could be significant for landscape and biodiversity. Energy generation from renewable sources is an important contribution to tackling this issue, alongside measures to reduce energy use and improve energy efficiency. However, this needs to be balanced with the impact that renewable energy developments may pose to the character of nationally important landscapes. The Blackdown Hills Plan 2004-2009 sets out the policy objectives of partners for the management of the Blackdown Hills AONB. The Plan contains the following objectives for Utilities and Renewable Energy: SI 7.1 To restrict, and where possible reduce, visual intrusions on the Blackdown Hills landscape such as radio masts, overhead powerlines and wind turbines. SI 7.2 To support the sensitive utilisation of renewable energy resources that are compatible with conserving the natural beauty of the AONB. The primary purpose of AONB designation is conservation and enhancement of natural beauty. Wind turbine developments in particular pose a significant threat to the essential qualities of the Blackdown Hills that gave rise to designation as an AONB, namely, the areas unspoilt character, remoteness and tranquillity. Therefore there will be a presumption against commercial wind energy developments in the AONB as it is unlikely that such proposals could be located without compromising the objectives of designation. In the event of proposals to develop wind turbines in the AONB, it is essential that an Environmental Impact Assessment should be carried out well before any planning application is made. Proposals will need to clearly demonstrate how conservation and enhancement of the area will not be compromised. In particular, the BHRP will seek evidence that an adequate site selection process has been carried out, including proper consideration of alternative sites outside the AONB and justification for the chosen site. The assessment should also include any cumulative impact on the landscape; design, colour and size; the effects of related infrastructure, such as access roads and grid connection; and issues surrounding decommissioning. AONB boundaries rarely present a sharp border of landscape quality, and so in some cases, adjacent developments may affect peoples enjoyment of the AONB and/or affect its character. The extent of the impact of development in adjoining areas will depend on visibility to and from the AONB and the precise character of the countryside and such cases will be assessed on an individual basis. There may be scope for small scale wind energy schemes to be accommodated in some locations without having an adverse impact on landscape or compromising the objectives of designation. Small scale schemes are likely to relate to single or small turbines supplying power to individual or clusters of homes, businesses or community buildings including schemes that are community led. There is considerable potential for the development of community led renewable schemes that meet local needs and are of a scale and nature that is compatible with conserving natural beauty, which may include micro-hydro, wood heat, active solar and photovoltaics. Where they are permitted, all developments of any nature should achieve the highest standards of quality and respect the qualities that underline the AONB designation.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 5 Code for Sustainable Building

Code for Sustainable Building (CSB)


Published by ODPM on 24 January 2005

What is the code? The code is a voluntary initiative, by Government and Industry, to actively promote the transformation of the building industry towards more sustainable practices by requiring buildings that use: Energy resources more efficiently; Water resources more efficiently; Material resources more efficiently; and Practices and materials designed to safeguard occupants' health and well being. A Senior Steering Group has been established to oversee the development of the CSB. Why is it needed? The principal objective of the code is to become the single national standard for sustainable building that all sectors of the building industry will subscribe to and consumers demand. To promote more sustainable building practices so that: today's best practice becomes tomorrow's standard practice. Guiding Principles for the Code Properties built to the code should be perceived by stakeholders as more marketable than other properties. Builders using the code will want to differentiate themselves in the market place as 'builders of quality'. Properties built to the code should be perceived by consumers as 'better built with lower running costs'. Compliance criteria should be simple, concise and clear. Compliance verification process should be perceived as reasonable, manageable and worthwhile - not burdensome.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

What is the timescale for this work? The Senior Steering Group aims to produce the first draft outline of the code in time for the Sustainable Communities Summit in January 2005. The aim is to complete development and testing of the code by the end of 2005, and to take action on the national rollout by early 2006. The first phase of the development work will focus on new build housing. Resources have been committed to establish demonstrations of the code across the Thames Gateway and within a HMR pathfinder area.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 6 Sustainable Buildings Task Group Report


An extract from section 4 on Planning and PPS1 from the Sustainable Buildings Task Groups report, Better buildings - better lives, published 17 May 2004, is reproduced below.
4.1 The Group has responded to the Governments consultation paper on Planning Policy Statement 1: Creating Sustainable Communities (PPS1). Paragraph 4.2 to 4.12 below form the basis of the response. 4.2 We support the main thrust of draft PPS1. In particular we welcome the Governments commitment to securing sustainable development and prudent use of natural resources through the planning system. The Group endorses the view that: policies should reflect a preference for minimising the need to consume new resources over the lifetime of the development [and that] consideration should be given to encouraging energy efficient buildings, community heating schemes, and the use of combined heat and power in developments (paragraph 1.21). 4.3 The Group welcomes the new duty in the Planning and Compulsory Purchase Bill for planmaking bodies to have the objective of promoting sustainable development. PPS1 will be a crucial tool in delivering this duty, but we believe that it needs to be much clearer about the extent to which the planning system can require more sustainable building practices in support of the new sustainable development duty, as opposed to merely encouraging or promoting them. 4.4 The planning system has an important role to play in promoting sustainable building practices. It can do this in at least three ways: (i) by encouraging higher standards of building performance than the minimum required through Building Regulations; (ii) by promoting area-based measures and infrastructure for improving building performance that are outside the scope of Building Regulations, such as sustainable urban drainage systems or the use of local combined heat and power (CHP) generation; and, (iii) by ensuring that the design, relationship and layout of new buildings support, rather than frustrate, peoples desire to pursue a lifestyle that is more environmentally and socially sustainable. An example of this might be by providing convenient space for separate waste collection and handling facilities to aid recycling on housing and industrial estates. 4.5 We agree with the PPS1 consultation document that planning should not duplicate aspects of sustainable buildings dealt with by the Building Regulations. On the other hand, planning plays a positive role in delivering elements of sustainable development through more sustainable building practices that cannot be delivered through control of individual buildings alone. For example, the aspect of a building has a major impact on its energy efficiency (passive solar gain) but is not controlled by the Building Regulations. 4.6 The Group supports the Governments desire to speed up the planning process and make it more transparent. We believe there is great scope for pre-application discussions on planning applications and sustainability appraisal of development plans without causing delays or confusion in development control or plan making regimes. Clarification is needed so that any potential conflict in Government policies for increased delivery and improved quality are avoided. A much clearer policy lead is required at the national level to support the wide range of initiatives to promote more sustainable building practices that have been made at the local level in recent years. 4.7 Issues relating to design and spatial planning are already dealt with in various planning guidance documents and other standards. For example, site layout and external features are dealt with in the standards developed by CABE and English Partnerships. Good Practice Guides supporting various Planning Policy Statements, for example PPG3 Housing and the forthcoming revision to PPG4 Industrial and Commercial Development also deal with spatial issues. We believe that the best practice guide recommended in paragraph 4.8 below needs to be consistent with the relevant elements of the CSB, particularly as regards site layout and external features.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

4.8 The Group recommends that the Government produce, as a matter of urgency, a best practice guide for delivering sustainable buildings to accompany PPS1 Creating Sustainable Communities. This guide needs to be consistent with the relevant elements of the CSB recommended in paragraph 2.4 and should highlight where Building Regulations and the planning system complement each other. This guide should not seek to address issues that fall within the scope of the Building Regulations, but should deal with spatial issues such as drainage systems, community heating systems and waste management. In particular the guide should: bring together and cross-refer the wide range of guidance and good practice that has already been produced, for example the BRE Sustainability Checklist. We note and welcome that CABE, English Partnerships and the Housing Corporation are aiming to synthesise their standards. We also welcome the Governments support to develop the BRE Sustainability Checklist for all Regional Development Agencies. explain the complementary roles of the building control system and the planning system and promote better coordination between the two; suggest model development plan policies for sustainable building; and, promote examples of good practice in the provision of Supplementary Planning Documents and planning briefs.

4.9 In addition, the best practice guide should consider the full range of sustainable building measures that can be promoted through the planning system including: improved energy efficiency in development design and layout; renewable energy generation; improved water efficiency, including sustainable drainage, in development design and layout; reduction in use of materials and recycling in both the construction process and in the use of the completed building; and, design for sustainable transport.

4.10 In particular, the Group recommends that Government should investigate how the planning system could support better water management. The Group notes and welcomes the interim code of practice agreed by the National Working Group on sustainable drainage (SUDS). We note that the issue of funding for the maintenance of UDS remains unresolved and urge the Government to address this issue. 4.11 There is increasing pressures to develop land that is close to or in the flood plain. We recognise the increased future flood risk estimates set out in the recent report of the Office for Science and Technology (OST) Foresight programme. Flood Risk Assessments should be produced for all development in the flood plain, proportionate to the development proposed. At the level of an individual building, the Building Regulations should require modern standards of flood resistance and resilience for all construction within areas of flood risk (see paragraph 3.10). 4.12 The Group recommends that the Government should ensure that development and planning policy seeks to minimise, and where possible avoid adding to, the overall level of flood risk. This should include reviewing and strengthening PPG25 Development and Flood Risk and making the Environment Agency a statutory consultee on flood risk in its forthcoming revision to the Town and Country Planning General Development Procedure Order (GDPO).

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 7 Policy ENV8 in the Draft Regional Plan


Policy ENV8 in the December 2004 draft consultation version of the East of England Regional Spatial Strategy is set out below for information.

Policy ENV8: Renewable Energy and Energy Efficiency To help the region move towards energy self-sufficiency, and meet and improve on its renewable energy targets set out in table 9.2, local development documents will contain policies for promoting and encouraging energy efficiency and renewable energy. These policies will presume in favour of, and emphasise the wider sustainable development benefits associated with, energy efficiency and renewable energy and will: a) require developers to maximise energy efficiencies to be gained from sustainable design and construction, community heating and combined heat and power schemes, and encourage developers to strive to achieve energy efficiency standards that exceed minimum standards; require energy consumption statements for development proposals above a threshold of 1,000 sq m or 50 dwellings, in order to ensure that the technical, environmental and economic feasibility of alternative systems such as: decentralised energy supply systems based on renewable energy combined heat and power (CHP) district or block heating or cooling, if available heat pumps, under certain conditions is considered and is taken into account before construction starts c) require all developments above the same threshold to incorporate equipment for renewable power generation so as to provide at least 10% of their predicted energy requirements specify the locational and other criteria by which applications for renewable energy developments will be assessed. Local development documents policies will define and relate renewable energy and energy efficiency policies to: Sustainable Communities Plan growth areas (see chapter 5, sub-regional and sub-area policies) settlements outside growth areas non-designated landscapes designated landscapes in accordance with the detailed guidance in appendix C to this RSS.

b)

d)

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

e) favourably consider the on-shore developments associated with off-shore energy generation f) encourage the use of existing infrastructure and the undergrounding of cables connecting new plant to the grid, wherever possible g) encourage methane exploitation from appropriate landfill sites, provided this is not used to prolong landfill operations beyond currently agreed targets h) actively encourage the development of community-based schemes, through full community engagement, for renewable energy generation and energy efficiency. Smallscale and community-based schemes appropriate to local need are most likely to be permissible in areas which are: within or close to settlements within suitable landscapes close to the origin of the energy resource close to groups of buildings (in rural areas). Supplementary planning guidance and, for major proposals, development briefs should be produced to elaborate and support renewable energy and energy efficiency policies and locational criteria contained in local development documents. Supporting Text 9.30 The UK government, as a signatory to the Climate Convention, committed the UK at the 1997 Kyoto Conference to reduce its greenhouse gas emissions by 12.5% below 1990 levels over the period 2008-2012. The Governments Climate Change the UK programme (2000), sets a higher target for reducing carbon dioxide emissions by 20% by 2010. The climate change programme also sets out a broad range of policies and measures across all sectors of the economy. It contains targets requiring suppliers to increase the provision of electricity from renewable sources to 10% and to at least double combined heat and power (CHP) capacity by 2010. The Energy White Paper Our energy future creating a low carbon economy (2003) sets a domestic goal to reduce carbon dioxide emissions by 60% below current levels by 2050. Other national goals are to maintain the reliability of energy supplies, promote competitive markets in energy and ensure adequate and affordable heating in every home. A doubling of the 2010 renewables share of electricity is aspired to by 2020. The Government has introduced a number of initiatives including a new renewables obligation, to succeed the non-fossil fuel obligation and the climate change levy. National and regional objectives relating to climate change will not be achieved without substantial efforts to save energy consumption and a switch to energy produced from naturally occurring, renewable sources. Current national planning policy guidance on renewable energy is set out in PPS22 (Renewable energy), which requires planning policies at regional and local levels to provide an effective framework encouraging these kinds of development.

9.31

9.32

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

9.33

The policy for renewable energy and energy efficiency in this RSS is based on a hierarchical approach, which, in descending priority order, seeks to encourage sustainable forms of development that: use less/reduce the need for energy use energy more efficiently use renewable energy uses clean and efficient technology for fossil fuel powered heating & co-generation.

9.34

A study commissioned by the East of England Sustainable Development Round Table in 2001, (Making renewable energy a reality setting a challenging target for the East of England), identified the sources of renewable energy in the region with the greatest potential as off-shore and on-shore wind, biomass, biofuels and solar power. The study concluded that, with a concerted effort by all the relevant authorities and agencies, 14% of the region's electricity could be produced from these renewable sources by 2010. This target has been adopted in the Regional Sustainable Development Framework. It has been reviewed for this RSS using the same methodology to establish a revised target for on-shore renewables generation at 2010 and new targets for 2020. Detailed explanations and workings are contained in technical paper Regional renewable energy targets for the East of England 2010 and 2020, 2004). In summary, the targets are shown in table 9.2:

Table 9.2 Reviewed renewable energy targets for 2010 and 2020 expressed as the percentage contribution of renewables to total electricity consumption in the East of England
2010 Excl. off-shore wind 10% 2010 Incl. off-shore wind 14% 2020 Excl. off-shore wind 17% 2020 Incl. off-shore wind 44%

9.35

For the purpose of this policy the means of generating renewable energy include photovoltaic energy, solar-powered and geo-thermal water heating, wind (onshore and, as relevant, offshore), energy crops and biomass, energy from human sewage and agricultural plant and animal waste but not energy from domestic or industrial waste, except the harvesting of methane from existing landfill sites. The development of renewable sources of energy; the use of energy efficient layout, design and equipment in new buildings; giving priority to locating new development in or adjacent to urban areas and the introduction of other measures to reduce the need to travel and increase the use of public transport (see policy T1) will all help to ensure that consumption of carbon-based energy is reduced. Farm diversification and rural employment can be assisted through the use of arable and forestry crops for power or heat generation and the production of biofuels. Scale will vary. Increasingly, smaller scale renewable applications are able to meet local needs for heat or power, so reducing demand for electricity produced from non-renewable resources.

9.36

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

9.37

EU Directive 2002/91/EC on the energy performance of buildings comes into force in 2006. Policy ENV8 (b) anticipates the provisions of article 5 on the basis that early implementation of this provision will increase the likelihood that the regional targets will be achieved. The generation of renewable energy happens not only at renewable power stations, but can also comprise an integral part of all new developments. Policy ENV8 (c) requires such provision in larger developments. In developing renewable energy schemes it is important to ensure they are compatible with other environmental objectives for the region, while recognising the specific locational requirements of certain renewable energy technologies. Issues of location and scale need careful consideration. Guidance on the derivation of locational criteria for incorporation in local development documents is contained in appendix C. It is important that individual proposals are considered in the full context of sustainable development, with their environmental, social and economic benefits properly accounted. In this context, if pursued in a sustainable manner, the exploitation of renewable energy sources could bring significant economic benefits, especially in terms of rural regeneration through the development of sources and technologies such as biomass and biofuels.

9.38

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Appendix 8 Information Sources


Government Departments & Agencies http://www.odpm.gov.uk - The Office of the Deputy Prime Minister responsible for local and regional government, planning, housing, fire, regeneration, social exclusion and neighbourhood renewal, including the creation of sustainable communities. http://www.dti.gov.uk/energy/ - The DTI's Energy Group deals with a wide range of energy related matters covering production, generation and supply. The Energy Group is committed to working with others in order to ensure a competitive energy market, whilst also achieving safe, secure and sustainable energy supplies. Work is also underway by the Department of Trade and Industry to collect energy consumption statistical data at regional and local levels (i.e. down to individual local authority area). http://www.defra.gov.uk - This site provides information on climate change, what causes it, how the world and the UK could be affected, what is being done to tackle the effects of climate change, and how industry, businesses, and individuals can do their bit to reduce greenhouse gas emissions. The site also has information on such matters as the Woodland Grant Scheme and the Farm Woodland Premium Scheme. http://www.est.co.uk - The Energy Saving Trust is one of the UK's leading organisations tasked with sustainable energy solutions in homes and on the road. They provide consumers and stakeholders with accurate, independently verified information on the benefits of sustainable energy products and services. They are recognised as a key provider of facts and figures on energy saving, while the Homes Energy Efficiency Database will provide a comprehensive picture of the uptake of measures across the UK. http://www.thecarbontrust.co.uk - The Carbon Trust provides free, practical advice to business and public sector organisations to help you reduce energy use. http://www.clear-skies.org - Clear Skies, funded by DTI and managed by BRE, aims to give householders and communities a chance to realise the benefits of renewable energy by providing grants and access to sources of advice. Householders can obtain grants between 400 to 5000 whilst not-for-profit community organisations can receive up to 100,000 (50,000 from April 2005) for grants. http://www.renewableseast.org.uk/intro_default.asp - Renewables East covers Hertfordshire, Norfolk, Suffolk, Essex, Bedfordshire and Cambridgeshire with the aim of helping the region to meet its renewable energy targets whilst ensuring the area gains the widest economic benefit. http://www.countryside.gov.uk - The CRI (Community Renewables Initiative) helps communities devise renewable energy projects that suit their locality and that they can benefit from. Their work covers a range of geographic locations, from remote rural areas to market towns, farmed landscapes to villages, and even cities and their edges. www.cri-east.org.uk - CRI-East is the partnership for the East of England Region, which includes the National Energy Foundation (NEF), Peterborough Environmental City Trust (PECT) and Writtle College.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

http://www.lga.gov.uk - The Local Government Association (LGA) was formed on 1 April 1997 and represents the local authorities of England and Wales - a total of just under 500 authorities. The LGA exists to promote better local government. They work with and for their member authorities to realise a shared vision of local government that enables local people to shape a distinctive and better future for their locality and its communities. http://www.natenergy.org.uk/ - The National Energy Foundation (NEF) is an independent educational charity based at Milton Keynes and controlled by an eminent Board of Trustees. It was established in 1988 to work for the more efficient, innovative and safe use of energy and to increase public awareness of energy in all its aspects. http://www.caddet.org - A unique source of information on commercial energy-saving and renewable energy technologies. http://www.swea.co.uk - The Severn Wye Energy Agency is one of a network of agencies across Europe, set up to stimulate the development of sustainable energy through local and regional action for energy efficiency and the use of renewable energy sources. The Severn Wye Energy Agency offers support to local authorities in achievement of their objectives under the Home Energy Conservation Act and strategic planning for renewable energy, as well as developing a range of initiatives with other local, regional and national bodies. http://www.actionrenewables.org - Action Renewables is a new programme based in Northern Ireland that has been set up in order to stimulate awareness of the issues associated with conventional energy use and of the range of solutions available through renewable energy technologies. http://www.sustainable-development.gov.uk/performance/indicators-home.htm - Sets out the UK Government Sustainable Development Strategy indicators. These comprise of a set of highlevel indicators in order to provide an overview of sustainable development across the UK and shared UK Framework Indicators that will be a mix of indicators, targets and performance measures in the individual strategies for the UK Government, Scotland, Wales and Northern Ireland. The indicators will be used to report annually on progress and assess whether the UK is succeeding in its goals, or whether different policies need to be developed. The indicators will also show how the UK compares internationally, reporting on global and EU trends, and exploring the feasibility of indicators to measure UK impacts overseas. http://www.london.gov.uk/mayor/environment/energy/london_renew.jsp - The website of London Renewables, the organisation works with the London Energy Partnership to enable London to meet its renewable energy targets as set in the Mayor's Energy Strategy. London Renewables promotes the uptake of renewable energy technology in the capital, in particular in buildings and new developments. Its programme, London Renewables - energy for our future is match funded by the Department of Trade and Industry. http://www.regensw.co.uk - Regen SW is the renewable energy agency for the South West of England. http://www.restats.org.uk - A renewable energy statistics database.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

Other Sources http://reslab.com.au - In 1998, the Alternative Energy Development Board of Western Australia funded the Australian CRC for Renewable Energy to develop a series of factsheets on renewable energy resources and technology. http://www.ecocentre.org.uk - The ECO Centre was established in 1980 as the West Wales Energy Group. Its remit is the promotion of the issues surrounding energy use and the environment. Primarily, they seek to reduce society's impact on the environment; in particular, its contribution to global warming and unnecessary climate change. http://www.cler.org/predac/ The CLER is the co-ordinator and initiator of the PREDAC (Promotion of Renewable Energy and Development of Actions at a Community Level) project. The goal of this project is to develop experience exchanges between European renewable energy and energy conservation actors. The project started on January 1st, 2002, with a total of 23 European partners - in 10 European countries - participating. The 2-year program is 67% subsidised by the European Union. http://www.foe.co.uk/england/ - Friends of the Earth. In communities across the country, they are asking for better transport, a solution to the waste crisis and creative ideas for a sustainable economy. http://www.reic.co.uk - The Renewable Energy Investment Club is an initiative to promote commercial activity in renewable energy. It enables renewable energy developers in other companies to issue shares to people interested in renewable energy. It enables local people to have a real stake in sustainable energy initiatives such as solar, wind, tidal, hydro or biomass, by linking them with renewable energy developers and providing a mechanism for investment in approved projects. http://esta.kiwi.co.uk/ - The ESTA web site is designed to help save energy and operating costs by applying energy management to buildings and processes. http://www.greenhouse-warming.org.uk/ - The site provides 30 information sheets on the subject of global warming. http://www.eci.ox.ac.uk/lowercf/demandreduction.html - The UK Energy Research Centre (UKERC) addresses the challenge of how to reduce energy demands by considering the introduction of new technologies and ways of influencing consumer behaviour, whilst also covering concerns about distribution and affordability. The Centre looks at the reducing the demand for fossil fuel energy and energy services / mobility, in order to contribute to reducing carbon emissions from energy use. http://www.eci.ox.ac.uk/lowercf/40house.html - The Environmental Change Institute (ECI) of the University of Oxford has a 40% House project, which studies behavioural and technological changes in the search for 60% better energy use across the housing market. http://www.tvenergy.org - TV Energy operates in Berkshire, Buckinghamshire, Oxfordshire, northern Hampshire and Surrey and promotes and facilitates practical sustainable energy solutions, as well as provide education for communities, businesses, organisations and individuals within and around the Thames Valley area.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

http://www.cse.org.uk - The Centre for Sustainable Energy (CSE) is a national charitable company that was established in 1979 and is based in Bristol with a board of trustees and around 30 staff. The Centre aims to advance sustainable energy policy and practice by seeking solutions that engage people and communities and which are both environmentally sound and affordable. http://www.nef.org.uk - The National Energy Foundation (NEF) is an independent educational charity, based at Milton Keynes and controlled by a Board of Trustees. It was established in 1988 to work for the more efficient, innovative and safe use of energy and to increase public awareness of energy in all its aspects. The Foundation encourages the development of renewable energy and energy efficiency. http://www.create.org.uk/default.asp - CREATE is a not-for-profit body that works with communities and organisations in order to reduce the effects of climate change and help build a sustainable future. Over the past 14 years, CREATE has developed training and support programmes for over 200 organisations across the public and private sectors, from village schools to multi-national corporations. http://www.r-p-a.org.uk/home.fcm - The Renewable Power Association (RPA) is a trade association whose membership spans the range of renewable technologies and resources and also includes service providers such as equipment manufacturers. http://www.bwea.com - The British Wind Energy Association provides information and acts on behalf of the UK wind industry. http://www.school4energy.net - The European Sustainable Energy Education Forum (ESEEF) helps teachers and students around Europe that are working with sustainable energy. ESEEF is a network of organisations and institutions working with sustainable energy and education at the primary and secondary school level. This website provides information about examples, places to visit, and links to information websites and relevant organisations.

s:\common\hannah\energy\entec planning considerations report (july 2005).doc

July 2005

You might also like