Arup Guidance Note on GLA Requirements for Renewables

Gives the following guidance for determining planning applications: ‘Local planning authorities should expect new development to:

• comply with adopted Local Plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable; and
• take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption’.

Finally, paragraph 97 states: ‘To help increase the use and supply of renewable and low carbon energy, local planning authorities should recognise the responsibility of all communities to contribute to energy generation from renewable or low carbon sources. They should: …identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers’.

In London, the Greater London Authority – Mayor of London Sustainable Design and Construction Supplementary Planning Guidance (2014) and London Plan (italics = best practice) states that the overall carbon dioxide emissions from a development should be minimised through the implementation of the energy hierarchy lean > clean > green set out in London Plan policy 5.2. and that Developments should be designed to meet the following Regulated carbon dioxide standards, in line with London Plan policy 5.2.

This policy also states that ‘To avoid complexity and extra costs for developers, the Mayor will adopt a flat carbon dioxide improvement target beyond Part L 2013 of 35% to both residential and non-residential development’ and that:

‘Where a planning application includes refurbishment or retrofitting works for a major development, applicants should submit energy strategies which follow the energy hierarchy and demonstrate appropriate reductions in carbon dioxide emissions. Whilst the targets in policy 5.2 apply to major developments, it is acknowledged that for many schemes involving existing buildings, it will be a challenge to meet these targets, except perhaps where a development can connect to a low or zero carbon energy source.

• Developments should contribute to ensuring resilient energy infrastructure and a reliable energy supply, including from local low and zero carbon sources.
• Developers are encouraged to include innovative low and zero carbon technologies to minimise carbon dioxide emissions within developments and keep up to date with rapidly improving technologies.
• Development applications are to be accompanied by an energy demand assessment.
• The design of developments should prioritise passive measures.
• Developers should aim to achieve Part L 2013 Building Regulations requirements through design and energy efficiency alone, as far as is practical.
• Where borough heat maps have identified district heating opportunities, boroughs should prepare more detailed Energy Master Plans (EMPs) to establish the extent of market competitive district heating networks.
• Developers should assess the potential for their development to:
  • connect to an existing district heating or cooling network;
  • expand an existing district heating or cooling network, and connect to it; or
  • establish a site wide network, and enable the connection.
• Where opportunities arise, developers generating energy or waste heat should maximise long term carbon dioxide savings by feeding the decentralised energy network with low or zero carbon hot, and where required, cold water.

• 2.5 Renewable energy
  • Boroughs and neighbourhoods should identify opportunities for the installation of renewable energy technologies in their boroughs and neighbourhoods.
  • Major developments should incorporate renewable energy technologies to minimise overall carbon dioxide emissions, where feasible.
• 2.5 Carbon Offset
  • Boroughs should establish a carbon off-set fund and identify suitable projects to be funded.
  • Where developments do not achieve the Mayor’s carbon dioxide reduction targets set out in London Plan policy 5.2, the developer should make a contribution to the local borough’s carbon dioxide off-setting fund.
• 2.5 Retrofitting
  • Boroughs should set out policies to encourage the retrofitting of carbon dioxide and water saving measures in their borough.
  • Where works to existing developments are proposed, developers should retrofit carbon dioxide and water saving measures.
• 2.5 Monitor Energy Use
  • Developers are encouraged to incorporate monitoring equipment and systems where appropriate to enable occupiers to monitor and reduce their energy use.
• 2.5 Supporting resilient energy supply
  • Developers are encouraged to incorporate equipment that would enable their schemes to participate in demand side response opportunities.’

In the City of London, the CS15 Sustainable Development and Climate Change guidance sets out policies:

• To enable City businesses and residents to make sustainable choices in their daily activities creating a more sustainable City, adapted to the changing climate.
• Requiring all redevelopment proposals to demonstrate the highest feasible and viable sustainability standards in the design, construction, operation and ‘end of life’ phases of development.
• Whereby proposals for major development should aim to achieve a BREEAM rating of ‘excellent’ or ‘outstanding’.
• Requiring development to minimise carbon emissions and contribute to a City-wide reduction in emissions.
  • adopting energy-efficiency measures;
  • enabling the use of decentralised energy, including the safeguarded Citigen CHP network, CHP-ready designs in areas where CCHP networks are not yet available, and localised renewable energy technologies;
  • adopting offsetting measures to achieve the Government’s zero carbon targets for buildings.
• Avoiding demolition through the re-use of existing buildings or their main structures, and minimizing the disruption to businesses and residents.

• Under DM15.1 Sustainability requirements:
  • Sustainability Statements must be submitted with all planning applications in order to ensure that sustainability is integrated into designs for all development. For major development (including new development and refurbishment) the Sustainability Statement should include as a minimum:
    • BREEAM or Code for Sustainable Homes pre-assessment;
    • an energy statement in line with London Plan requirements;
    • demonstration of climate change resilience measures.
  • BREEAM, Code for Sustainable Homes and/or Housing Quality Mark assessments should demonstrate sustainability in aspects which are of particular significance in the City’s high density urban environment. Developers should aim to achieve the maximum possible credits to address the City’s priorities.
  • Innovative sustainability solutions will be encouraged to ensure that the City’s buildings remain at the forefront of sustainable building design. Details should be included in the Sustainability Statement.
  • Planning conditions will be used to ensure that Local Plan assessment targets are met.
• DM15.2 Energy and CO₂ emission assessments:
  • Development design must take account of location, building orientation, internal layouts and landscaping to reduce likely energy consumption.
  • For all major developments, energy assessments must be submitted with the application.
• DM15.3 Low and zero carbon technologies:
  • For development with a peak heat demand of 100 kW or more, developers should investigate the feasibility and viability of connecting to existing decentralised energy networks. This should include investigation of the potential for extensions of existing heating and cooling networks to serve the development and development of new networks where networks are not available. Connection routes should be designed into the development where feasible and connection infrastructure should be incorporated wherever it is viable.
  • Where connection to offsite decentralised energy networks is not feasible, installation of on-site CCHP and the potential to create new localised decentralised energy infrastructure through the export of excess heat must be considered.
  • Where connection is not feasible or viable, all development with a peak heat demand of 100 kW or more should be designed to enable connection to potential future decentralised energy networks.
  • Other low and zero carbon technologies must be evaluated. Non-combustion-based technologies should be prioritised in order to avoid adverse impacts on air quality.
• DM15.4 Offsetting of carbon emissions:
  • All feasible and viable on-site or near-site options for carbon emission reduction must be applied before consideration of offsetting. Any remaining carbon emissions calculated for the lifetime of the building that cannot be mitigated onsite, will need to be offset using ‘allowable solutions’.
  • Where carbon targets cannot be met on-site, the City Corporation will require carbon abatement elsewhere or a financial contribution, negotiated through an S106 planning obligation to be made to an approved carbon offsetting scheme.
  • Offsetting may also be applied to other resources including water resources and rainwater run-off to meet sustainability targets off-site where on-site compliance is not feasible.

The clear message from these policy initiatives is that in the foreseeable future, building energy requirements must be met from sources which are not wholly reliant on a fossil-fuelled national Grid but should utilise energy derived from renewable sources to include, if possible, a proportion which is generated locally.

Background; Policies and Legislation

EUROPEAN UNION: EU Climate Change Package

• The EU’s climate and energy policy sets the following targets for 2020:
  • A 20% reduction in EU greenhouse gas emissions from 1990 levels;
  • Raising the share of EU energy consumption produced from renewable resources to 20%;
  • A 20% improvement in the EU’s energy efficiency.

NATIONAL: Climate Change Act 2008

• The Climate Change Act sets legally binding greenhouse gas emission reduction targets of at least 80% by 2050 (with an interim target of 26% by 2020) against a 1990 baseline, which are to be achieved through action taken in the UK and abroad.

NATIONAL: The National Planning Policy Framework (NPPF)

• The National Planning Policy Framework (NPPF) was published in March 2012. It is intended to replace various existing Planning Policy guidance documents so as to make the planning system less complex and more accessible. Key sections from the NPPF are:
• Paragraph 95, which states that: ‘To support the move to a low carbon future, local planning authorities should …when setting any local requirement for a building’s sustainability, do so in a way consistent with the Government’s zero carbon buildings policy and adopt nationally described standards’.