Bath & North East Somerset Council are currently consulting on the Local Plan Partial Update. The purpose of this Options Consultation is to give Bath and North East Somerset residents and other stakeholders a chance to comment on the options, or potential approaches, for addressing some of the critical issues facing our area, including the climate and ecological emergencies.
The consultation closes on 18th February 2021. We urge as many people as possible to respond to the consultation to demonstrate local support for planning policies that enable an effective response to the climate and ecological emergencies.
For more information go to B&NES Council website
Here is BWCE’s response:
Bath & West Community Energy (BWCE) is a not for profit, Community Benefit Society. We are working to put people at the heart of the energy transition, placing ownership and control of energy in the hands of consumers, via clean energy projects that actively involve and benefit local communities in the Bath and surrounding area.
BWCE has so far installed 12.35 MW of community owned renewable energy, enough to match the annual electricity demand from 4,000 homes and re-distribute to date over £200,000 of surplus back into local communities. In addition to this we are assessing the potential for a community owned electric vehicle charging network, community renewable heating projects and testing community approaches to minimising peak electricity demand.
BWCE strongly welcomes and supports B&NES Council’s update to its Local Plan and the strong emphasis placed on climate change mitigation and environmental quality. BWCE supports the strengthened policies around renewable energy with a new policy on wind energy, the strengthened policies on sustainable construction and the new policies on whole life carbon assessments and electric vehicles. We also make a number of recommendations for enhancing these policies further.
The Local Plan update also provides a welcome range of policies on sustainable transport planning and environmental quality. We would be interested to hear from other practitioners, closer to these policy areas than BWCE, as to whether these policies are commensurate with the challenges we face.
Sustainable construction (DM1, 2 and 3) – It’s good to see the strengthening of the sustainable construction policy. Given the government now seems to be supporting the Future Homes Standard for new homes, we expect the Local Plan to follow option 2 for residential development. If for some reason this does not happen, then the minimum transitional carbon reduction should be 20% through fabric performance, in line with the Future Homes Standard, rather than the 10% mentioned here.
There is also debate around the 2025 date for delivering the full Future Homes Standard, with many experts saying that this should be brought forward to 2023. BWCE recommends that B&NES plays a strong leadership role by committing to a further ramping up of standards in 2023, as part of the next Local plan update.
We particularly welcome policies for non-residential development and retrofit and note that government has recently published consultations on both these issues.
We would support option 2 for existing buildings and a commitment to 20% reduction in regulated carbon emissions. Though it is unclear why this policy refers to just renewable energy and doesn’t include improvement in fabric performance.
Ensuring a minimum EPC rating for Houses in Multiple Occupations (HMOs) of at least ‘C’ is good and in line with the latest government consultation (recently closed) for the wider Private Rented Sector. We believe an EPC rating ‘C’ represents the lowest that a minimum standard should be set at. Again, it would be good to see a commitment to increasing this in the next Local Plan review in 2023.
We would strongly recommend that there is adequate provision for performance monitoring and post construction quality assessment to ensure that the high sustainability standards set by policy are actually implemented in the real world. Policy should flag both the importance and the intent to follow through with this and be supported by further guidance as to how this monitoring will be delivered.
We have not commented on the range of place specific polices, on the grounds that with regards climate mitigation, issues should be covered within the development management polices such as these on sustainable development.
However, we would suggest that where there are development sites that include land appropriate for the development of larger scale renewables, such as ground mount solar, that may or may not be in excess of what is required to meet sustainable construction guidelines, that these opportunities are not lost. For example, there could be a recommendation to review the potential of such opportunities as community owned renewable energy sites. Thereby offering the potential for community investment to finance the project and generate community benefit as a result. This way, opportunities for larger renewables projects associated with new development could be progressed at no additional cost to the developer.
Whole Life Carbon Assessments (DM4) – We particularly welcome new policy on this, recognising the importance of embodied carbon emissions linked to the whole life cycle of materials, construction and use of the building.
If it is felt that there is insufficient evidence to set a threshold for life cycle carbon emissions at this stage, it would be good to recognise in the policy the intention to set a threshold as soon as the evidence is there to justify it, either as part of the next Local Plan update in 2023 or before if possible.
Renewable energy (DM5) – It’s good to see a focus on energy storage and a prohibition on new gas fired generators. However, we note that the targets for renewable energy have not been changed from the policy in the core strategy approved in 2014. This is a missed opportunity to recognise the increasing demands on climate mitigation. This is particularly surprising given the research B&NES Council commissioned from Anthesis following the Council’s climate emergency declaration that suggested far higher goals were both achievable and necessary if we are to make the rapid progress to net zero that was targeted within the climate emergency declaration.
Local renewable energy is important because it helps keep energy bills down with lower capital costs than large scale offshore wind for example and is closer to demand and so also reduces transmission costs and losses. Local renewable energy also delivers local benefit, particularly if community owned, for the local economy and local communities. By being locally visible, it is also a constant reminder to us of where our energy comes from and so hopefully helps us focus on using it more efficiently. We should be maximising local renewables wherever we can.
However, doing this will be challenging in large part due to grid constraints in the B&NES area that will severely constrain the ability to secure high levels of local renewables. Increasing local targets sends a very clear signal to our local grid operator Western Power Distribution and helps build the evidence base on which they can justify the grid reinforcement that is required in this area. Further grid reinforcement is required not just for renewable energy, but also for the higher electricity demand that will come from the increased use of heat pumps and electric vehicles, also forecast to meet our carbon reduction goals.
So, in a very real sense, increasing targets could have a material impact on our ability to secure local renewables. If there are technical reasons why these higher targets could not be incorporated into this update, again flagging an intention to increase targets in the next update in 2023, following the more detailed resource assessment currently underway, will make a clear statement of intent and demonstrate a clear direction of travel.
We would also strongly recommend that the current B&NES Supplementary Planning Guidance on Solar PV in greenbelt is reviewed and updated where necessary, and to include the development of wind energy.
Wind energy (DM6 & 7)– We strongly support this new policy as it offers the potential to finally see wind energy in the local area. Onshore wind energy is vitally important as the cheapest of all forms of renewable energy, but also because it helps more closely balance the generation of electricity with demand. Wind turbines generate electricity whenever the wind blows, not just during the day when solar panels are generating. So, it helps us more easily meet electricity demand during peak times in a world without the more flexible, but highly carbon intensive, fossil fuel generating plant that can more closely follow shifts in demand.
We note the landscape sensitivity analysis for wind energy that has been carried out in B&NES and acknowledge that wind energy will have a visual impact locally and we need to minimise that impact where possible. This analysis gives B&NES Council the ability to prioritise development away from the areas with the highest impact. However, we believe being able to see wind turbines has far less of an environmental impact than the alternative fossil fuel generation. We also believe large turbines are graceful and remind us that we all have a responsibility to use energy as carefully as possible.
As such we strongly believe that the policy should adopt option 2, allowing turbines in areas of moderate-high impact. This will protect those areas of the highest impact but provide the ability to select those sites that are best suited to wind energy and so be able to deliver what is needed with the fewest number of sites.
We also believe that the references to the technical capacity of wind turbines in each option could be misleading. In any assessment the technical potential capacity is always many times larger than what is practically achievable. As a result, these figures, that imply the B&NES renewable electricity target will be easily met with wind turbines even if option 1 is selected, will in no way represent the much lower scale of development that will actually be seen if this policy is passed.
In addition, we would ask for greater clarity around what is meant by ‘community support’.
We know that any development will never be supported by everyone, this would be a very high hurdle and a more stringent requirement than any other development faces. So, some statement that at least clarifies that community support does not mean 100% support would be helpful. Otherwise, one person or a small group might be able to stop an otherwise well supported and appropriate development.
It should be possible to draft guidance that highlights a range of factors that you might expect to see (or not see) in a project that has community support, without having to try and define what it means in absolute terms, which could be misleading and unhelpful in itself.
One of the indicators of community support should include project ownership by a not-for-profit community energy enterprise (a Community Benefit Society for example), with an asset lock that protects any asset for community benefit. Ownership by this sort of organisation offers local accountability, opportunities for local investment in the project, involvement and influence in the organisation’s governance and the opportunity to recycle surplus cash as benefit back into the local community.
As such we would recommend that in this context a strong link is made to the separate existing policy on community energy.
Electric Vehicles (DM8) – Policy on electric vehicle charging is important and welcome. Technology for chargepoints is evolving rapidly with increasing pressure on chargepoints to be ‘smart’ so as to allow the remote control of charging to minimise conflict with times of peak demand. The next generation of chargepoints is also only just being tested that allows vehicle batteries to be utilised by the grid when connected, to help balance supply and demand during times of high or low generation of renewable energy. New standards are also required to ensure technology is interoperable and doesn’t tie consumers to individual systems or suppliers.
All this development is happening rapidly and is likely to significantly change technology over the next few years.
So, given that electric vehicle use is still low, though rapidly increasing, many of the residents of new developments will not own electric vehicles. As such it would make sense for new developments to install the infrastructure, future-proofed as far as possible, but the chargepoints in just a proportion rather than all of the dwelling/parking spaces, to account for current and near term levels of demand.
If central and local government continue to provide grants to support the take up of chargepoints, then it would maximise the potential for new chargepoints to more closely match the take up of electric vehicles and so ensure that the technology utilised was always the most advanced and appropriate to the demands of a flexible grid.
Otherwise, there is the danger that we will need to replace obsolete technology with significant associated cost and waste of resources.
As a result, BWCE would support the options 2a and 3a for major residential development and non-residential development with more than 10 parking pays, requiring 20% active chargepoints and passive technology for the rest.
However, we would also recommend that there is an additional requirement that for residential development over 10 dwellings there is the same 20% active provision required.
This policy should also flag the council’s intention to proactively review the level of requirement within the next Local Plan update in 2023 to clearly highlight the direction of travel for industry. This next update provides a timely opportunity to increase the level of active provision in new development, if considered appropriate at that time to meet increasing demand and in light of new technology development.
We welcome any feedback you have on our response.
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