Core Strategy Preferred Options (Revised October 2008)

RE: Rochford District council - Core Strategy preferred Options consultation

BWEA welcomes the opportunity to provide comments on the Council's core Strategy Preferred Options document and provides this submission on behalf of the UK wind energy industry.

BWEA was established in 1978 and is the representative body for companies active in the UK wind, wave and tidal energy market. Its membership has grown rapidly over recent years and now stands at over 450 companies.

The UK has a rich variety of renewable energy resource, including 40% Europe's wind resource. This resource will need to be utilized if the UK is to deliver its share of Europe's 20% renewable energy target by 2020. Given the UK's low base-line levels of renewable heat, the majority of this target will need to be met through onshore wind. It is therefore important to support and encourage the growth of the sector if the UK is to meet its national and European renewable energy and carbon reduction targets.

In representing the wind industry, BWEA is in a unique position to comment on the circumstances which affect the future growth and development of the sector. BWEA would be pleased to clarify any issues raised and offer any further information which may be required.

Thank you for the opportunity to submit comments on the Preferred Options Document. If you have any queries please do not hesitate to contact me.

BWEA welcomes the preparation of the council's Local development Framework (LDF) and wishes to emphasise the important contribution that the Council's policies can make in contributing to both the national and regional targets for renewable energy generation. BWEA strongly recommend that the Council introduce specific policies designed to deliver greater production of renewable energy and increased levels of energy efficiency, in order to minimise the impacts of climate change and achieve the Council's 'Priority 9: A smaller carbon footprint with less waste'.

Policy ENV6 Large Scale Renewable energy Projects - Preferred Option

BWEA objects to this policy on the grounds that it fails to comply with PPS22. Policy ENV6 fails to actively encourage both large and small-scale renewable energy development. Policy ENV6 also conflicts with PPS2 in its treatment of international, national, regional and local area designations. As stated in more detail below, no area designation should result in an automatic block on development. The levels of legal protection accorded to international and national designations, for example, are not the same as those accorded to regional or local designations, and, as such, these areas should not be regarded of equal value.

Please see further guidance regarding PPS22 and renewable energy policy and the local level, below.

ENV7 Small Scale Renewable Energy Projects - Preferred Option

In the absence of an additional, specific policy on Sustainable Design and Construction, BWEA objects to this policy on the grounds that it does not go far enough to enabling the delivery of Government objectives for all new homes to be developed to zero-carbon standards by 2016, and for all new commercial buildings to be built to zero-carbon standards by 2019.

By simply seeking to 'favourably consider small-scale renewable energy projects in both new an existing development', BWEA believe that this policy fails to comply with the Government's PPS1 on Climate change. Please see further guidance regarding PPS1, renewable energy policy and Low and Zero Carbon Developments, below.

Renewable Energy Policy

The LDF should include a robust criteria based policy that will be used to assess all applications for renewable energy developments. It is important that the Plan presents a positive, objective and robust approach to renewable energy for the wider and local benefit. As such, BWEA recommend that the Council include specific development control policy on renewable energy, focusing on the key criteria that will be used to judge applications, and providing direct reference to PPS22. More detailed issues may be appropriate to supplementary planning documents, and guidance on these issues can be found in the Companion Guide to PPS22.

Planning Policy Statement 22 states that local development documents should contain policies designed to promote and encourage, rather than restrict, the development of renewable energy resources. BWEA therefore recommend that policies designed to safeguard the character and setting of listed buildings, conservation areas and greenbelt, for example, have regard to the positive contribution that renewable energy can play in reducing the Council's overall cO2 emissions and in mitigating against the environmentally damaging effects of climate change.

Landscape and nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. Planning applications for renewable energy developments in such areas should be assessed against criteria based policies set out in local development documents, including any criteria that are specific to the type of area concerned. Local authorities should ensure that any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances.

Planning authorities should not make assumptions about the technical and commercial feasibility of renewable energy projects (e.g. identifying generalised locations for development based on mean wind speeds). Technological change can mean that sites currently excluded as locations for particular types of renewable energy development may in future be suitable. Similarly, local planning authorities should not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location.

All information requested of applicants should be proportionate to the scale of the proposed development, its likely impact on and vulnerability to climate change, and be consistent with that needed to demonstrate conformity with the development plan and the Climate Change Supplement to PPS1. Specific and standalone assessments of new development should not be required where the requisite information can be made available to the planning authority through other submitted documents - for example, as part of a Design and Access Statement, or Environmental Impact Assessment.

An applicant for planning permission to develop a proposal that will contribute to the delivery of the Key Planning Objectives set out in the Climate Change Supplement to PPS1 should expect expeditious and sympathetic handling of the planning application.

Practical guidance and support for the implementation of the policies in the Climate Change Supplement to PPS1 can be found in its companion guide.

Low and Zero Carbon Developments

The planning system needs to support the delivery of the timetable for reducing carbon emissions from domestic and non-domestic buildings, and local planning authorities are expected to actively encourage smaller scale renewable energy schemes through positively expressed policies in local development documents, as stated in PPS22. Alongside criteria-based policy development in line with PPS22, the Climate Change Supplement to PPS1 recommends that local authorities consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure where this would help secure their development.

BWEA emphasises the contribution that small renewable systems can make, and strongly urges the Council to implement a policy for the mandatory requirement of onsite renewables, as requested by Yvette Cooper, the Minister for Housing and Planning, on the 8th of June 2006 (http://www.themertonrule.org/). Such a policy would require onsite renewables to provide electricity for at least 10% of all new buildings' needs (including refurbishments), in addition to stringent energy efficiency/building performance requirements. Recent research by the Department for Communities and Local Government found that around a third of Local Authorities surveyed are introducing such policies within Development Plans (http://www.communities.gov.uk/index.asp?id=1500549). Following this research the Government has urged all Council's to include such policies in their Local Plans (http://www.communities.gov.uk/index.asp?id=1002882&PressNoticeID=2167).

The following wording is highlighted as an example:

'All non-residential or mixed use developments (new build, conversion, or renovation) above a threshold of 1,000m2 will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.

All residential developments (new build, conversion, or renovation) of 10 or more units will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.'

While building regulations will be strengthened over the next decade, BWEA recommend the inclusion of a discrete policy on sustainable design and construction methods, and the introduction of minimum efficiency standards for extensions, change of use conversions, and refurbishments/listed building restorations. Such a policy would help ensure increases in energy efficiency within the existing building stock, as well as in new build development. BWEA recommend looking at the Renewable Energy Toolkit for planners, developers and consultants, developed by the London energy Partnership for further guidance (http://www.london.gov.uk/mayor/environment/energy/docs/renewables_toolkit.pdf).

In accordance with the Climate Change Supplement to PPS1, planning authorities should have an evidence-based understanding of the local feasibility and potential for renewable and low-carbon technologies, including microgeneration, to supply new development in their area. Drawing from this evidence-base, local authorities should:

1. Set out a target percentage of the energy to be used in new development to come from decentralised and renewable or low-carbon energy sources, where it is viable. The target should avoid prescription on technologies and be flexible in how carbon saving from local energy supplies are to be secured,
2. Where there are particular and demonstrable opportunities for greater use of decentralised and renewable or low-carbon energy than the target percentage, bring forward development area 22 or site-specific targets to secure this potential; and, in bringing forward targets,
3. set out the type and size of development to which the target will be applied; and
4. Ensure there is a clear rationale for the target and it is properly tested.

In addition, BWEA recommend that the development plan provide a brief outline of the different renewable energy generation technologies, and equally encourage and promote all forms of renewable energy (solar, biomass, wind, geothermal, hydro etc). The potential for an Energy Services Company and site-wide CHP should also be considered for inclusion.

Thank you for the opportunity to submit comments on these documents. BWEA looks forward to future opportunities to participate in this consultation. If you have any queries please do not hesitate to contact BWEA.

RE: Rochford District council - Core Strategy preferred Options consultation

BWEA welcomes the opportunity to provide comments on the Council's core Strategy Preferred Options document and provides this submission on behalf of the UK wind energy industry.

BWEA was established in 1978 and is the representative body for companies active in the UK wind, wave and tidal energy market. Its membership has grown rapidly over recent years and now stands at over 450 companies.

The UK has a rich variety of renewable energy resource, including 40% Europe's wind resource. This resource will need to be utilized if the UK is to deliver its share of Europe's 20% renewable energy target by 2020. Given the UK's low base-line levels of renewable heat, the majority of this target will need to be met through onshore wind. It is therefore important to support and encourage the growth of the sector if the UK is to meet its national and European renewable energy and carbon reduction targets.

In representing the wind industry, BWEA is in a unique position to comment on the circumstances which affect the future growth and development of the sector. BWEA would be pleased to clarify any issues raised and offer any further information which may be required.

Thank you for the opportunity to submit comments on the Preferred Options Document. If you have any queries please do not hesitate to contact me.

BWEA welcomes the preparation of the council's Local development Framework (LDF) and wishes to emphasise the important contribution that the Council's policies can make in contributing to both the national and regional targets for renewable energy generation. BWEA strongly recommend that the Council introduce specific policies designed to deliver greater production of renewable energy and increased levels of energy efficiency, in order to minimise the impacts of climate change and achieve the Council's 'Priority 9: A smaller carbon footprint with less waste'.

Policy ENV6 Large Scale Renewable energy Projects - Preferred Option

BWEA objects to this policy on the grounds that it fails to comply with PPS22. Policy ENV6 fails to actively encourage both large and small-scale renewable energy development. Policy ENV6 also conflicts with PPS2 in its treatment of international, national, regional and local area designations. As stated in more detail below, no area designation should result in an automatic block on development. The levels of legal protection accorded to international and national designations, for example, are not the same as those accorded to regional or local designations, and, as such, these areas should not be regarded of equal value.

Please see further guidance regarding PPS22 and renewable energy policy and the local level, below.

ENV7 Small Scale Renewable Energy Projects - Preferred Option

In the absence of an additional, specific policy on Sustainable Design and Construction, BWEA objects to this policy on the grounds that it does not go far enough to enabling the delivery of Government objectives for all new homes to be developed to zero-carbon standards by 2016, and for all new commercial buildings to be built to zero-carbon standards by 2019.

By simply seeking to 'favourably consider small-scale renewable energy projects in both new an existing development', BWEA believe that this policy fails to comply with the Government's PPS1 on Climate change. Please see further guidance regarding PPS1, renewable energy policy and Low and Zero Carbon Developments, below.

Renewable Energy Policy

The LDF should include a robust criteria based policy that will be used to assess all applications for renewable energy developments. It is important that the Plan presents a positive, objective and robust approach to renewable energy for the wider and local benefit. As such, BWEA recommend that the Council include specific development control policy on renewable energy, focusing on the key criteria that will be used to judge applications, and providing direct reference to PPS22. More detailed issues may be appropriate to supplementary planning documents, and guidance on these issues can be found in the Companion Guide to PPS22.

Planning Policy Statement 22 states that local development documents should contain policies designed to promote and encourage, rather than restrict, the development of renewable energy resources. BWEA therefore recommend that policies designed to safeguard the character and setting of listed buildings, conservation areas and greenbelt, for example, have regard to the positive contribution that renewable energy can play in reducing the Council's overall cO2 emissions and in mitigating against the environmentally damaging effects of climate change.

Landscape and nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. Planning applications for renewable energy developments in such areas should be assessed against criteria based policies set out in local development documents, including any criteria that are specific to the type of area concerned. Local authorities should ensure that any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances.

Planning authorities should not make assumptions about the technical and commercial feasibility of renewable energy projects (e.g. identifying generalised locations for development based on mean wind speeds). Technological change can mean that sites currently excluded as locations for particular types of renewable energy development may in future be suitable. Similarly, local planning authorities should not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location.

All information requested of applicants should be proportionate to the scale of the proposed development, its likely impact on and vulnerability to climate change, and be consistent with that needed to demonstrate conformity with the development plan and the Climate Change Supplement to PPS1. Specific and standalone assessments of new development should not be required where the requisite information can be made available to the planning authority through other submitted documents - for example, as part of a Design and Access Statement, or Environmental Impact Assessment.

An applicant for planning permission to develop a proposal that will contribute to the delivery of the Key Planning Objectives set out in the Climate Change Supplement to PPS1 should expect expeditious and sympathetic handling of the planning application.

Practical guidance and support for the implementation of the policies in the Climate Change Supplement to PPS1 can be found in its companion guide.

Low and Zero Carbon Developments

The planning system needs to support the delivery of the timetable for reducing carbon emissions from domestic and non-domestic buildings, and local planning authorities are expected to actively encourage smaller scale renewable energy schemes through positively expressed policies in local development documents, as stated in PPS22. Alongside criteria-based policy development in line with PPS22, the Climate Change Supplement to PPS1 recommends that local authorities consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure where this would help secure their development.

BWEA emphasises the contribution that small renewable systems can make, and strongly urges the Council to implement a policy for the mandatory requirement of onsite renewables, as requested by Yvette Cooper, the Minister for Housing and Planning, on the 8th of June 2006 (http://www.themertonrule.org/). Such a policy would require onsite renewables to provide electricity for at least 10% of all new buildings' needs (including refurbishments), in addition to stringent energy efficiency/building performance requirements. Recent research by the Department for Communities and Local Government found that around a third of Local Authorities surveyed are introducing such policies within Development Plans (http://www.communities.gov.uk/index.asp?id=1500549). Following this research the Government has urged all Council's to include such policies in their Local Plans (http://www.communities.gov.uk/index.asp?id=1002882&PressNoticeID=2167).

The following wording is highlighted as an example:

'All non-residential or mixed use developments (new build, conversion, or renovation) above a threshold of 1,000m2 will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.

All residential developments (new build, conversion, or renovation) of 10 or more units will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.'

While building regulations will be strengthened over the next decade, BWEA recommend the inclusion of a discrete policy on sustainable design and construction methods, and the introduction of minimum efficiency standards for extensions, change of use conversions, and refurbishments/listed building restorations. Such a policy would help ensure increases in energy efficiency within the existing building stock, as well as in new build development. BWEA recommend looking at the Renewable Energy Toolkit for planners, developers and consultants, developed by the London energy Partnership for further guidance (http://www.london.gov.uk/mayor/environment/energy/docs/renewables_toolkit.pdf).

In accordance with the Climate Change Supplement to PPS1, planning authorities should have an evidence-based understanding of the local feasibility and potential for renewable and low-carbon technologies, including microgeneration, to supply new development in their area. Drawing from this evidence-base, local authorities should:

1. Set out a target percentage of the energy to be used in new development to come from decentralised and renewable or low-carbon energy sources, where it is viable. The target should avoid prescription on technologies and be flexible in how carbon saving from local energy supplies are to be secured,
2. Where there are particular and demonstrable opportunities for greater use of decentralised and renewable or low-carbon energy than the target percentage, bring forward development area 22 or site-specific targets to secure this potential; and, in bringing forward targets,
3. set out the type and size of development to which the target will be applied; and
4. Ensure there is a clear rationale for the target and it is properly tested.

In addition, BWEA recommend that the development plan provide a brief outline of the different renewable energy generation technologies, and equally encourage and promote all forms of renewable energy (solar, biomass, wind, geothermal, hydro etc). The potential for an Energy Services Company and site-wide CHP should also be considered for inclusion.

Thank you for the opportunity to submit comments on these documents. BWEA looks forward to future opportunities to participate in this consultation. If you have any queries please do not hesitate to contact BWEA.

RE: Rochford District council - Core Strategy preferred Options consultation

BWEA welcomes the opportunity to provide comments on the Council's core Strategy Preferred Options document and provides this submission on behalf of the UK wind energy industry.

BWEA was established in 1978 and is the representative body for companies active in the UK wind, wave and tidal energy market. Its membership has grown rapidly over recent years and now stands at over 450 companies.

The UK has a rich variety of renewable energy resource, including 40% Europe's wind resource. This resource will need to be utilized if the UK is to deliver its share of Europe's 20% renewable energy target by 2020. Given the UK's low base-line levels of renewable heat, the majority of this target will need to be met through onshore wind. It is therefore important to support and encourage the growth of the sector if the UK is to meet its national and European renewable energy and carbon reduction targets.

In representing the wind industry, BWEA is in a unique position to comment on the circumstances which affect the future growth and development of the sector. BWEA would be pleased to clarify any issues raised and offer any further information which may be required.

Thank you for the opportunity to submit comments on the Preferred Options Document. If you have any queries please do not hesitate to contact me.

BWEA welcomes the preparation of the council's Local development Framework (LDF) and wishes to emphasise the important contribution that the Council's policies can make in contributing to both the national and regional targets for renewable energy generation. BWEA strongly recommend that the Council introduce specific policies designed to deliver greater production of renewable energy and increased levels of energy efficiency, in order to minimise the impacts of climate change and achieve the Council's 'Priority 9: A smaller carbon footprint with less waste'.

Policy ENV6 Large Scale Renewable energy Projects - Preferred Option

BWEA objects to this policy on the grounds that it fails to comply with PPS22. Policy ENV6 fails to actively encourage both large and small-scale renewable energy development. Policy ENV6 also conflicts with PPS2 in its treatment of international, national, regional and local area designations. As stated in more detail below, no area designation should result in an automatic block on development. The levels of legal protection accorded to international and national designations, for example, are not the same as those accorded to regional or local designations, and, as such, these areas should not be regarded of equal value.

Please see further guidance regarding PPS22 and renewable energy policy and the local level, below.

ENV7 Small Scale Renewable Energy Projects - Preferred Option

In the absence of an additional, specific policy on Sustainable Design and Construction, BWEA objects to this policy on the grounds that it does not go far enough to enabling the delivery of Government objectives for all new homes to be developed to zero-carbon standards by 2016, and for all new commercial buildings to be built to zero-carbon standards by 2019.

By simply seeking to 'favourably consider small-scale renewable energy projects in both new an existing development', BWEA believe that this policy fails to comply with the Government's PPS1 on Climate change. Please see further guidance regarding PPS1, renewable energy policy and Low and Zero Carbon Developments, below.

Renewable Energy Policy

The LDF should include a robust criteria based policy that will be used to assess all applications for renewable energy developments. It is important that the Plan presents a positive, objective and robust approach to renewable energy for the wider and local benefit. As such, BWEA recommend that the Council include specific development control policy on renewable energy, focusing on the key criteria that will be used to judge applications, and providing direct reference to PPS22. More detailed issues may be appropriate to supplementary planning documents, and guidance on these issues can be found in the Companion Guide to PPS22.

Planning Policy Statement 22 states that local development documents should contain policies designed to promote and encourage, rather than restrict, the development of renewable energy resources. BWEA therefore recommend that policies designed to safeguard the character and setting of listed buildings, conservation areas and greenbelt, for example, have regard to the positive contribution that renewable energy can play in reducing the Council's overall cO2 emissions and in mitigating against the environmentally damaging effects of climate change.

Landscape and nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. Planning applications for renewable energy developments in such areas should be assessed against criteria based policies set out in local development documents, including any criteria that are specific to the type of area concerned. Local authorities should ensure that any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances.

Planning authorities should not make assumptions about the technical and commercial feasibility of renewable energy projects (e.g. identifying generalised locations for development based on mean wind speeds). Technological change can mean that sites currently excluded as locations for particular types of renewable energy development may in future be suitable. Similarly, local planning authorities should not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location.

All information requested of applicants should be proportionate to the scale of the proposed development, its likely impact on and vulnerability to climate change, and be consistent with that needed to demonstrate conformity with the development plan and the Climate Change Supplement to PPS1. Specific and standalone assessments of new development should not be required where the requisite information can be made available to the planning authority through other submitted documents - for example, as part of a Design and Access Statement, or Environmental Impact Assessment.

An applicant for planning permission to develop a proposal that will contribute to the delivery of the Key Planning Objectives set out in the Climate Change Supplement to PPS1 should expect expeditious and sympathetic handling of the planning application.

Practical guidance and support for the implementation of the policies in the Climate Change Supplement to PPS1 can be found in its companion guide.

Low and Zero Carbon Developments

The planning system needs to support the delivery of the timetable for reducing carbon emissions from domestic and non-domestic buildings, and local planning authorities are expected to actively encourage smaller scale renewable energy schemes through positively expressed policies in local development documents, as stated in PPS22. Alongside criteria-based policy development in line with PPS22, the Climate Change Supplement to PPS1 recommends that local authorities consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure where this would help secure their development.

BWEA emphasises the contribution that small renewable systems can make, and strongly urges the Council to implement a policy for the mandatory requirement of onsite renewables, as requested by Yvette Cooper, the Minister for Housing and Planning, on the 8th of June 2006 (http://www.themertonrule.org/). Such a policy would require onsite renewables to provide electricity for at least 10% of all new buildings' needs (including refurbishments), in addition to stringent energy efficiency/building performance requirements. Recent research by the Department for Communities and Local Government found that around a third of Local Authorities surveyed are introducing such policies within Development Plans (http://www.communities.gov.uk/index.asp?id=1500549). Following this research the Government has urged all Council's to include such policies in their Local Plans (http://www.communities.gov.uk/index.asp?id=1002882&PressNoticeID=2167).

The following wording is highlighted as an example:

'All non-residential or mixed use developments (new build, conversion, or renovation) above a threshold of 1,000m2 will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.

All residential developments (new build, conversion, or renovation) of 10 or more units will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.'

While building regulations will be strengthened over the next decade, BWEA recommend the inclusion of a discrete policy on sustainable design and construction methods, and the introduction of minimum efficiency standards for extensions, change of use conversions, and refurbishments/listed building restorations. Such a policy would help ensure increases in energy efficiency within the existing building stock, as well as in new build development. BWEA recommend looking at the Renewable Energy Toolkit for planners, developers and consultants, developed by the London energy Partnership for further guidance (http://www.london.gov.uk/mayor/environment/energy/docs/renewables_toolkit.pdf).

In accordance with the Climate Change Supplement to PPS1, planning authorities should have an evidence-based understanding of the local feasibility and potential for renewable and low-carbon technologies, including microgeneration, to supply new development in their area. Drawing from this evidence-base, local authorities should:

1. Set out a target percentage of the energy to be used in new development to come from decentralised and renewable or low-carbon energy sources, where it is viable. The target should avoid prescription on technologies and be flexible in how carbon saving from local energy supplies are to be secured,
2. Where there are particular and demonstrable opportunities for greater use of decentralised and renewable or low-carbon energy than the target percentage, bring forward development area 22 or site-specific targets to secure this potential; and, in bringing forward targets,
3. set out the type and size of development to which the target will be applied; and
4. Ensure there is a clear rationale for the target and it is properly tested.

In addition, BWEA recommend that the development plan provide a brief outline of the different renewable energy generation technologies, and equally encourage and promote all forms of renewable energy (solar, biomass, wind, geothermal, hydro etc). The potential for an Energy Services Company and site-wide CHP should also be considered for inclusion.

Thank you for the opportunity to submit comments on these documents. BWEA looks forward to future opportunities to participate in this consultation. If you have any queries please do not hesitate to contact BWEA.

RE: Rochford District council - Core Strategy preferred Options consultation

BWEA welcomes the opportunity to provide comments on the Council's core Strategy Preferred Options document and provides this submission on behalf of the UK wind energy industry.

BWEA was established in 1978 and is the representative body for companies active in the UK wind, wave and tidal energy market. Its membership has grown rapidly over recent years and now stands at over 450 companies.

The UK has a rich variety of renewable energy resource, including 40% Europe's wind resource. This resource will need to be utilized if the UK is to deliver its share of Europe's 20% renewable energy target by 2020. Given the UK's low base-line levels of renewable heat, the majority of this target will need to be met through onshore wind. It is therefore important to support and encourage the growth of the sector if the UK is to meet its national and European renewable energy and carbon reduction targets.

In representing the wind industry, BWEA is in a unique position to comment on the circumstances which affect the future growth and development of the sector. BWEA would be pleased to clarify any issues raised and offer any further information which may be required.

Thank you for the opportunity to submit comments on the Preferred Options Document. If you have any queries please do not hesitate to contact me.

BWEA welcomes the preparation of the council's Local development Framework (LDF) and wishes to emphasise the important contribution that the Council's policies can make in contributing to both the national and regional targets for renewable energy generation. BWEA strongly recommend that the Council introduce specific policies designed to deliver greater production of renewable energy and increased levels of energy efficiency, in order to minimise the impacts of climate change and achieve the Council's 'Priority 9: A smaller carbon footprint with less waste'.

Policy ENV6 Large Scale Renewable energy Projects - Preferred Option

BWEA objects to this policy on the grounds that it fails to comply with PPS22. Policy ENV6 fails to actively encourage both large and small-scale renewable energy development. Policy ENV6 also conflicts with PPS2 in its treatment of international, national, regional and local area designations. As stated in more detail below, no area designation should result in an automatic block on development. The levels of legal protection accorded to international and national designations, for example, are not the same as those accorded to regional or local designations, and, as such, these areas should not be regarded of equal value.

Please see further guidance regarding PPS22 and renewable energy policy and the local level, below.

ENV7 Small Scale Renewable Energy Projects - Preferred Option

In the absence of an additional, specific policy on Sustainable Design and Construction, BWEA objects to this policy on the grounds that it does not go far enough to enabling the delivery of Government objectives for all new homes to be developed to zero-carbon standards by 2016, and for all new commercial buildings to be built to zero-carbon standards by 2019.

By simply seeking to 'favourably consider small-scale renewable energy projects in both new an existing development', BWEA believe that this policy fails to comply with the Government's PPS1 on Climate change. Please see further guidance regarding PPS1, renewable energy policy and Low and Zero Carbon Developments, below.

Renewable Energy Policy

The LDF should include a robust criteria based policy that will be used to assess all applications for renewable energy developments. It is important that the Plan presents a positive, objective and robust approach to renewable energy for the wider and local benefit. As such, BWEA recommend that the Council include specific development control policy on renewable energy, focusing on the key criteria that will be used to judge applications, and providing direct reference to PPS22. More detailed issues may be appropriate to supplementary planning documents, and guidance on these issues can be found in the Companion Guide to PPS22.

Planning Policy Statement 22 states that local development documents should contain policies designed to promote and encourage, rather than restrict, the development of renewable energy resources. BWEA therefore recommend that policies designed to safeguard the character and setting of listed buildings, conservation areas and greenbelt, for example, have regard to the positive contribution that renewable energy can play in reducing the Council's overall cO2 emissions and in mitigating against the environmentally damaging effects of climate change.

Landscape and nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. Planning applications for renewable energy developments in such areas should be assessed against criteria based policies set out in local development documents, including any criteria that are specific to the type of area concerned. Local authorities should ensure that any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances.

Planning authorities should not make assumptions about the technical and commercial feasibility of renewable energy projects (e.g. identifying generalised locations for development based on mean wind speeds). Technological change can mean that sites currently excluded as locations for particular types of renewable energy development may in future be suitable. Similarly, local planning authorities should not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location.

All information requested of applicants should be proportionate to the scale of the proposed development, its likely impact on and vulnerability to climate change, and be consistent with that needed to demonstrate conformity with the development plan and the Climate Change Supplement to PPS1. Specific and standalone assessments of new development should not be required where the requisite information can be made available to the planning authority through other submitted documents - for example, as part of a Design and Access Statement, or Environmental Impact Assessment.

An applicant for planning permission to develop a proposal that will contribute to the delivery of the Key Planning Objectives set out in the Climate Change Supplement to PPS1 should expect expeditious and sympathetic handling of the planning application.

Practical guidance and support for the implementation of the policies in the Climate Change Supplement to PPS1 can be found in its companion guide.

Low and Zero Carbon Developments

The planning system needs to support the delivery of the timetable for reducing carbon emissions from domestic and non-domestic buildings, and local planning authorities are expected to actively encourage smaller scale renewable energy schemes through positively expressed policies in local development documents, as stated in PPS22. Alongside criteria-based policy development in line with PPS22, the Climate Change Supplement to PPS1 recommends that local authorities consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure where this would help secure their development.

BWEA emphasises the contribution that small renewable systems can make, and strongly urges the Council to implement a policy for the mandatory requirement of onsite renewables, as requested by Yvette Cooper, the Minister for Housing and Planning, on the 8th of June 2006 (http://www.themertonrule.org/). Such a policy would require onsite renewables to provide electricity for at least 10% of all new buildings' needs (including refurbishments), in addition to stringent energy efficiency/building performance requirements. Recent research by the Department for Communities and Local Government found that around a third of Local Authorities surveyed are introducing such policies within Development Plans (http://www.communities.gov.uk/index.asp?id=1500549). Following this research the Government has urged all Council's to include such policies in their Local Plans (http://www.communities.gov.uk/index.asp?id=1002882&PressNoticeID=2167).

The following wording is highlighted as an example:

'All non-residential or mixed use developments (new build, conversion, or renovation) above a threshold of 1,000m2 will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.

All residential developments (new build, conversion, or renovation) of 10 or more units will be expected to provide at least 10% of their energy requirements from onsite renewable energy generation.'

While building regulations will be strengthened over the next decade, BWEA recommend the inclusion of a discrete policy on sustainable design and construction methods, and the introduction of minimum efficiency standards for extensions, change of use conversions, and refurbishments/listed building restorations. Such a policy would help ensure increases in energy efficiency within the existing building stock, as well as in new build development. BWEA recommend looking at the Renewable Energy Toolkit for planners, developers and consultants, developed by the London energy Partnership for further guidance (http://www.london.gov.uk/mayor/environment/energy/docs/renewables_toolkit.pdf).

In accordance with the Climate Change Supplement to PPS1, planning authorities should have an evidence-based understanding of the local feasibility and potential for renewable and low-carbon technologies, including microgeneration, to supply new development in their area. Drawing from this evidence-base, local authorities should:

1. Set out a target percentage of the energy to be used in new development to come from decentralised and renewable or low-carbon energy sources, where it is viable. The target should avoid prescription on technologies and be flexible in how carbon saving from local energy supplies are to be secured,
2. Where there are particular and demonstrable opportunities for greater use of decentralised and renewable or low-carbon energy than the target percentage, bring forward development area 22 or site-specific targets to secure this potential; and, in bringing forward targets,
3. set out the type and size of development to which the target will be applied; and
4. Ensure there is a clear rationale for the target and it is properly tested.

In addition, BWEA recommend that the development plan provide a brief outline of the different renewable energy generation technologies, and equally encourage and promote all forms of renewable energy (solar, biomass, wind, geothermal, hydro etc). The potential for an Energy Services Company and site-wide CHP should also be considered for inclusion.

Thank you for the opportunity to submit comments on these documents. BWEA looks forward to future opportunities to participate in this consultation. If you have any queries please do not hesitate to contact BWEA.