Renewable energy and local plan policies

Case study

Contents
Introduction 4 About the Case Studies 5 Lessons 6 Spatial policies for renewable energy 8 Criteria-based policies for renewable energy 12 Spatial policies for Low Carbon Heat 13 Evidence base 16 Consultation and testing at Examination 18 Conclusions and lessons 19

This case study was prepared for PAS by BPP Consulting.

July 2013

Introduction
Paragraph 97 of the NPPF advises that to help increase the use and supply of renewable and low carbon energy local planning authorities should consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources. The footnote to the policy makes it clear that where plans identify areas as suitable for renewable and low-carbon energy development, they should set out what criteria have determined their selection, including for what size of development the areas are considered suitable. Authorities should also have policies to ensure any adverse impacts are addressed satisfactorily. Identifying suitable areas for such developments implies a degree of spatial specificity in plans, through mapping or describing broad or specific locations where opportunities may exist and where development might be most appropriate and encouraged. policies need to be supported by a robust evidence base that has been used flexibly according to local circumstances consult widely and early on the evidence base and resultant polices to avoid surprises and reduce risks of challenge. consider whether separate policies are required reflecting different components of carbon reduction (energy efficiency, district heating, renewable energy development) and the different types of developer and possible The case studies illustrate how some planning authorities with recently adopted or emerging plans are taking a spatial approach to policies on renewable energy. Spatial identification of opportunities is most common for district heating Renewable energy and local plan policies - case study 4 delivery mechanisms ensure policies are flexible to reflect viability, costs and constraints, and robust to changes in technology and economic circumstances. It is early days in terms of implementation. The policies are fairly new, so the authorities haven't yet seen how they are working out in practice. However, the case studies do illustrate that some of the fundamentals of good plan-making apply to this area of planning, like any other: and combined heating and cooling but there are a few examples of for freestanding renewable energy developments, such as wind turbines.

About the Case Studies

The case studies are drawn from urban and rural, metropolitan and two tier planning authorities. These authorities have recently adopted plans or have plans at an advanced stage of preparation with explicit spatial policies and/or supporting text that identifies suitable areas for renewable and low carbon energy sources and supporting infrastructure. Spatial policies are set within wider policies on the delivery of renewable energy as summarised below.

We looked at how these authorities are approaching the issues:

Bristol City Council Darlington Borough Council Hastings Borough Council Richmondshire District Council South Staffordshire Council Manchester City Council Stockport Metropolitan Borough Council

For further details on these councils and their plans, see Appendix A.

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Lessons
Based on the experiences of the authorities featured here the following lessons can be highlighted. In general though, the same principles which apply to good plan-making overall also apply to this area of policy making: it may be helpful to use consultants that have developed the evidence base (renewable and low carbon capacity, constraints and opportunities) to advise on framing of policies to ensure accurate interpretation of information.

Prepare a robust evidence base use of external independent expertise is important in developing a robust evidence base with the expertise used to support the planning authority at examination collaboration with other authorities in preparing the evidence base helps consideration of a wider geographic area strategically (and identifying where realistic opportunities may be) and also brings economies of scale be prepared to adapt how you use evidence to inform and defend policy in the light of feedback from consultation if necessary.

Achieve a balance between specificity and flexibility ensure policies are flexible to reflect viability, costs and constraints, and be robust to changes in technology and economic circumstances combine identification of opportunities and priorities spatially with criteria in policies against which proposals can be considered to address potential impacts and constraints consider use of landscape character assessments and sensitivity assessments to help assess its capacity to accommodate renewable energy installations and consider proposals apply policies in a pragmatic way, ensuring viability of developments is maintained while reducing carbon emissions. Be clear about delivery mechanisms be clear who the audience is for different policies or components of policies (energy efficiency, carbon savings, district heating, renewable energy development)

Avoid misinterpreting information an Energy Opportunities Map or similar can be used to provide a spatial steer to developers and form the basis for dialogue. It should not imply development will necessarily be permitted in identified areas or will not be permitted outside of these

Renewable energy and local plan policies - case study 6

and consider framing policies to reflect this consider preparing additional guidance to assist interpretation and implementation of complex policies, for example for energy and carbon standards exceeding Building Regulations

masterplanning presents an opportunity to design-in renewable and low carbon energy, including district heating infrastructure, to developments at an early stage.

Understand and explain the links between policy objectives climate change mitigation policies (e.g. district heating, and renewable energy development) have different audiences and delivery mechanisms but are all necessary to promote the common objective of reducing greenhouse gas emissions.

Ensure you engage parties early on getting buy-in from developers, development management, senior management, and politicians at an early stage, and where possible ongoing training, is essential so that the evidence base and policies are understood and implemented as intended.

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Spatial policies for renewable energy

Spatial policies have been produced which apply to free-standing renewable energy installations (which include wind turbines and wind farms, but could also apply to hydro power, and large solar photovoltaic arrays, biomass-fired plants including combined heat and power plants). The approaches to spatial policy for renewables vary and include: covered by national landscape or heritage designations. The supporting text refers to the evidence base (Hastings Renewable and Low Carbon Energy Study, 2009) which identified potential for wind energy in two locations at Combe Valley Countryside Park (within both the Hastings and Rother areas) and at Hastings Country Park which are identified on the Key Diagram along with Identification of areas with potential for renewable (generally wind) energy development on a map associated with the policy description in policy of broad or specific locations suitable for renewable or low carbon energy development eference in policy and/or supporting text to areas identified as suitable for renewable energy in the supporting evidence base reference in the supporting text to areas of opportunity identified in the evidence base (energy studies). Positive policies supporting renewable energy development and identifying areas of potential are necessary to help achieve objectives and targets for reducing carbon emissions including offsetting those associated with growth proposed in the the locations with potential for low carbon heat. This potential is further being explored through the allocation of one potential site for harnessing wind (SiteFB12) in the emerging Development Management Plan (Proposed Submission January 2013).

Hastings Core Strategy Policy SC6 provides support for renewable energy
facilities that meet criteria in the policy including scale and cumulative impact on landscape and built environment, impact on community, economy, biodiversity and historic interests, and on areas

Planning Strategy.

Stephanie Roots, Senior Planning Officer, Hastings Borough Council

Renewable energy and local plan policies - case study

Figure 1 Hastings Core Strategy Key Diagram identifying 5 Potential Areas of Search for Renewable Energy (orange discs)

Renewable energy and local plan policies - case study 9

South Staffordshire

also identifies

However this potential is not explicitly identified on the Key Diagram.

locations with greatest renewable energy (wind, small-scale hydro, and biomass) potential on a map in the Core Strategy, reproduced from the supporting Staffordshire County Wide Renewable/ Low Energy Carbon Study. Policy EQ6 also identifies the potential for wind energy development in the District as four large-scale turbines, and sets out criteria against which proposals will be considered. Although the policy does not make reference to particular locations, the supporting text refers to the map of Locations with Renewable Energy Potential which includes four potential sites of greatest opportunity for wind development (for 3 or more turbines) as included in the Renewable Energy Study.

Richmondshires Submission Core Strategy Policy CP1 makes

it clear that proposals will be supported and encouraged that reflect and respond positively to the Richmondshire Local Renewable and Low Carbon Energy Capacity Study (2012) and the studys Energy Opportunities Map (EOM). The EOM identifies areas where there are specific physical, social and environmental constraints that would restrict renewable and low carbon energy delivery, and also identifies areas where there might be specific spatial opportunities; such as delivery of infrastructure accompanying strategic growth. Although renewable energy schemes are not explicitly precluded outside these areas, the EOM represents the most promising areas for renewable and low carbon energy generation. The map only identifies where there may be opportunities and not where proposals will necessarily be permitted.

Darlington Core Strategy Policy CS3 provides support for renewable energy. The
text identifies wind energy as having the greatest potential to contribute to the Boroughs renewable electricity supply. Assessments of wind speeds, technical and environmental constraints as well as the potential landscape and visual impact are to be used to help identify sustainable locations appropriate for wind energy development. It also identifies Darlingtons urban fringe including the strategic development locations identified in Policy CS1 as being suitable for small-scale wind energy.

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Figure 2 Richmondshire evidence base Energy Opportunities Map (referred to in Core Strategy Policy CP1) identifying Potential Wind Resource (hatched area in north east of plan area) and Viable Residential Heat Demand (for district heating) (orange areas) Renewable energy and local plan policies - case study 11

Criteria-based policies for renewable energy

In addition to identifying opportunities spatially, the case study Core Strategies include policies that set out criteria against which proposals will be considered within the policies for renewable and low carbon energy. These commonly include factors reflecting policy or environmental constraints, and potential impacts of renewable energy developments including: reflecting paragraph 98 of the NPPF, such as by South Staffordshire.

natural, built, historic and cultural landscape and townscape including buildings, features, habitats and species of international, national and local importance

residential amenity including visual intrusion, air, dust, noise, odour, traffic generation, recreation and access

transport infrastructure and the local highway network

cumulative impact.

They also include technology-specific factors, particularly wind turbines. The visual impact of wind development in particular is addressed in most policies, commonly requiring use of landscape character assessments and sensitivity frameworks such as by Richmondshire, and of the criteria used to identify areas suitable for wind development Renewable energy and local plan policies - case study 12

Spatial policies for Low Carbon Heat

All of the Core Strategy (Local Plan) case studies identify the potential for district heating spatially through: describing broad locations within the policy identifying locations on a separate map accompanying the policy identifying locations on the Key Diagram reference to the evidence base (energy studies including heat mapping) used to inform and support the policy. Hastings Planning Strategy Policy SC5 identifies potential opportunities for combined heat and power and district heating networks at three heatdensity opportunity areas where opportunities will be explored for Combined Heat and Power Bristol identifies and maps Heat Priority Areas. Core Strategy Policy BCS14 expects development to incorporate infrastructure for district heating where feasible, reflecting a heat hierarchy that prioritises connection to existing heat networks and site-wide renewable CHP over fossil fuelled (gas) community CHP, with individual building renewable heating as the least favoured. Richmondshires Core Strategy draft Policy CP1 refers to the Energy Opportunities Map (EOM) which Darlingtons Core Strategy Policy CS1 identifies the strategic development areas including the Town Centre and Town Centre Fringe where development should include biomass/combined heat and power installations and district heating and cooling networks. Policy CS3 supports renewable and low carbon energy giving significant weight to its Renewable energy and local plan policies - case study 13 identifies 3 areas where district heating islikely to be most feasible. Most development is small scale with no major strategic development sites and so the focus for development is at Catterick Garrison where the major opportunity for district heating exists, particularly as a masterplan for the site could incorporate district heating and associated systems connected to district heating networks (in the vicinity of the Hospital, Sports Centre, and town centre). The Proposed Submission Development Management Plan includes Site Allocations, where proponents are expected to investigate the potential for district heating and/or combined heat and power. environmental, social and economic benefits while requiring potential impacts, including cumulative effects, to be considered and mitigated. It also requires developments to connect to district heating schemes where opportunities exist.

infrastructure at the outset.

SD-3 identifies two types of area that have distinct energy opportunities identified spatially in its Energy

The potential for district heating networks to be developed will need to be reflected in and encouraged by masterplans incorporating district heating infrastructure, to ensure effective coordination across sites and related infrastructure.

Opportunities Plan:

Network Development Area: where the proximity of new and existing buildings creates sufficient density to support district heating and/or cooling networks (potential district heating areas on the Energy Opportunities Plan); and

John Hiles, Planning Policy Officer Hambleton and Richmondshire District Councils

Microgeneration Area: locations where lower densities and a fragmented mix of uses mean that only building scale solutions are possible (in effect the rest of the Borough).

Manchester s Core Strategy Policy EN5 identifies broad Strategic Areas for low and zero carbon decentralised energy infrastructure in the City Centre, Airport, major development sites, and strategic housing and employment locations. Developments are expected to have energy proposals plans detailing measures to incorporate low and zero carbon energy infrastructure. Policy EN7 has a presumption in favour of low and zero carbon decentralised energy generally, subject to criteria being met, with the supporting text identifying the main sources to deliver the capacity (opportunities for which to be identified in energy proposals plans). Instead, policies often require proposals to be considered with reference to Landscape Character Also in Greater Manchester, Stockports Core Strategy Development Management Policy Renewable energy and local plan policies - case study 14 A number of other emerging plans do not identify areas that may be suitable for renewable energy, on the basis that the information on resource availability and constraints may not be sufficiently robust to delineate suitable areas. Development Management Policy SD-4 requires that new development in Network Development Areas, where technically feasible and financially viable, should consider district heating to help deliver carbon reductions.

Assessments and assessments of relative sensitivity (to wind and large-scale solar, individually and cumulatively) of landscape character types.

This includes areas with experience of large-sale renewable energy developments and pressure for further development e.g. North Devon and Torridge (Local Plan consultation draft, January 2013), Cornwall Council (Local Plan pre submission General Policies March 2013), Northumberland Local Development Plan Core Strategy Preferred Options (Consultation Document: February 2013).

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Evidence base
All of the Core Strategy case studies were supported by a renewable and low carbon energy study. The approaches to preparing the evidence base are similar. The evidence base usually has been prepared by independent technical consultants and includes all or some of the following components: Renewable energy potential, assessing the presence and distribution of resources (average wind speed, hydro, biomass) and constraints to deployment, identifying the theoretical and practical potential generation from different resources and areas where development may be appropriate. Evidence to support energy efficiency and carbon reduction standards beyond the Building Regulations, for example identifying current and projected emissions and the contribution that may be made to reducing emissions through tighter standards usually with reference to national standards such as BREEAM and Code for Sustainable Homes. Consultation on the energy assessments helped to build awareness and understanding of the emerging evidence base prior to consultation on resultant Heat mapping identifying areas of high current or potential heat demand and consumption and/or surplus heat generation where district heating or combined heat and power may be most feasible. These are generally more densely developed urban areas with a mix of uses with a constant heat (or cooling) demand, where there may be anchor heat loads (swimming pools, hotels, hospitals or types of industry, or where major development is proposed). Renewable energy and local plan policies - case study 16 policies. In Staffordshire, consultation events were led by the consultants that prepared the joint Staffordshire County Wide Renewable/Low Energy Carbon Study, involving developers, politicians and other interested parties. Often strategic energy assessments undertaken to support Regional Spatial Strategy policy were used, with additional local studies providing more detailed authority-specific evidence.

Similar stakeholder events were held as part of AGMA Decentralised and Zero Energy Carbon Planning study in Greater Manchester to build awareness and take on board views from developers and public, and additional specific consultation on energy policies was undertaken as part of CS consultation.

Collaboration with other authorities in preparing the evidence base is important in considering a wider area strategically (and identifying where realistic opportunities may be) and also has economies of scale.

Kelly Harris, Local Plans Team Leader South Staffordshire Council

A sound evidence base is required to demonstrate deliverability of policies including as far as possible, consideration of the effects on development viability.

Katrina Holt, Senior Planner Manchester City Council

Examples emerged of specific consultation events on energy policy over and above normal consultation on emerging plans, although Bristol held a specific stakeholder event on climate change as part of the consultation on the Publication version of the Plan.

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Consultation and testing at Examination

As with other types of development, early engagement with interested parties including developers, community groups and parish councils, pressure groups and councillors helps to develop understanding of the issues and identify and resolve areas of real and potential concern. Common challenges to spatial policies include the lack of flexibility resulting from identifying suitable areas, and the implication that proposals outside Darlington identified and mapped in its Preferred Options consultation draft Core Strategy an Area of Least Constraint (with Least Visual and Landscape Impact).Karen Johnson of Darlington Borough Council explains that the consultation identified little support for identification of Areas of Least Constraint (for wind) in the plan, with objections including communities and the wind energy industry that was concerned that the approach would not be flexible to adapt to changes in technology that proposals should be considered on their merits, and areas outside of that identified may prove suitable for wind energy development. A sound evidence base is necessary but the authority should be flexible in how it uses it and not be afraid of changing its approach reflecting issues raised at consultation. By not restricting development to the areas mapped, the policy was found to be sufficiently flexible. The inspector agreed that this part of the policy may be misleading and so misrepresented the Core Strategy intentions, impacting on its effectiveness (and so soundness). Reference to the map was therefore removed from policy itself but retained in the supporting text). of these will not be appropriate. Clarity over what identification of locations implies in terms of areas of greatest opportunity rather than preferred areas outside of which proposals will not be permitted, is therefore important in framing policy. As a result the mapping of areas based on windspeed and relative constraints was not included in the adopted Plan.

Karen Johnson, Darlington Borough Council Renewable energy and local plan policies - case study 18

Conclusions and lessons

It is still early days in terms of plans containing explicitly spatial policies identifying suitable areas for renewable and low carbon energy. Those that have recognise that identification of broad or specific areas where opportunities for renewable and low carbon energy exists may provide a useful steer to potential developers as to areas where proposals may be considered to be generally appropriate. existing heat generators and major consumers. Implementation of district heating is proving difficult given the complexity and costs of ensuring that the heat generation capacity, heat distribution pipework, and secure market for heat are all in place at the right time.

However, developments will also need to be otherwise acceptable and meet a range of criteria. Mapping of suitable areas with potential/ opportunity based on constraints and resource (e.g. wind speed) cannot consider all local issues, impacts and merits of development. It may also be misinterpreted if not carefully drafted, to imply that development outside of such areas is inappropriate. This can be an unintended consequence of attempting to prepare a positive strategy.

Identifying suitable locations for district heating in policy may be more straightforward than for free-standing renewable energy developments, generally being existing urban or major development areas, particularly if in proximity to Renewable energy and local plan policies - case study 19

Appendix A authority and contact details

Bristol City Council Core Strategy (adopted June 2011) provides general support for renewable energy including large-scale free-standing installations, and accords significant weight to the benefits of such developments. While the policy does not identify locations for free-standing renewable installations, the supporting text refers to the City-wide Sustainable Energy Study and identifies Avonmouth as having potential for development of energy from waste and biomass, and for commercial scale wind farms.

Michael Wilberforce, Senior Planning Policy Officer t 0117 90 36693 e. michael.wilberforce@bristol.gov.uk

Darlington Borough Council Core Strategy (adopted in May 2011) policies support renewable and low carbon energy developments generally, with criteria against which proposals will be considered. It supports such development giving significant weight to its environmental, social and economic benefits while requiring potential impacts, including cumulative effects, to be considered and mitigated. The supporting text advises that assessments of wind speeds, technical and environmental constraints as well as the potential landscape and visual impact studies of wind development in the north east of the Borough are to be used to help identify sustainable locations appropriate for wind energy development.

Karen Johnson t. 01325 388047 e. Karen.Johnson@darlington.gov.uk

Stephanie Roots, Senior Planning Officer t. 01424 783329 e. sroots@hastings.gov.uk

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Hastings Borough Council The Planning (Core) Strategy Submission draft examined February 2013) contains a suite of policies addressing renewable and zero carbon development. This includes an energy hierarchy to identify the most suitable and cost effective method of achieving low carbon development, and offset emissions forecast to arise from development over the plan period. It prioritises energy efficiency, then on-site renewable energy generation or on-site connected heating, or combined heat/cooling and power and then suitable additional measures such as larger CHP or district heating systems or Mega Watt (MW) scale wind. The Development Management Plan (Proposed Submission January 2013) Site Allocations include sites with potential for low carbon and renewable energy.

Stephanie Roots, Senior Planning Officer t. 01424 783329 e. sroots@hastings.gov.uk

Richmondshire District Council The submitted Local Plan Core Strategy (February 2013) contains 3 components: Supporting renewable and Low Carbon Energy; Ensuring carbon savings in existing and new development; and Climate Change adaptation. Policy CP1 supports and encourages renewable and low carbon energy that responds positively to the opportunities identified in the Richmondshire Local Renewable and Low Carbon Energy Capacity Study (2012) and the studys Energy Opportunities Map and meets criteria set out in the policy including landscape and visual impact (based on a landscape sensitivity framework) and community benefits plus areas of potential wind resource. The supporting text makes it clear that although the deployment of renewable energy will not be precluded outside these areas, the EOM is considered to represent the most promising areas for renewable and low carbon energy generation.

John Hiles, Planning Policy Officer, Hambleton and Richmondshire District Councils t. 01748 827025 e. John.Hiles@Richmondshire.gov.uk

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South Staffordshire Council Core Strategy (adopted in December 2012) Policy EQ6 sets a target for renewable energy generation in the plan area, supporting development of biomass-fuelled heat and power generally and including criteria against which proposals are to be considered. The supporting text identifies biomass as the preferred resource and technology to deliver carbon reduction standards. A Design Guide is being developed which will be include advice to householders on energy efficiency and renewable energy.

Kelly Harris, Local Plans Team Leader t. 01902 696317 e. k.harris@sstaffs.gov.uk

Manchester City Council The Core Strategy adopted in July 2012 contains a suite of policies (EN4, EN5, EN6 and EN7) encouraging renewable and low carbon energy, and carbon reduction. Policy EN4 aims to reduce carbon emissions through, where possible, development locating close to, and being designed to, enable connection to low or zero carbon supplies. Katrina Holt, Senior Planner t. 0161 234 4570 e. k.holt@manchester.gov.uk

Stockport Metropolitan Borough Council Core Strategy (adopted in March 2011) Policy CS1 requires all development to demonstrate how it will contribute towards reducing the Boroughs carbon footprint by achieving carbon management standards. The Core Strategy seeks to identify and enable opportunities for low and/or zero carbon developments and includes an Energy Opportunities Plan. A suite of development management policies covering energy efficient design, incorporation of low carbon and renewable technologies in existing dwellings and identifying opportunity areas for heat and renewable energy provide for implementation of the policy.

Angie Jukes, Health & Environment Advisor (Planning) t: 0161 474 4385 e: angie.jukes@stockpot.gov.uk

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References
Bristol City Council: Core Strategy: http://www.bristol.gov.uk/sites/default/files/documents/planning_and_building_regulations/ planning_policy/local_development_framework/Bristol%20Development%20Framework%20Core%20 Strategy%20June%202011.pdf

CS evidence base Bristol Citywide Sustainable Energy Study http://www.bristol.gov.uk/sites/default/files/ documents/planning_and_building_regulations/planning_policy/local_development_framework/Bristol%20 Development%20Framework%20Core%20Strategy%20June%202011.pdf

Darlington Borough Council: Core Strategy: http://www.darlington.gov.uk/Living/Planning/Planning+Policy/corestrategy.htm

CS evidence base: Decentralised Renewable and Low Carbon Energy Study 2009 and Update to 2009 Decentralised Renewable and Low Carbon Energy Study Final Report, (Entec July 2010)

Wind Farm Development and Landscape Capacity Studies: East Durham Limestone and Tees Plain (Arup 2008 for Association of North East Councils), and addendum report 2009 http://www.darlington.gov.uk/Living/Planning/Planning+Policy/background.htm

Hastings Borough Council: Planning Strategy: http://www.hastings.gov.uk/environment_planning/planning/localplan/ planningstrategysubmission

Development Management Plan: http://www.hastings.gov.uk/environment_planning/planning/ localplan/documents/#dpd_report

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Local Plan evidence base: Hastings Borough Renewable and Low Carbon Energy Study, (Element Energy 2009) http://www.hastings.gov.uk/environment_planning/planning/localplan/ldf_ documents/renewable_energy_study/

Manchester City Council: Core Strategy: http://www.manchester.gov.uk/downloads/download/4964/core_strategy_ development_plan

Evidence base: Decentralised and Zero Energy Carbon Planning (Urbed/AECOM/Quantum for AGMA, June 2010) http://www.trafford.gov.uk/environmentandplanning/strategicplanning/ localdevelopmentframework/agmadecentralisedenergystudy/

Richmondshire District Council: Core Strategy: http://www.richmondshire.gov.uk/planning/planningpolicy/corestrategy.aspx

CS evidence base: Richmondshire Local Plan Renewable and Low Carbon Study (AECOM, August 2012) http://www.richmondshire.gov.uk/pdf/TE010%20Renewable%20and%20Low%20 Carbon%20Energy%20Study%20(August%202012).pdf

South Staffordshire Council: Core Strategy: http://www.sstaffs.gov.uk/pdf/ADOPTED%20Core%20Strategy%20December%20 2012.pdf

Examination: http://www.sstaffs.gov.uk/your_services/strategic_services/planning_policy_-_local_ plans/core_strategy/examination.aspx

CS evidence base: Staffordshire County-wide Renewable / Low Carbon Energy Study (CAMCO, September 2010) http://www.tamworth.gov.uk/PDF/Staffordshire_LDF%20Evidence%20Base%20Report_V7_ ISSUED.pdf
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Stockport Metropolitan Borough Council Core Strategy: http://www.stockport.gov.uk/2013/2994/developmentcontrol/planningpolicy/LDF/ldfc orestrategydpd?view=Standard

Evidence base: including Decentralised and Zero Energy Carbon Planning (Urbed/AECOM/ Quantum for AGMA, June 2010) http://www.stockport.gov.uk/services/environment/planningbuilding/planningpolicy/ldf/ldfevidence

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