Land and planning policies - Climate Change Background Paper September 2013 - Nottingham City Council
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Nottingham City land and planning policies Development Plan Document Climate Change Background Paper September 2013
Contents
1. Introduction 2
2. National Context 3
3. City Council Guidance and Policy 5
4. Other Relevant Publications and Tools 12
5. Sustainable Building Standards 15
6. Climate Change Mitigation 17
7. Locally Derived National Standards 21
8. Climate Change Adaptation 22
9. Sustainability Statements 23
10. Viability and Feasibility 24
11. Conclusions 24
1
1. Introduction
1.1 Climate change refers to changes in long term trends of normal
weather patterns. The time scale for this is observed over periods of
30 years, scientifically and spatially from a specific location.
1.2 The impacts of climate change can include extreme weather, flooding
and altered habitats. However the effects of climate change can both
be mitigated against and adapted to.
1.3 The purpose of this paper is to set out the planning context for climate
change and examine what the potential scope of policies should be
incorporated in the LAPP DPD.
1.4 The type and extent of policies that could be included within the LAPP
DPD, which are being examined in this paper are:
• Energy Efficiency: Solid Wall Insulation
• Utilising Energy Efficient Supplies: District Heating
• Maximising Use of Renewable Energy Generation Systems:
Wind Turbines
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Combined Heat and Power
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Solar Thermal
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Biomass
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Heat Pumps
• Carbon Offsetting
• Green Infrastructure
• Sustainable drainage
• Flood Risk
1.5 In 2006, Nottingham generated 14.43% of its own heat and power from
low or zero carbon generation. The City’s ability to adapt to climate
change has also been increased recently, through the development of
the Nottingham Left Bank Flood Alleviation Scheme (FAS).
2
2. National Context
Climate Change Act (2008)
2.1 The Climate Change Act (2008) puts in place a legally binding target to
reduce green house gas emissions by at least 80% by 2050.
2.2 The main provisions of the Act are:
• Carbon targets and carbon budgeting: in addition to the long
term target of at least 80% reduction in Greenhouse Gas
Emissions by 2050, there is also a carbon budgeting system,
which caps emissions over five year periods.
• The Committee on Climate Change: The Act created an
independent body to advise Government of the level of carbon
budgets and where cost effective carbon savings can be made.
• Trading schemes: It introduced emissions trading schemes to
reduce green house gas emissions.
• Impact and adaptation to climate change: The Government must
report at least every five years on the risks to the UK from
climate change, and publish a programme setting out how these
impacts will be addressed. Powers for Government to require
public bodies to carry out their own climate impact risk
assessment and make plans to address those risks were also
introduced.
Planning and Energy Act (2008)
2.3 This Act enables Local Planning Authorities to set reasonable
requirements for:
• A proportion of energy used in development to be from
renewable sources in the locality of the development;
• A proportion of energy used in development to be low carbon
energy from sources in the locality of the development; and
• Development to comply with energy efficiency standards that
exceed the energy requirements of building regulations.
National Planning Policy Framework (2012)
2.4 The National Planning Policy Framework (NPPF), which was published
in March 2012, sets out a number of requirements for planning and
climate change. It requires Local Planning Authorities (LPAs) to adopt
proactive strategies to mitigate and adapt to climate change, taking full
3account of flood risk, coastal change and water supply and demand
considerations.
2.5 Paragraph 95 sets out that, to support the move to a low carbon future
LPAs should:
• Plan for new development in locations and ways which reduce
greenhouse gas emissions;
• Actively support energy efficiency improvements to existing
buildings; and
• 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.
2.6 In order to increase the use and supply of renewable and low carbon
energy, LPAs should recognise the responsibility on all communities to
contribute to energy generation from these sources. In accordance
with Paragraph 97 they should:
• Have a positive strategy to promote energy from renewable and
low carbon sources;
• Design their policies to maximise renewable and low carbon
energy development while ensuring that adverse impacts are
addressed satisfactorily, including cumulative landscape and
visual impacts;
• Consider identifying suitable areas for renewable and low
carbon energy sources, and supporting infrastructure, where this
would help secure the development of such sources;
• Support community-led initiatives for renewable and low carbon
energy, including developments outside such areas being taken
forward through neighbourhood planning; and
• 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.
2.7 The NPPF also sets out specific guidance with regards planning for
flooding. Paragraph 100 states that inappropriate development in
areas at risk of flooding should be avoided by directing development
away from areas at highest risk. Local Plans should apply a
sequential, risk based approach to flooding, taking account the impacts
of climate change by:
4• Applying the Sequential Test;
• If necessary, applying the Exception Test;
• Safeguarding land from development that is required for current
and future flood management;
• Using opportunities offered by new development to reduce the
causes and impacts of flooding; and
• Where climate change is expected to increase flood risk so that
some existing development may not be sustainable in the long-
term, seeking opportunities to facilitate the relocation of
development, including housing, to more sustainable locations.
2.8 Further to this, Paragraph 102 states that, if, following application of the
Sequential Test, it is not possible, consistent with wider sustainability
objectives, for the development to be located in zones with a lower
probability of flooding, the Exception Test can be applied if appropriate.
For the Exception Test to be passed:
• it must be demonstrated that the development provides wider
sustainability benefits to the community that outweigh flood risk,
informed by a Strategic Flood Risk Assessment where one has
been prepared; and
• a site-specific flood risk assessment must demonstrate that the
development will be safe for its lifetime taking account of the
vulnerability of its users, without increasing flood risk elsewhere,
and, where possible, will reduce flood risk overall.
2.9 Both elements of the test will have to be passed for development to be
allocated or permitted.
National Renewable Energy Action Plan (2009)
2.10 The United Kingdom is legally committed to achieving 15% of the UK’s
energy demand from renewable sources by 2020.
2.11 The action plan intends to achieve the 15% target through domestic
action.
2.12 It states that the UK could deliver about 30% of electricity, 12% of heat,
and 10% of transport energy from renewable sources by 2020
3. City Council Guidance and Policy
3.1 The City Council has produced a number of documents that are
relevant to the consideration of climate change issues and future
5policies for inclusion in the Local Plan. The main documents for
consideration are:
• Sustainable Community Strategy
• The Nottingham Growth Plan
• Low Carbon Pioneer City
• Energy Strategy
• The Municipal Waste Management Strategy
• Community Climate Change Strategy
• The Aligned Core Strategy – Proposed Submission
• The City Council Renewable Energy Requirement
• Guidance on the production of Energy Statements
The Sustainable Community Strategy (2009)
3.2 The Nottingham Plan to 2020 is the Sustainable Community Strategy.
It has three cross-cutting aims – green (which includes climate
change), aspiring, fair – and six strategic priorities:
1. Develop Nottingham’s international standing for science and
innovation, sports and culture;
2. Transform Nottingham’s neighbourhoods;
3. Ensure that all children and young people thrive and achieve;
4. Tackle poverty and deprivation by getting more local people into
good jobs;
5. Reduce crime, the fear of crime, substance misuse and anti-
social behaviour; and
6. Improve health and wellbeing.
3.3 Under strategic priority 1, one of the headline targets is to reduce the
City’s carbon emissions by 26% of 2005 levels by 2020. The 2005
baseline was 6.5 tonnes of CO2 per capita.
The Nottingham Growth Plan (2012)
3.4 The Nottingham Growth Plan was launched in 2012. It sets out the
strategy for economic growth within the City. One of the key sectors
6identified for delivery in the futures ‘clean technology’, which includes
companies providing technologies, goods and services that will enable
the UK’s transition to a low-carbon economy.
Low Carbon Pioneer City
3.5 Nottingham has been recognised by the Department of Energy and
Climate Change as a Low Carbon Pioneer City. This is in recognition of
Nottingham ambitious plans and investment in green infrastructure and
technologies, generation of low carbon jobs, and accelerate reductions
in emissions as well as its due to its role as one of the UK’s leading
cities in low / zero carbon generation. Being recognised as a Low
Carbon Pioneer City means that Nottingham will have access to
Government Funding streams to trial initiatives before they become
national schemes.
11.1 Nottingham so far has been successful in securing finding via Low
Carbon Pioneer Cities programme for Heat Strategy Master Planning,
which assesses the feasibility of district heating networks in the
Southern Gateway, Boots Enterprise Zone, and the Creative Quarter.
This funding is also looking at feasibility to develop pricing mechanisms
that offer incentives to develop and connect to heat networks.
3.6 Nottingham has also secured funding for Green Deal go early, which
has seen Nottingham deliver solid wall insulation, and Green Deal type
assessment and measures in social housing in Nottingham, as well as
workshops for the non-domestic sector to outline opportunities
available through Green Deal. To continue to secure funding, our
policies and strategies must
Energy Strategy (2010)
3.7 Lower carbon emissions should be achieved in line with energy
strategy targets
3.8 The Energy Strategy (2010-2021) provides an overarching framework
for the City’s plans, programmes and initiatives relating to sustainable
energy supply and use to 2021: cutting emissions, maintaining energy
security, maximising economic opportunities and protecting the most
vulnerable citizens.
3.9 The Action Plan prioritises the delivery of:
• A 26% reduction of carbon dioxide emissions against 2005
levels,
• 20% of the City’s own energy generated from low or zero carbon
sources by 2020.
73.10 To meet the national and local targets for heat and power, the strategy
sets out that the following will be required:
• More than doubling the size of the City district heating network;
• Development of a local biomass processing and transfer site;
• Significant capacity of new biomass CHP plant with associated
district heating;
• Consideration of a City anaerobic digester;
• Increase in low or zero carbon energy measures installed in the
domestic and commercial sector.
3.11 The strategy sets out the following energy vision for Nottingham:
• A city insulated against high energy prices;
• Secure, low carbon energy supply and services available for
businesses, public and domestic sector;
• A City prepared for climate change and peak oil;
• A City leading on growth in low carbon jobs, industries, services
and training;
• A City exemplar of integrated low carbon heat, power and
transport;
• An exemplar of neighbourhood community energy solutions; and
• A smart City where energy flows are planned, mapped and
monitored.
3.12 A detailed action plan sets out a significant number of actions through
which to meet the targets and aims. One of these actions is the
establishment of an Energy Park to support new and relocating energy
related businesses to base their operations here.
3.13 This strategy is currently under review, and a updated version will be
issued later in 2013
8The Municipal Waste Management Strategy (2010)
3.14 ‘A Waste-Less Nottingham – Waste Strategy 2010-2030’ sets out the
principles for the management of all Nottingham City’s municipal
waste.
3.15 The strategy aims to deliver the following five key actions:
• To produce the lowest amount of household waste per person of
any Core City in England;
• To increase the amount of reuse and recycling from just over a
third of our waste at present to the majority of household waste
(55+%);
• To transform the management of trade waste and other (non
household) wastes by providing new services and infrastructure
to reduce, recycle and recover energy;
• To save an additional 3-6000 tonnes of carbon dioxide per year
by recovering energy from waste, helping to combat climate
change and making the carbon savings by the waste
management service around 16-19000 tonnes of CO2/year, this
is 25-30% of the City Council emissions, e.g. from heating
buildings, vehicle usage, street lighting etc;
• To recover around 47 million kilowatt hours of energy from
waste using the Energy from Waste plant at Eastcroft with
associated District Heating and electricity generation scheme,
and by also processing food and other organic waste in a
technology known as Anaerobic Digestion.
Nottingham Community Climate Change Strategy (2012)
3.16 The Nottingham Community Climate Change Strategy (2012-2020) has
the following vision:
• A City where there is access to secure, affordable local energy,
where buildings make the most of the natural environment and
are adaptable to our future climate;
• A City with little congestion and vehicle use, and excellent public
transport, and where vehicles are fuelled by renewable energy;
• A City where you can buy local affordable food, where you have
a place to breathe and enjoy the best of what nature provides;
and
• A City where you have a secure career at the forefront of the low
carbon technology, within a thriving green economy.
93.17 The document recognises the links with other City Council strategies,
including planning policy and the Core Strategy / Local Plan.
3.18 It also recognises Nottingham City’s plans for investing in the low
carbon economy and, in particular, the existing Science City
designation and the promotion of an Energy Park in Bulwell.
3.19 The document seeks to achieve behavioural change in the community
and has set up a methodology through which to engage communities
identify their priorities and develop an action plan.
The City Council Renewable Energy Requirement (2007)
3.20 In May 2007, Nottingham City Council Executive Board approved an
interim standard requiring 10% of energy supplied in all developments
over 1,000 square metres to be gained from on-site or decentralised
renewable or low carbon energy source. This interim measure, which
is also known as a ‘Merton Rule’ was put in place to bridge the gap
until the adoption of the Core Strategy.
Energy Statements
3.21 In conjunction with the City Council Renewable Energy Requirement,
Nottingham City Council produced guidance on how to complete an
energy statement.
3.22 The key information required in these statements is:
• How much CO2 will the development emit annually in operation?
• Reference to how these emissions have been calculated?
• Which technology has (or technologies have) been chosen to
deliver a 10% reduction in annual carbon emissions?
• How have annual savings from the chosen technology (or
technologies) been calculated for this site?
The Nottingham City Aligned Core Strategy (2012)
3.23 The Nottingham City Aligned Core Strategy was published for a six
week period of formal representations from June 2012. Policy 1:
Climate Change sets out the following requirements:
1. All development proposals will be expected to deliver high levels
of sustainability in order to mitigate against and adapt to climate
change, and to contribute to national and local targets on
reducing carbon emissions and energy use. The onus will be on
developers to robustly justify why full compliance with policy
requirements is not viable or feasible.
Sustainable Design and Adaptation
102. Development, including refurbishment where it requires planning
permission, will be expected to demonstrate the following:
a) how it makes effective use of sustainably sourced resources and
materials, minimises waste, and water use. For residential
development, planned water use should be no more than 105
litres per person per day;
b) how it is located, laid out, sited and designed to withstand the
long and short term impacts of climate change, particularly the
effect of rising temperatures, sustained periods of high
temperatures and periods of intense rain and storms;
c) that the building form and its construction allows for adaptation
to future changes in climate; and
d) that the building form and its construction permits further
reduction in the building’s carbon footprint, where feasible and
viable.
Reducing Carbon Dioxide Emissions
3. Development must demonstrate how carbon dioxide emissions
have been minimised in accordance with the following energy
hierarchy:
a) Using less energy through energy efficient building design and
construction, including thermal insulation, passive ventilation
and cooling.
b) Ensuring all energy consuming equipment is as efficient as
possible, and well managed
b) Utilising energy efficient supplies – including connecting to
available and planned heat and power networks
c) Maximising use of renewable and low carbon energy generation
systems
4. Further guidance on how development should contribute to
reducing Carbon Dioxide emissions will be set out in
Development Plan Documents, where appropriate.
Decentralised Energy Generation
5. The extension of existing or development of new decentralised
renewable and low-carbon energy schemes appropriate for the
11plan area will be promoted and encouraged, including biomass
power generation, combined heat and power, and micro
generation systems. In line with the energy hierarchy, adjacent
new developments will be expected to utilise such energy
wherever it is feasible and viable to do so.
Flood Risk and Sustainable Drainage
6. Development proposals that avoid areas of current and future
flood risk and which do not increase the risk of flooding
elsewhere and where possible reduce flood risk, adopting the
precautionary principle, will be supported.
7. Where no reasonable site within Flood Zone 1 is available,
allocations in Flood Zone 2 and Flood Zone 3 will be considered
on a sequential basis.
8. Where it is necessary to apply the Exception Test within the
urban areas, the following factors will taken into account when
considering if development has wider sustainability benefits to
the community that outweigh flood risk:-
a) there are exceptional and sustainable circumstances for locating
the development within such areas, including the necessary re-
use of brownfield sites; and
b) the risk can be fully mitigated by engineering and design
measures.
9. Where appropriate, further guidance on the application of the
sequential and exception test will be set out in Local
Development Documents.
10. All new development should incorporate measures to reduce
surface water run-off, and the implementation of Sustainable
Urban Drainage Systems into all new development will be
sought unless it can be demonstrated that such measures are
not viable or technically feasible.
3.24 The document, along with the representations received, will be
submitted to the Secretary of State for consideration and, following this,
will be adopted, if found sound.
4. Other Relevant Publications and Tools
4.1 In addition to the formal Council publications set out above, a number
of other evidence base documents / tools have been developed,
including:
• Towards a Sustainable Energy Policy for Nottinghamshire
12• Aecom – Greater Nottingham Draft Climate Change Policy and
Evidence Base Review
• Nottingham City Local Carbon Framework – Energy Calculator
and Decision Support System
• Allowable Solutions for Tomorrow’s New Homes: Towards a
Workable Framework’
• Zero Carbon Strategies for tomorrow’s new homes
Towards a Sustainable Energy Policy for Nottinghamshire (2009)
4.2 The document was prepared by Nottinghamshire Sustainable Energy
Planning Partnership (NSEPP). As it was prepared in 2009, it was
based upon Planning Policy Statement 1: Planning for Sustainable
Development, and the companion guide, and Planning Policy
Statement 22: Renewable Energy. It also used the 2006 Building
Regulations as a baseline and included unregulated emissions in the
definition of Zero Carbon.
4.3 The key recommendation of this document was increased carbon
reduction targets above those required by building regulations, for both
domestic and non-domestic development, until 2016, when the zero
carbon requirement would come into force.
Greater Nottingham Draft Climate Change Policy and Evidence
Base Review (2012)
4.4 This document was produced by Aecom to assess the appropriateness
of the Aligned Core Strategy Climate Change policy and the Towards a
Sustainable Energy Policy for Nottinghamshire paper.
4.5 The document contained recommendations for changes to the Core
Strategy Climate Change Policy, many of which were included in the
publication version. The document suggested that the Towards a
Sustainable Energy Policy for Nottinghamshire papers robustness
could be brought into question on the basis that it included unregulated
emissions and was based upon 2006 building regulations
requirements.
Nottingham City Local Carbon Framework – Energy Calculator
and Decision Support System
4.6 In 2010, Nottingham City Council was awarded funding from the
Department of Energy and Climate Change (DECC) as part of the
Local Carbon Framework (LCF). There were two outputs from the
project – an ‘Energy City Tool’ and a ‘Decision Support Tool’. Both
13tools were developed by ESRI UK in conjunction with Nottingham City
Council.
4.7 The Energy City Tool, otherwise known as the Energy Calculator
enables citizens and other property owners such as commercial
businesses, to better understand potential opportunities and benefits
for renewable and low carbon energy investments in their properties.
This includes an overview of likely up-front costs and estimated
payback of taking up low carbon energy measures. The aim of the
Decision Support Tool, also called the Decision Support System (DSS),
is to help planners, and potentially other business users to locate
opportunities for implementing renewable and low carbon generation
technologies and assess their potential impact. More information on
these two tools is provided in Appendix 1.
Allowable Solutions for Tomorrow’s New Homes (2011)
4.8 In July 2011, the Zero Carbon Hub published ‘Allowable Solutions for
Tomorrow’s New Homes: Towards a Workable Framework’. To
comply with the 2016 Building Regulations, new zero carbon homes
will have to meet on-site requirements for Carbon Compliance
(achieved through energy efficiency of the fabric, the performance of
heating, cooling and lighting systems, and low and zero carbon
technologies). In addition, through Allowable Solutions (AS), they will
need to account for the carbon emissions that are not expected to be
achieved on site through Carbon Compliance. Carbon Compliance
and Allowable Solutions measures will both be needed to meet the
zero carbon Building Regulations in 2016, and each will need to be
submitted, checked and verified as part of Building Control approval1.
4.9 The key parts of the consolidated framework proposal presented in the
report were:
• A choice for Local Planning Authorities to develop a policy on
Allowable Solutions (Route A);
• The opportunity, when working to Route A (i.e. to Local Plans),
for housing developers to seek out best value for Allowable
Solutions via a Community Energy Fund or by Private contract
with a third party provider;
• The option of purchasing Allowable solutions from a Private
Energy Fund (Route B) when the Local Planning Authority does
not have an Allowable Solutions policy;
• A Verification and Certification Scheme to show that an
investment will achieve the required carbon emissions
reductions. The scheme will monitor Allowable Solutions
1
Source: Allowable Solutions for Tomorrow’s New Homes: Towards a Workable Framework, Zero Carbon Hub
(2011)
14delivery and release credits, certificates and finds in a timely
way to facilitate Allowable Solutions project development and
Buildings Regulations approval;
• A single Allowable Solutions Fund Holding to provide a secure
‘Bank’ for the Allowable Solutions investment flow.
4.10 It has been proposed that there will be three routes for Allowable
Solutions, on site, near site and off site.
Zero Carbon Strategies for Tomorrow’s New Homes
4.11 In February 2013, the Zero Carbon Hub published ‘Zero Carbon
Strategies for tomorrow’s new homes’. It sets out three strategic
design approaches for complying with the zero carbon definition:
• Approach A: Balanced
• Approach B: Extreme Fabric
• Approach C: Extreme LC (Low Carbon) Technologies
Permitted Development
4.12 Many low carbon technologies are permitted development on dwelling
houses, however, there are instances where they require planning
permissions, for instance, in a Conservation Area with and Article 4
Direction, or where there would be a material increase in the height or
appearance of the dwelling, e.g. through retrofitting solid wall insulation
or solar panels.
4.13 In instances where an installation is not permitted development,
planning permission must be sought. The types of development that
are classed as ‘Permitted Development’ can be found in the ‘General
Permitted Development Order2’.
5. Sustainable Building Standards
5.1 The Government has announced that all new homes must be zero
carbon from 2016 and are considering a similar approach for new non-
domestic buildings from 2019. There are several methods through
which a building’s sustainability can be increased, above and beyond
the Building Regulations requirements.
5.2 The Code for Sustainable Homes (the Code) is the national standard
for the sustainable design and construction of new homes. The Code
aims to reduce carbon emissions and create homes that are more
sustainable. It measures the sustainability of new homes against nine
2
http://www.legislation.gov.uk/uksi/2011/2056/made
15categories of sustainable design, rating the ‘whole home’ as a
complete package. It covers energy / CO2, water, materials, surface
water runoff (flooding and flood prevention), waste, pollution, health
and well-being, management and ecology.
5.3 The Code uses a six star rating system to communicate the overall
sustainability performance of new homes against the nine categories
and sets minimum standards for energy and water use at each level.
5.4 The Code is not mandatory, and there is no intention to make it
mandatory. The only circumstances where it can be required are:
• Where Local Authorities stipulate a requirement in their Local
Plans;
• Where affordable housing is funded by the Homes and
Community Agency (HCA), which requires homes to be built to
Code Level 3.
5.5 The Level 3 energy standard is incorporated into the 2010 Building
Regulations, the Level 4 energy standard will be incorporated in 2013
and the Level 6 energy standard will be incorporated in 2016.
5.6 The latest cost review for the Code for Sustainable Homes was
published in 2011. This document sets out the extra-over costs for
each dwelling type and development scenario with the Part L 2006
baseline3.
5.7 The most widely accepted standard for non-domestic development is
the Building Research Establishment Environmental Assessment
Method (BREEAM). Like the Code, it is not a statutory requirement,
however, Local Authorities may incorporate the standard into their
Local Plan.
5.8 For newly constructed non-domestic buildings (which include office,
industrial, retail, education, healthcare, prisons, law courts and
residential institutions), BREEAM looks at the following categories:
• Management
• Health and Wellbeing
• Energy
• Transport
• Water
3
http://www.communities.gov.uk/publications/planningandbuilding/codeupdatedcostreview
16• Materials
• Waste
• Pollution
• Innovation
5.9 BREEAM scores are defined as – outstanding, excellent, very good,
good, pass and unclassified. The latest guidance on BREEAM new
construction was published in 2011.
6. Climate Change Mitigation
6.1 Mitigating means to alleviate some of the force or intensity of
something. In terms of climate change, any activity which reduces the
effects of climate change, such as energy use reduction, can be said to
‘mitigate’ climate change.
6.2 Given the context set out in Sections 2 to 5 and the energy hierarchy
contained within the Aligned Core Strategy Policy, the issues
surrounding climate change mitigation considered in this Background
Paper are:
• Energy Efficiency: Solid Wall Insulation
• Utilising Energy Efficient Supplies: District Heating
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Wind Turbines
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Combined Heat and Power
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Solar Thermal
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Biomass
• Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Heat Pumps
• Carbon Offsetting
Energy Efficiency: Solid Wall Insulation
6.3 The majority of energy efficient measures that are retrofitted do not
require planning permission, however, as set out above, there are
17instances where this is not the case. Retrofitting solid wall insulation is
one instance where planning permission may be necessary.
6.4 Where planning permission is required, planning policies should be in
place by which to judge any planning application.
Utilising Energy Efficient Supplies: District Heating
6.5 Aligned Core Strategy Policy 1 sets out that energy efficient supplies
should be utilised where possible, including connection to available
heat and power networks.
6.6 Nottingham City currently has an extensive district heating network,
which is run by EnviroEnergy via heat received from the Eastcroft
Energy from Waste facility.
6.7 The existing district heating network runs into St Ann’s and the Lace
Market, and was recently extended to the south of the City Centre.
6.8 The existing network has capacity at many points, however, it is not
possible to connect at all points in the network. Consultation with
EnviroEnergy should establish whether it is possible to connect through
development.
6.9 Aligned Core Strategy Policy 1 makes it clear that new developments
are requested to connect to existing schemes where feasible and
viable to do so. However, many schemes expand over time and, whilst
it may not be possible to connect to a district heating scheme at
present, it may be possible to connect to a scheme in the future.
Therefore, new developments should be designed so they are capable
of connecting to a district heating scheme in the future.
Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Wind Turbines
6.10 Aligned Core Strategy Policy 1 sets out that the use of renewable and
low carbon energy generation systems should be maximised.
6.11 The development of the Decision Support System (DSS) energy
mapping exercise that was undertaken in Nottingham established
parameters for which it considered wind technology suitable. However,
whilst it sets out ‘suitable, possible and unsuitable’ locations for wind
turbines, the following should be taken into consideration:
• The tool only details the appropriateness of medium scale wind
turbines
• Medium scale is defined as 100 to 500kw rating
• Other scales of turbine have not been assessed
18• The tool is a guide only and should not be taken as a definitive
answer as to whether wind turbines are suitable in a particular
location, or whether they would be granted planning permission
in a particular location.
6.12 The following table defines what is unsuitable, possible and suitable
(as mapped in the tool):
Classification Definition
Unsuitable Any areas less than 80m away from buildings, unless
only 1 building is affected.
Possible Any areas between 80 -100m away from buildings, or
less than 80m from a building if only 1 building is
affected.
Suitable Any areas greater than 100m away from buildings.
6.13 The following constraints were taken into consideration when
developing the model:
Dataset Constraint parameters
Inland Water Exclude areas
Electricity Transmission lines Exclude areas within 25m
Masts Exclude areas within 25m
Pylons Exclude areas within 25m
Roads Exclude areas within 15m
Railways Exclude areas within 15m
Scheduled Ancient Monuments Exclude areas within 80m
SSSI Exclude areas within 100m
Local Nature reserves Exclude areas within 100m
Ancient Woodland Exclude areas within 100m
BioSincs Exclude areas within 100m
Listed Buildings Exclude areas within 100m
Conservation Areas Exclude areas within 100m
GeoSincs Exclude areas within 100m
Mobile Phone Operators Exclude areas within 25m
Tram line Exclude areas within 15m
Wind Speed (10m above land) Exclude areas with a wind speed
lower than 4.5m/sec
6.14 Whilst the energy map does not consider mircogeneration, small or
large scale turbines, it is still important to establish planning policies
through which to consider any planning application.
6.15 Microgeneration schemes (less than 1.5kw) are permitted development
in most instances. Small scale is defined as 1.5 to 100kw and large
scale is defined as over 500kw. The guidelines for minimum distances
are 2.5kw to 10kw turbine up to 100m, 10kw to 50kw turbine over
100m from the nearest line of sight.
196.16 Regardless of the minimum distances that are required to establish
suitability in principle, there are other factors that are required in order
to demonstrate the acceptability of a wind turbine. These include the
impact on local amenity in terms of:
• Noise
• Shadow flicker and
• Visual dominance
6.17 Other potential relevant impacts can include:
• Impact on historic environment
• Ground conditions
• Natural environment
• Air safety (electro-magnetic interference) and
• Transport
6.18 It is important that any planning policy addresses the different
acceptable distances for each size of wind turbine, as well as the other
potential impacts.
Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Combined Heat and Power
6.19 The Decision Support System (DSS) energy map also shows the
potential heat loads within the City, i.e. areas within the City where
there are facilities that have large heat requirements. This is an
important aspect of the tool, as it enables the identification of areas
where a Combined Heat and Power (CHP) scheme may be needed.
This is not to say that a scheme would not be suitable in other
locations, but that the development of such schemes should be
preferred within these areas as there is an identified use for the excess
heat. Planning policies should try to locate CHP facilities within those
areas where there is an identified need where possible.
6.20 Combined heat and power schemes can take many forms, and include:
• Biomass
• Gas
6.21 Energy from Waste plants, such as the Eastcroft facility, can also
contribute to CHP and district heating. Waste planning is, however, a
20separate matter and documents are produced jointly with the County
Council.
Maximising Use of Renewable and Low Carbon Energy
Generation Systems: Solar Thermal, Biomass and Ground / Air
Source Heat Pumps
6.22 The Nottingham Energy Strategy has targets for the installation of solar
thermal hot water systems, biomass systems, and heat pumps
6.23 These technologies should be a viable option where it is not possible to
connect to the district heating network.
6.24 These measures should be a viable alternative to grid supplied natural
gas, and evidence will be provided where these measures cannot be
installed.
6.25 Further information on renewable technologies can be found at
Nottingham Energy Partnership at
http://www.nottenergy.com/renewables/.
Carbon Offsetting
6.26 Whilst the Government has not produced final guidance relating to
Allowable Solutions, the guidance produced to date indicates that such
a scheme would be used to account for the carbon emissions that are
not expected to be achieved on site through Carbon Compliance, i.e.
Allowable Solutions will be required in addition to onsite measures to
deliver zero carbon by 2016.
6.27 The proposed Core Strategy policy does not require a contribution to
carbon reduction above building regulations, therefore, there will be no
need to contribute to a carbon offsetting scheme prior to the anticipated
introduction of zero carbon in 2016
7. Locally Derived National Standards
7.1 The Code for Sustainable Homes is the nationally recognised
sustainability standard for housing, whilst BREEAM is the nationally
recognised sustainability standard for other forms of development
7.2 Whilst there is no requirement to adopt a certain level of these
standards, planning authorities may do so through planning policies,
where justified. The AECOM review of current policy practice
highlighted examples where authorities had used standards in policies.
7.3 Viability can be a significant issue when prescribing such standards.
The ‘Nottingham Core Affordable Housing Viability Assessment: Final
Report’ raised questions regarding the viability of affordable housing
within some areas of Nottingham.
217.4 It is likely that including a policy requirement to provide a certain level
on the Code for Sustainable Homes could have an impact on the
viability of development, in some areas. However, this is not to say
that a policy could not set out a requirement, subject to site by site
viability and technical feasibility.
7.5 Similarly, requiring a particular level of BREEAM could have an impact
on the viability of development but a policy requirement could be put in
place making any such requirement subject to viability or technical
feasibility.
7.6 When developing site specific allocations, consideration should be
given to whether any specific requirements can be established, rather
than applying the general Development Management policy to the
allocation.
8. Climate Change Adaptation
8.1 Adaptation means responding to the impact of a changing climate, i.e.
seeking to lower the risks posed by the consequences of climate
change through incorporating measures in new development, such as
sustainable drainage infrastructure and planting extra trees.
8.2 The Aligned Core Strategy Publication (June 2012) sets out that
development should demonstrate:
• how it is located, laid out, sited and designed to withstand the
long and short term impacts of climate change, particularly the
effect of rising temperatures, sustained periods of high
temperatures and periods of intense rain and storms; and
• that the building form and its construction allows for adaptation
to future changes in climate.
8.3 Given the context set out in Sections 2 to 5 and the energy hierarchy
contained within the Aligned Core Strategy Policy, the issues
surrounding climate change adaptation considered in this Background
Paper are:
• Green Infrastructure
• Sustainable drainage
• Flood Risk
Green Infrastructure
8.4 Green Infrastructure (GI) is the strategically planned network of
multifunctional green spaces and other environmental features. It may
22run across Local Authority boundaries and the Greater Nottingham
Aligned Core Strategies sets out policies for the promotion of GI and
maps the strategic network.
8.5 Mapping GI, or the potential for GI, can both help protect the existing
features, as well as enabling the expansion of the network through
development.
Sustainable Drainage Systems (SuDS)
8.6 SuDS are defined as management practices and control systems
designed to drain surface water in a more sustainable way than
conventional systems. Reducing and decreasing the amount of surface
water run-off helps to manage water resources more sustainably and
helps meet national planning policy which promotes the control of
surface water run-off as near to the source as possible. SuDS also
have a role in improving the quality of the run-off from a development
and enhancing nature conservation/biodiversity, particularly in densely
built up urban areas.
8.7 SuDS schemes can vary in size and composition and can be used in
most developments where the flow of water would be large enough to
be readily reduced. Preventative measures, such as basic good
housekeeping, are always the first stage of the SuDS approach to avert
or reduce pollution and run-off quantities. Techniques which can be
incorporated in developing SuDS vary from the relatively
straightforward such as soakaways and reducing areas of impervious
surfaces on a site through to green roofs and using swales, basins,
infiltration trenches, filter drains and drainage ponds to collect and
store water.
Flood Risk
8.8 Policy 1 of the Aligned Core Strategy seeks to allocate sites away from
areas of greatest flood risk, i.e. it applies a sequential approach and,
where necessary, the exception test.
8.9 The National Planning Policy Framework (NPPF) provides further
guidance on the allocation and granting planning permission of sites
within areas of flood risk.
8.10 In accordance with the NPPF, where relevant, planning applications for
new development should be informed by a site specific flood risk
assessment, following the sequential test and, if required the exception
test.
9. Sustainability Statements
9.1 Sustainability statements are often produced in order to assess the
sustainability measures that are incorporated into development and
23ensure that they meet policy requirements. At present, Nottingham
City Council requires ‘Energy Statements’ to be produced to ensure
that development provides the 10% renewable energy requirement, or
equivalent from other sources.
9.2 National standards, such as the Code for Sustainable Homes and
BREEAM, require that a statement should be produced in order to
assess how a development meets the requirements of a given level.
Therefore, if these standards are required, it will not be necessary to
require a separate sustainability statement.
9.3 If, however, these standards are not required, then it may be necessary
to require sustainability statements to demonstrate how the
requirements of the Greater Nottingham Aligned Core Strategies and
the Local Plan have been met.
10. Viability and Feasibility
10.1 Placing additional requirements on development can add to the cost of
a scheme and, in some cases, may make it unviable. Similarly, it may
not be technically feasible to provide some measures onsite.
10.2 In order to ensure the deliverability of Local Plans, undue burdens
should not be placed on development in accordance with the NPPF. In
order to ensure compliance with the NPPF, a plan-wide viability
assessment will be undertaken, following consultation on the Preferred
Option.
11. Conclusions
11.1 Nottingham is recognised as being a Low Carbon Pioneer City, due to
its role as one of the UK’s leading cities in low / zero carbon
generation. It has secured funding in the past due to this and, in the
future, will be in a good position to receive further funding. The desire
for Nottingham to develop low carbon employment is set out in the
Growth Plan, which seeks to develop ‘clean technology’, and also the
Sustainable Community Strategy (SCS), in which ‘green’ is one of the
key themes.
11.2 To date, there have been a number of successful low carbon /
sustainable developments and initiatives within Nottingham, including:
• 16.7% reduction in City CO2 between 2005 and 2009
• Most energy self sufficient City in the UK, with 11% of heat and
power generated from renewables and waste
• Solar Photovoltaic Panels: over 1800 installed on social housing
24• Founding member of the Nottingham Declaration on Climate
Change
11.3 Nottingham also has a number of unique assets, including, an
extensive existing district heating network.
11.4 Based upon this context, the City is therefore in a good position to
provide higher levels of sustainable development in the future than
other UK cities and planning policy is one of the key tools for delivering
this sustainable development.
11.5 It is, therefore, recommended that, in addition to the Core Strategy
policies, future planning policies should seek a higher level of
sustainability in development. Measures should include:
• Incorporation of the Code for Sustainable Homes into policy;
• Incorporation of BREEAM into policy;
• Seeking Allowable Solutions contributions in policy;
• Setting out requirements for renewable energy development in
policy;
• Seeking connection to, and expansion of, the district heating
network through policy;
• Setting our policies surrounding flood risk and climate change
adaptation.
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