Response from Mrs Elizabeth Jones, South Lakes World Development Movement
1. Mrs Elizabeth Jones, South Lakes World Development Movement : 9 Jul 2008 09:18:00
To which part of the Report does your representation relate?
Paragraph or Section
Preferred Option - PO24 - Sustainable Energy
Please write your comment or explain your reasons for supporting or opposing this part of the Report. You may also wish to refer to the tests of soundess in the glossary of the Preferred Options document before making your comments.
The option chosen (Option 3) is the weakest of the three options put forward , with thresholds used in the original “Merton Policy” not in more recent upgrades of that policy.
Upgrades to lower thresholds, as in option 2, are being developed all over the UK because the construction industry has found that the additional costs are not serious hindrances to development. The NW RSS Panel report recommended thresholds as in Option 2 , and these were only not taken forward by GONW because they felt that LDF’s were a better place for such policies. There is no local reason why these more stringent thresholds should not be included, as market demand in the area is strong. Local GHG emissions /head are more than twice those in urban areas such as Manchester and actions to reduce these are very urgent. As many of the proposed homes will be affordable and for local occupancy it is even more important that the running costs are kept low, and fuel poverty avoided. The tendency for developers to achieve capital savings at the expense of future running cost can only be prevented by strong and coherent policy and enforcement.
More seriously however PO24 is also weakened by wording asking only for a 10%
reduction in carbon emissions, not asking for on-site renewable energy generation. It is also open to the developer to offer alternative reductions from construction techniques, or design and layout, whereas such techniques and best practice in design and layout should be a separate, additional, requirement. PO24 does not explain what baseline is to be used to measure “10% reductions” against. Is it to be 10% over and above Building Regulations in force at the time of the application? Or 10% over and above Sustainable Code 4,5 or 6? The BREEAM methodology required by NWRSS does include such references and could also be asked for in the policy. In summary PO24 is not sound because it is neither an appropriate or coherent option and not strong enough to secure reductions in local GHG emissions or reduce future fuel poverty.
What change(s) would you suggest for this part of the Report? PO24 should read something like:“The Council will require all developments, either new build or conversion , with a floor space of 500m2 , or 5 or more residential units to incorporate on-site renewable energy equipment to reduce predicted CO2 emissions by at least 10% .”This is the policy now (following their experience) being adopted by Merton, except that Merton is now seeking to reduce the threshold to include single houses.It may also include “All new development should meet BREEAM “Excellent”, or “ Very Good” standard in rural areas”Proposals should demonstrate that siting, layout and construction, maximise opportunities for passive temperature management, and minimise the GHG emissions from construction and use.Additional sections should be included to encourage new renewable energy on existing buildings, and encourage sustainable construction even where this challenges the prevailing design aesthetic for the area, and also explore the potential for other renewable energy generation (e.g hydro).
SL WDM comments about additional sections within PO24 could sensibly be included as a new option or policy. Indeed the Sustainability Appraisal for the DPD also points out that the LPA has the responsibility to consider renewable energy generation in its area, and that consideration should be given to include an additional policy on renewable energy.A Core Strategy Policy should be developed that promises a study on renewable energy potential, in addition to the Wind Energy SPD already developed jointly with Cumbria County Council. For example more radical consideration should be given to hydro opportunities, including small scale dams taking water diverted from low volume becks. The viability of such energy generation schemes should be assessed against a range of scenarios for carbon reduction legislation and energy prices. Small scale schemes for use when wind speeds are low should also be considered as part of an overall resilience and renewable / low carbon energy plan for the area. If the plan is to be sound it must include the flexibility to respond to the likely rises in energy prices, and potential renewable sites should be safeguarded from other development that could be affected or inhibit development in the future.Note that many towns in the UK built economic success on similar schemes, which do not have to run 24/7 in order to make a significant contribution.Such a policy option should be backed by evidence of GHG emissions for South Lakeland, and a proposal to reduce this in line with government policy. It now appears that the Climate Change Bill is likely to become law this Autumn, and the target of 60% reduction by 2050 is likely to be increased to 80%. The reductions required are seriously threatening to our economy and comfort if radical steps are not taken as soon as possible