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Chapter Five: Comments on Micro-Renewables
Introduction
5.1 The draft guidance indicated that micro-renewables could make a valuable contribution towards achieving a low carbon economy, tackling climate change, addressing fuel poverty and ensuring a reliable energy supply in the future. It pointed out that advice on the issues to be taken into account with regard to installation on existing buildings was set out in the Annex to PAN 45. The draft SPP indicated that the Executive was positively considering how to use permitted development rights for micro-renewables. It proposed that development plan policies should make clear that new developments must fully consider the options for micro-renewable technologies, as part of a range of energy efficiency measures, and set out a target % reduction of predicted annual CO2 emissions arising from these measures. The SPP invited comments on the suggestion that a 10% reduction would be appropriate, what it should apply to and how it should be implemented.
General Points
5.2 There were 103 responses which generally covered the matters in paragraphs 44-46 without dealing with the key consultation question (see Table 5.1 for a detailed breakdown). There was almost universal agreement that micro-renewables should be encouraged but many points of clarification were also raised and numerous modifications to the draft suggested.
5.3 Notwithstanding the reference in the SPP to the intention to publish a separate Energy Efficiency Strategy for Scotland, many respondents felt that the guidance here regarding new and existing buildings should have been framed within advice regarding the range of measures needed to reduce energy consumption and increase its more effective use in buildings as well as encouraging the development of more sustainable forms of generation. In this context there were a number of suggestions that the SPP be broadened to encourage the deployment of a combination of energy efficiency measures which would include more CHP and District Heating schemes (possibly fuelled by biomass), promote higher levels of insulation, ground source heat pumps and utilisation of solar energy, even though it was acknowledged that some of these were more the concern of the Building Regulations.
Table 5.1: General Views on Micro-renewables
Respondent Categories | Broadly Positive Views | Broadly Negative Views | Mixed Views and Queries | Total Responses |
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No. | % | No. | % | No. | % | No. | % |
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Local Authorities | 4 | 4% | 0 | 0% | 12 | 12% | 16 | 16% |
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Public Bodies | 4 | 4% | 1 | 1% | 2 | 2% | 7 | 7% |
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Businesses | 7 | 7% | 0 | 0% | 9 | 9% | 16 | 16% |
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Professional & Academic Bodies | 4 | 4% | 1 | 1% | 4 | 4% | 9 | 9% |
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Voluntary Sector | 14 | 14% | 2 | 2% | 4 | 4% | 20 | 19% |
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Public and Politicians | 28 | 27% | 3 | 3% | 4 | 4% | 35 | 34% |
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Totals | 61 | 59% | 7 | 7% | 35 | 34% | 103 | 100% |
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5.4 There were a handful of comments suggesting that it would have been useful to have provided a definition of "micro-renewable" as a development generating less than 50 kilowatts, and to incorporate a section on small to mid-scale energy technologies.
5.5 Views were relatively evenly split, and also varied across all respondent groups, on the desirability of using permitted development rights to positively encourage micro-renewables. Those with concerns highlighted the fact that both individually and cumulatively some forms of micro-renewables (wind turbines) raise amenity issues (visual intrusion, noise, flicker etc.) They called for more research, better advice on design and siting and further consultation before implementing any change in the planning regime. Those in favour of a more favourable regime mentioned the deterrent effect of the cost and procedures associated with obtaining consents and the positive signal their removal would send out to the industry and consumers.
5.6 Most development industry respondents raised some concerns regarding the requirement to consider options for micro-renewables in new developments. In particular, the likely cost which house purchasers would have to bear was frequently cited and there were various suggestions for financial support schemes or tax breaks to be introduced as an incentive to encourage the take up of the new micro-renewable technologies. It was considered that there might be considerable public resistance to the technologies and that programmes of public education might also be required. There was a suggestion that funding for pilot projects might be a way to broaden the acceptability of new energy efficient housing schemes and also that more progress needed to be made on net metering. Another respondent thought that this element of the guidance was premature, given the inexperience of the development industry and the poor accreditation, insufficient robustness and uncertain cost-effectiveness of the technology.
5.7 Finally, there were a few notes of caution raised regarding micro-renewables. Concerns were expressed as to whether grid utilities would have the capacity to absorb a multiplicity of 'ad hoc', small scale, fluctuating, generation developments. A professional body felt that micro-renewables should only be installed where environmental and economic benefits were sufficient to outweigh the costs, while some individual responses suggested that there was a need in some circumstances to evaluate micro-renewables options against larger scale, co-ordinated approaches which might be more cost effective.
Views on the 10% Minimum Policy Standard
5.8 This section of the draft SPP attracted the greatest proportion of comments - 120 individual comments (52% of all responses). Around half of all the responses considered that the suggested level was too low and more ambitious targets (varying from 15-50%, but with 20% most frequently cited) should be set. These views were most prevalent amongst voluntary body and individual respondents but a number of energy businesses also thought higher levels were attainable. Local authorities most supported the suggested 10% level while development industry respondents had the most queries about what the proposal actually meant and how it would be measured in practice. There was a small cluster of responses which considered the 10% level to be arbitrary and sought clearer justification for its selection while others thought it should vary in relation to different types of property. See Table 5.2 for more details.
Table 5.2: Views on the 10% Minimum Policy Standard
Respondent Categories | About Right | High or Query | Too Low | Total |
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No. | % | No. | % | No. | % | No. | % |
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Local Authorities | 13 | 11% | 8 | 7% | 7 | 6% | 28 | 23% |
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Public Bodies | 1 | 1% | 3 | 3% | 2 | 2% | 6 | 5% |
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Businesses | 6 | 5% | 8 | 7% | 6 | 5% | 20 | 17% |
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Professional & Academic Bodies | 2 | 2% | 2 | 2% | 3 | 3% | 7 | 6% |
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Voluntary Sector | 1 | 1% | 9 | 8% | 9 | 8% | 19 | 16% |
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Public and Politicians | 5 | 4% | 2 | 2% | 33 | 28% | 40 | 33% |
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Totals | 28 | 23% | 32 | 27% | 60 | 50% | 120 | 100% |
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5.9 There were numerous comments to the effect that any target should be seen as a minimum requirement and many also suggested that it should be steadily increased on a year by year basis, especially if national targets were to be met. Several respondents queried whether the CO2 emission reduction was the right measure and whether energy use was a better measure, given that it could include heating and cooling as well as electricity and afforded the opportunity for a more holistic approach to the development of sustainable building design and operation.
5.10 A particular cluster of responses, many from the development industry, concerned the issue of the relationship between what the SPP was proposing and what might be required in terms of energy efficiency under the Building Regulations. There were questions as to whether the SPP requirement was in addition to this, and a number of suggestions that in any event it should be.
5.11 With respect to the developments to which the policy should apply, there were a number of positive references to the London Borough of Merton's policy which related to proposals for 10 + houses or 1000m2 of non-residential property. Others sought wider definitions - several suggested a 500m2 threshold and there was considerable support for all residential and non- residential properties. However, there were some concerns regarding the application of the target to listed buildings and property in conservation areas and consequently, the need for an element of flexibility. There was widespread support for the application of the target to both new buildings and the conversion of existing buildings.
5.12 The question of implementation was interpreted very widely by respondents and there was little consensus regarding the most appropriate way forward. There was some support for the Development Plan or Supplementary Planning Guidance to set the policy framework with implementation through Development Management and/or Building Control. Several respondents referred to the need for Section 75 agreements, especially if to achieve the policy target offsite measures needed to be brought into the equation.
5.13 Significant concerns were expressed about skill deficiencies both within the planning profession and building industry, to design, implement and assesses schemes. The need for benchmarks on the energy performance of buildings was mentioned as necessary (there were references in this context to BREEAM1; EcoHomes and the Energy Performance of Buildings Directive) and for substantial monitoring and enforcement regimes to be put in place. The need for further technical advice from SEDD via an updated PAN 45 or a document similar to PSS 22 Companion Guide which was available in England was highlighted by a number of respondents.
Key Points
5.14 There was almost universal agreement amongst respondents that micro-renewables should be very positively encouraged. Many respondents felt that the micro-renewables guidance should have been framed within advice covering measures needed to reduce energy consumption and increase its more effective use in all buildings. Views were relatively evenly split on the desirability of using permitted development rights to encourage the positive uptake of micro-renewables.
5.15 Most development industry respondents raised some concerns regarding the requirement to consider options for micro-renewables in new developments. In particular, the likely cost which house purchasers would have to bear was frequently cited and there were various suggestions for financial support schemes or tax breaks to be introduced as incentives.
5.16 Around half of all the responses considered that the suggested 10% target CO2 reduction level was too low and more ambitious targets (varying from 15-50%, but with 20% most frequently cited) should be set. There were numerous comments to the effect that any target should be seen as a minimum requirement and many also suggested that it should be steadily increased on a year by year basis.
5.17 With respect to the developments to which the policy should apply, there were a number of positive references to the London Borough of Merton's policy which related to proposals for 10+ houses or 1000m 2 of non-residential property. Others sought wider definitions - several suggested a 500m 2 threshold and there was considerable support for all residential and non- residential properties. There was little consensus on the question of implementation.
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