Policy ENV7 - Small Scale Renewable Engergy Projects

The Council's support for renewable energy is welcome.

Representations relate to policies ENV6, 7 and 8

Unsound: (i) not consistent with national policy (ii) not justified: not found on a robust evidence base, and (iii) not effective; not deliverable/flexible.

The requirements of these policies are generally, in principle, reasonable.

However we have several points of concern/issues.

1. Regarding the statement in paragraph 8.32 that "the use of biomass heating will not be supported...." A policy (or in this case a supporting statement to the policy) should not be prescriptive with regard to technologies. Technology and product innovation is advancing so quickly that this reference is not applicable with the majority of products on the market.

Furthermore, Building Regulations Parts F and L recently consulted on, and Part J now subject to consultation do not discriminate against such systems. According, flexibility in approaches should be upheld and specific quality metrics applied through Building Regulations and the CSH, and not planning policy. This will ensure that the most sustainable technologies are employed, by way of example 'Pyrolosis' would not be allowed, with the Core Strategy in its current form. There are no detrimental affects with regard to air quality when running such plant. Indeed, this plant runs on municipal waste, rubber tyres etc and biofuels.

Changes necessary to make the Core Strategy sound

The statement that "the use of biomass heating will not be supported...." should be deleted from paragraph 8.32. This section should accord with the flexible principles outlined in PPS1 and its supplement.

2. Given the current consultation of the Definition of Zero Carbon Homes, it is particularly difficult to comment on the proposals outlined. Indeed, CSH must also be revised to align with the regulatory definition of a zero carbon, as will the recent consultation documents for SAP, Part F and L of Building Regulations and the current Part J consultation.

We agree with principles of the Governments 'Energy Hierarchy' as far the energy efficiency measures are concerned, but we do not believe the incorporation of on-site renewable energy equipment to reduce predicted CO2 emissions by at least 10% above and beyond Building Regulations requirement, or indeed a district energy solution is most satisfactory manner to reduce emissions.

This view is substantiated by UK-GBC (in its 'Definition of Zero Carbon Report' May 2008), the First London Report 'Cutting the Capital's Carbon Footprint - Delivering Decentralised Energy' and much ongoing research. For example, we are currently working with the UK-GBC and the Zero Carbon Hub 'District Sustainable Infrastructure - Task Group' and will be reporting our findings to Ministers in late November 2009. Whilst, we cannot share the details of the draft reports, it can be stated that flexibility in the planning of developments must be maintained.

The principle of decreasing CO2 emissions by targeting reductions through energy efficiency measures is favoured by the CLG (as described in the December 2008 Zero Carbon consultation document).

Decreasing the operational carbon emissions of the site by reducing the heat demands of each dwelling has the benefit of reduced fuel bills for the occupiers. This will also improve the rating of the Energy Efficiency index on each Energy Performance Certificate (EPC), making these dwellings more appealing to potential residents, and attracting residents concerned with energy conservation.

Schemes which utilise CHP and renewable energy generated heat, such as biomass, whilst decreasing CO2 emissions by offsetting inefficient electricity production and burning 'green' fuel will actually increase the fuel bills for the residents.

Reducing the fundamental base heat demands is the only fail-safe way of keeping the heating costs down in the dwellings. This is imperative for the affordability of all dwellings, as it safeguards against fuel poverty in a volatile fuel market. Furthermore, renewable energy and CHP installations are cost intensive and they often diminish funds that could otherwise go towards fabric enhancement.

CHP and renewables, whilst technically reducing CO2 emissions, do nothing to decrease the energy demands of a dwelling, and often actually conceal a less efficient building.

Furthermore the extensive below ground heating pipework network required on most sites is more prone to heat loss and leakage. The installation of private heating pipework within adoptable roads creates issues of responsibility which are still not fully resolved within the UK.

District heating maybe more suited to high/super density developments that have a balanced load profile (a mix of uses). Although, as proven by the UK-GBC, in its 'Definition of Zero Carbon Report' May 2008, some 80% of schemes would not be deliverable. Subsequently, CLG has consulting on the 1. Energy efficiency 2. Carbon compliance and; Allowable solutions approach - to date no definitive policy has been announced.

Whilst, it is not possible to guess the outcome of the many consultations, our (and our) peer group view (shared with CLG, DBERR and DEFRA, DECC and Treasury through meetings arranged by invitation) is that the allowable solutions (depending on the cost of carbon) with the Energy efficiency measures will form future policy and regulations.

District heating systems have inherent issues of accountability. This is fuelled by occupiers perceiving little control over their heating bills and the lack of choice (e.g. lock-in) for the supply of heat. Additionally, combined heat and power only becomes financially viable if the power can be utilised on site (private wire system) as current policy dictates that exporting to the grid is not economically viable.

Private wire systems lock users into one supplier and after a recent European court (Citiworks) case, the whole legality of private wire in the UK is now uncertain - this is subject to further DECC/CLG(?) consultation later this year. The proposed individual/local heating systems and individual utility supplies give occupants the freedom of choice.

With regard to Policy ENV 8, whilst we are pleased to see that measures will not be required if "not feasible or viable", but it is not clear that this statement has had regard to the overall costs of bringing sites to the market (including the costs of any necessary supporting infrastructure) and the need to avoid any adverse impact of development on the needs of the community etc. The definition of "feasibility" needs to be a broad one, and include technological viability as well as commercial drivers.

Future developments should be designed to include (where appropriate) small scale renewable energy projects, as this will contribute to a more sustainable form of development.