Sustainable energy scale - building / development integrated renewable and low carbon energy
On-site renewable and low carbon energy generation polices have, in England, become known as the ‘Merton Rule’ after the London borough that pioneered them. However, the proposed changes to Building Regulations will significantly raise the bar on CO2 reductions and so reduce the role that planning has in terms of building or development integrated generation.
Despite that, you should support developers in meeting their regulatory obligations by using viability assessments to test whether or not there is any opportunity to set performance standards ahead of building regulations. So, your planning policy should focus on:
- Area-wide decentralised renewable and low carbon policies and targets. Your evidence base should enable targets to be tested for their impact on the viability of a development. You also need to consider how easy it will be for your development management colleagues to check – and developers demonstrate – compliance with policy and targets requiring reductions in CO2 emissions specifically from decentralised renewable or low carbon sources – this has been a major problem with Merton style on-site renewable energy policies. Don’t forget though, that Building Regulations Part L already require developers to show CO2 performance of buildings, so compliance with these policies and targets could be demonstrated with a building control certificate that includes the Target Emission Rate and Dwelling Emission Rate. See SE 1. Develop area wide min LZC target for new dev and SE 4. Develop area wide renewable energy targets for more details.
- Strategic sites for decentralised renewable and low carbon policies and targets. Your considerations here should be largely the same as for area-wide approaches, but focusing on strategic sites will allow you to capture site-specific opportunities. For example, a development site may be sufficiently large to make certain technologies viable on their own. Similarly, some sites may be close to a district heating network into which they can connect. Both of these might be missed if you only consider area-wide solutions. See SE 2. Develop energy carbon policies & targets for strategic sites for more details.
- Sustainable building standards. You could develop policy which sets targets, subject to tests of viability, to achieve a certain level of performance under sustainable building standards, such as the Code for Sustainable Homes and BREEAM. You could also require certain performance for specific elements of such standard and this is a particularly useful approach for focusing on issues not covered as part of the building regulations, such as ecology or adaptation to climate change. SE 5. Sustainable Building Standards
- Improvements to existing building stock. You might consider requiring planning applications for changes to existing domestic dwellings to undertake reasonable improvements to the energy performance of the dwelling. To be affective, you would need to ensure that improvements were additional to the requirements under Part L of the building regulations for the changes for which planning permission is sought. Improvements could include loft and cavity wall insulation, draught-proofing, improved heating controls and replacement boilers.
- Enabling future improvement. You could use Supplementary Planning Documents to set design and layout requirements which maximise the energy performance of new development and to enable later retrofit of energy measures.
You could develop a range of further policies to ensure enforcement as well as developing a carbon buyout fund which gives you flexibility to take advantage of a range of opportunities. See Community integrated energy and infrastructure.
