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Official use only Ack.

Rec’d. Duly made.

Resp.No. Doc. Ref:

Core Strategy Spatial Options Consultation

19 October – 11 December 2009

Planning tomorrow today

Comment Form

I am commenting on questions DW6, DW7, DW8, DW9, DW10 and DW 11 of the
Core Strategy Spatial Options document – Core Policies Climate Change
Question DW6: Do you agree with the targets suggested by the research for renewable
energy or should we aim to higher targets?

We recognise that setting renewable energy targets are a welcome and significant step
forward, although we feel that there is scope for reviewing the targets upwards in 2-3 years
time. Our clear preference is that the targets should represent a larger proportion of the
technical potential outlined in the CAMCO report. Whilst the report demonstrates that the
renewable energy resources in the B&NES area are more limited and economically less
attractive than in other parts of the UK, given time and increasing fuel prices the achievable
potential will increase.

Comparing the proposed targets for 2020 with the 2005 energy demand in B&NES (as given
in the CAMCO report), the targets would imply that 8.9% of electricity consumption and 8.4%
of heat requirement would come from renewable energy. These figures compare
unfavourably with the UK national targets for 2020, which are 32% of electricity consumption
and 14% of heat requirement as set out by DECC. This highlights the need for the core
strategy to present the renewable energy targets as a percentage of total B&NES energy
consumption and also to present a target maximum absolute energy demand and absolute
level of carbon emissions.

We realise that maximising the achievable renewable energy potential, especially in terms of
locations for wind turbines will be contentious, but B&NES should make it a priority to
facilitate the expansion of the renewable sector. This will lead not only to a significant
proportion of power being generated locally but will act as a driver to expand local
businesses and meaningful employment opportunities. To do otherwise would be to pay lip
service to the council’s own policies for combating climate change.

The core strategy recognises that the planned “Feed-in-tariff” for households will influence
the uptake of small-scale renewable energy, and may result in greater use of small-scale
wind, solar thermal and solar PV systems. However, monitoring the uptake of these
technologies in B&NES up to 2020 and 2026 will be important so that a clear understanding
of their contribution can be measured. Further analysis of the potential impact of the “Feed-
in-tariff” would be useful to inform future strategic planning.

Please complete a separate form for each part of the document you would like to comment on
Regarding the proposed mix of technologies, we would not accept that only up to 9-10 large
scale wind turbines are likely to be feasible in B&NES, and we also suggest that more than
10 smaller scale wind turbines could be achieved. We are aware of several local farmers
who are interested in wind energy, and if built in suitable locations in rural areas, many of
these could be acceptable. When local people have a stake in wind turbines opposition to
their siting dramatically reduces. B&NES should make use of this fact and work with local
groups such as Transition Bath to ensure local participation and community ownership of the
means of generation. With this strategy in place we believe that the target for wind energy
could be increased.

For biomass, we note that a woodfuel supply chain would need to be put in place, but there
may be a conflict between land used for energy crops, and land used for food. Lower grade
agricultural land or land subject to flooding could be used for biomass production. Average to
high grade land will be vital for food production. Woodfuel from south of the B&NES area is
likely to be needed, but transport energy and costs may be a barrier. Further information on
woodfuel potential is given in the SW Regional Woodfuel Framework 2005.

No account is taken in the draft core strategy of technological innovation over the next few
years being able to deliver higher targets. Further research should be conducted into the
likelihood of new technologies becoming available and cost-effective in future years. For
example, plans are emerging for energy companies such as United Utilities and Ecotricity to
deliver renewable biogas to customers through the natural gas network. Biogas from
anaerobic digestion of food and other wastes is a potentially very interesting new opportunity.
Also in the wastes sector, new techniques such as pyrolysis and gasification are in the
development phases and these could offer additional sources of renewable energy within a
sustainable waste management strategy.

Question DW7: Can you comment on any other planning framework to ensure a
smooth and effective way to support renewable energy production?

It is essential that a new paradigm is established for renewable energy installations. The
focus should be changed to the planners facilitating the maximisation of renewable
generation. They should be rewarded for finding ways to maximise renewable installations.

The core strategy does not explain what the Council will do to deliver its contribution to the
renewable energy targets. One key area would be to develop suitable planning frameworks
which encourage renewable energy development. For example, B&NES could set design
standards for small scale renewable energy in the context of our World Heritage Site, and
mirror national policy in respect of permitted development.

The consultation implies that wind turbines should be located near to new developments, but
there is no connection between the location of the optimum wind sites and the urban
extensions. In addition, good practice guides for wind energy development specify minimum
distances between turbines and houses. Pre-identified sites for renewable energy projects
would be useful, rather than simply responding to developers’ proposals. Whilst the strategy
makes life easy for housing developers by identifying areas of search in the urban extensions
where planning permission may be more straightforward, it does not do the same for a
developer wishing to build a waste-to-energy plant, a biomass gasification plant or a wind
The strategy restricts Council activity to public sector demonstration schemes in its own
properties, but more could be achieved if there is collaboration with the private and voluntary
sectors. For example, the Council should consider waiving planning fees for community-led
projects and offer technical support and guidance to such projects. The Council could also
consider working directly with local community groups in joint ventures so as to capitalise on
local involvement. For example, Woking Council have achieved much by setting up a joint
venture ESCO with the private sector which delivers sustainable energy services via CHP,
PV and fuel cell systems.

It would be a tremendous boost to the national climate change programme if B&NES can
demonstrate that its planning policies and active support of renewable energy can be seen to
be successful in our very special World Heritage Site location.

Question DW8: Do you think a local policy should be developed to support retro-

A large proportion of the capacity targets are only delivered by constructing new buildings
rather than by retrofitting on existing buildings. We strongly agree with the idea of developing
a local policy to support retro-fitting, which thereby could encourage a greater uptake of small
scale renewable energy. This could be extended into the energy efficiency area; for
example, planning permission for a house extension could be granted only if a more than
adequate level of insulation was used and will be retro fitted in the original house.

Question DW9: Do you agree with the targets suggested by the research for
decentralised energy supply?

The target for decentralised energy supply in larger scale new developments is to reduce
emissions from energy used on the development by the equivalent of 20%. We agree with
this figure, as it helps support renewable energy development in the B&NES area, and
provides support to the renewable energy industry in terms of security. The Code for
Sustainable Homes (CSH) will very quickly require far more than 20% renewable energy, and
the CO2 reductions required by the code represent by far the more potent demands in terms
of new build.

Question DW10: Do you agree with this threshold?

The threshold for larger scale development is over 10 dwellings or 1000m2 of non-residential
use. We agree with this threshold, as it is sufficiently low to capture a significant number of
likely new developments.

Small scale, but non domestic, wind turbines in the 50-75kW size range are ideally suited to
smaller housing developments. B&NES should identify areas suitable for smaller scale
housing developments with on site wind generation. For example the Vestas 75kW turbine,
costing about £100,000 installed, would generate some 100,000kWh per year at an annual
mean wind speed of 5m/s (manufacturer’s figures). This would be sufficient to meet 100% of
the annual electricity demands of 30 average medium size homes with an annual
consumption of 3,300kWh each. As part of a strategy to achieve Code for Sustainable
Homes Level 6, this approach represents much better value for money than individual solar
PV generation. The cost of the wind turbine will be around £3,300 per home. To generate
100% of the annual demand from PV would require an array of around 5kW (Energy Saving
Trust figures) at a cost in excess of £20,000.
Question DW11: Do you agree that major developments should meet higher targets
than national standards for sustainable construction and energy efficiency?

We agree that major developments should meet higher targets then national standards.
However, we do not agree with some of the proposed target levels of CSH achievement (in
the table on page 40 of the strategy). For residential developments in the urban extensions,
CSH Level 4 should be applied for both periods of the years 2010-2012 and 2013-2015. For
brown-field residential developments we agree with the levels proposed. For non-residential
developments in urban extensions, we suggest that the energy reductions should be 25%
compared with the 2006 Building Regulations Standard in each of the periods 2010-2012 and
2013-2015. For brown-field non-residential developments we agree with the proposed

A report was done for the SW Regional Assembly ( to generate

evidence for a higher than national target and provided the evidence to support higher code
levels within the SW Regional Spatial Strategy. Another reason for the suggested changes is
that the standards should be higher for the urban extensions because brown-field sites are
more difficult to deal with, particularly as some of the relevant technologies such as biomass
CHP will not be available in the early years of the period from 2010-2019.

We would like to point out that improved energy efficiency represents by far the most
effective means of reducing CO2 emissions. B&NES has more scope to influence energy
efficiency by setting targets around reducing energy demand in both existing and new
buildings. Although this is difficult in a planning document beyond the policies on new build
in the urban extensions and brown-field sites, we would urge that more comprehensive
energy demand reductions targets are included in other corporate policies.

Question DW12: Do you agree with the threshold or should it be lower?

For brown-field residential developments we suggest that the threshold for applying these
CSH levels should be lower, at 50 dwellings not 500.

Signature:………………………………………………….... Date: 5. January 2010

Name (please print)………………Dr David Martin ……………………………………………….

Organisation (if applicable) ………Transition Bath Energy Group………………………….
Address …6 Beech Avenue, Bath, BA2 7BA.
Daytime Tel. No. 01225 460392….. Fax. No. …………………………………..