Consultation on PPS: Planning for a Low Carbon Future in a Changing Climate

• The strength of the wording is notable. For example:
  
  • “Planning should shape places so as to help secure radical cuts in greenhouse gas emissions.”
  • “Planning for more renewable and low carbon energy development should be at the heart of good planning: it is neither optional nor additional.”
  • “In determining planning applications for major development, local planning authorities should give great weight to compliance with the criteria” for designing a low carbon future."
  • The draft suggests occasions where planning permission can be refused if it is not up to standard.
     
• The draft emphasises the role of planning in delivering stand-alone energy schemes and “opportunities at a scale which developers would not be able to realise on their own in relation to specific developments” (LCF7.1). Building regulations are expected to deliver development integrated renewable and low carbon energy, except where specific opportunities present themselves.

• Much of the real value of the draft PPS lies in its clear support for identifying energy opportunities through the evidence base. Rather than necessarily being highly technical, an evidence base should focus on spatially identifying supply and demand opportunities and using them to inform policy-making. The energy opportunities mapping exercises undertaken by a growing number of authorities demonstrate how this can be achieved (For example, AGMA, Eastbourne, Enfield, Bassetlaw, Cannock Chase, Cornwall, North Hampshire, Hertfordshire, South Gloucestershire, Cornwall, Coventry amongst others). These studies can be undertaken jointly with the region, since following the Renewable and Low-carbon Energy Capacity Methodology (DECC (January 2010) Renewable and Low-carbon Energy Capacity Methodology. Methodology for the English Regions) will also provide much of the evidence needed to support Core Strategy policies. This could provide a valuable resource for local authorities and enable them to focus resources on more detailed studies if required. A number of regions are going some way towards this already, including Yorkshire and Humber and the South West, but clearly the future of this approach will be determined by the future of the regional tier.

• Importantly, the draft emphasises the role of supply and demand opportunities studies (including heat mapping) beyond planning. Paragraph 11 says it “is also vital for delivering on a range of wider local priorities, such as fuel poverty, local energy security, waste management and targets for renewable capacity.” In other words, the capacity study becomes a resource for local authorities and their partners as well as planning.

• Adaptation to climate change has a more prominent place than the existing PPS1 Supplement and, as with energy, implies that a spatial mapping approach should be taken.

• There is no reference as to whether or not planning can be used to support the retrofit of existing homes (so called ‘consequential improvements’). While this should be a building regulations issues, as it is for non-domestic buildings, it has been dropped from recent changes. Many planning authorities are keen to explore how planning can play a role and would value clarification here.

Further exploration finds the Government's line in their response to the CLG committee: "We have some reservations about whether it is entirely appropriate to use a planning application to extend a family home to compel improvements in the energy efficiency of the existing fabric. We would want to be sure that this type of regulation, even with its laudable intentions, could not have unintended and adverse consequences." [www.official-documents.gov.uk/document/cm74/7428/7428.pdf]

• Climate change is placed on an equal footing to housing and economic development in the regional strategy. It plays an important role in setting renewable energy targets, based on the DECC methodology.
• Locally, the level of ambition in LDFs will need to be commensurate with that at regional level and in paragraph 16 local authorities are encouraged to set “stretching local targets to develop renewable energy sources in their area.” Interestingly, this is not reflected in policies LCF1 and 4.
• In setting targets the PPS expects that minimum megawatt generation targets will be set at regional level using the DECC methodology for 2015, 2020 and 2030.
• The role of targets in new development is significantly reduced, relying instead on the building regulations. The situation is very different from 2007: we now have more clarity around the zero carbon trajectory and the feed-in-tariff and forthcoming renewable heat incentive should drive microgeneration such that planning no longer needs to play anything more than a supporting role. Specifically:
  
  •  It spells out how targets should be expressed in LDDs ‘if’ they are used, rather than the implication in the current PPS1 Supplement that they ‘should’ be used.
  • Increasingly demanding building regulations means that area-wide decentralised energy targets will not be necessary after 2013, though they are supported prior to this.
  • Site specific targets can still be used, including Code/BREEAM targets and, where justified, these sustainable design targets can be applied to whole areas.
  •  The emphasis is very much on using policy to support developers in meeting regulatory requirements, e.g. creation of or connection to district heating.

• Alongside identifying locations, through the mapping exercise, where renewable and low carbon energy will be suitable (broad areas for ‘substantial development’ in the regional strategy and through local supply and demand opportunities studies), energy will also be an important factor in the LDF site allocation process. Non energy development in these areas should not prejudice renewable energy development.
   
• Broadly speaking, the local planning approach builds on that in the current PPS, including:
  
  • A positive approach to protecting landscape and townscape.
  • Setting out how district heating opportunities will be supported, including by requiring new development to connect.
  • Support for community-led renewable and low carbon energy developments.
  • Allocating strategic sites that have a central part to play in delivering local decentralised energy.
     
• Local policies will need to be consistent with the building regulation’s allowable solutions part of the zero carbon homes and buildings policy. Policy has yet to be finalised but will have significant implications for planning since LDF will need to identify potential allowable solutions.

• Viability remains a key issue, particularly the relationship between energy and housing delivery. Further clarification will hopefully be included in the forthcoming practice guide (Planning Advisory Service is leading its preparation) since it is proving a tricky issue for many planners. A shift away from development integrated energy targets should, however, help to reduce the need for detailed viability studies.

• The series of development management policies are designed to provide strong support for renewable and low carbon energy. They enable planners to turn down applications that are not consistent with the local energy approach and equally leave planning authorities needing good reason to refuse a renewable or low carbon application.

• Green belt development management policy makes it clear that many renewable energy projects will be inappropriate and that developers will need to demonstrate “very special circumstances” if they are to proceed. These circumstances, however, include wider environmental benefits associated with renewable energy and suggests that green belt is viewed as a very useful opportunity. The practice guide will need to provide clear guidance for policy and decision-makers and applicants.

• As more wind schemes are developed, cumulative impact becomes much more of an issue. Cumulative impact is not included in the list of matters to be taken into consideration when determining planning applications in Policy LCF14, whereas it is specifically mentioned in PPS22 (paragraph 21). In view of the possibility that wind-farms become quite common in non-designated parts of the county, it might be helpful to have clarity on whether they should be spread evenly or clustered.