Renewable energy

Policy PODM18: Energy demand and performance of new buildings (including extensions)

  1. The expected energy use of buildings must be as low as possible; the building regulation standards are the minimum. Applicants will be required to demonstrate what measures they have taken to achieve more energy efficiency.

Reducing energy requirements of new build

  1. Developments are required to meet or reduce at least 10% of their predicted energy requirements, using the following hierarchy:
    1. Reduce the overall energy demand in the first place. Development is required to take a ‘fabric first’ approach and reduce overall energy demand through its design, materials, layout and orientation.
    2. Energy efficient and conservation measures. Proposals are then also required to maximise the use of energy efficiency and energy conservation measures; and
    3. Decentralised and renewable or low-carbon sources for any residual amount.
  2. Buildings designed to Passivhaus standard (or equivalent) would generally be encouraged, subject to other relevant policies of the Plan.

Reducing Energy Consumption in Existing Buildings

  1. For all development proposals which involve the change of use or redevelopment of a building, or an extension to an existing building, the applicant is encouraged to consider all opportunities to improve the energy efficiency of that building including the original building, if it is being extended.
  2. Where the building pre-dates 1919[73], methods of improving energy efficiency should be carefully considered so that they are not detrimental to the fabric of the building.

Heritage Assets

  1. Planning permission and, where relevant, listed building consent, will be granted for works required to improve the energy performance of designated and non-designated heritage assets where it complies with other relevant policies and can be clearly demonstrated that this is compatible with all of the following:
    1. The heritage asset’s character and appearance;
    2. The heritage asset’s special architectural or historic interest;
    3. The long-term conservation of the built fabric; and
    4. The wider setting of the heritage asset.

Energy Statement

  1. An energy statement which demonstrates the approach is required to accompany planning applications.

Reasoned Justification

The Climate Change Act 2008 legislates for a 34% reduction in greenhouse gas emissions against 1990 levels by 2020, and an 100% reduction by 2050. The UK government has set the climate change target into law to reduce emissions by 78% by 2035 compared to 1990 levels. The incorporation of renewable energy generation technologies and energy efficiency measures into the design of new development can make a significant contribution to achieving these targets.

The policy approach seeks development that is designed to reduce energy demand in the first place, then to use energy efficiency improvements, and finally to use renewable energy technologies where appropriate.

On-site provision will normally be the preferred mechanism for decentralised and renewable or low-carbon sources. However, off-site schemes will be permitted where it would result in the generation of a greater amount of energy or would have a lesser visual/environmental impact. Planning conditions and/or obligations will be used to make sure the energy infrastructure comes on-line before the development is occupied.

Addressing climate change is also about making improvements to resource and energy efficiency.

Future Homes Standard

Government is committed to improving the energy efficiency of new homes through the Building Regulations system through the Future Homes Standard (FHS). The introduction of the FHS will ensure that an average home will produce at least 75% lower CO2 emissions than one built to recent/current energy efficiency requirements. Homes built under the FHS will be ‘zero carbon ready’, which means that in the longer term, no further retrofit work for energy efficiency will be necessary to enable them to become zero-carbon homes as the electricity grid continues to decarbonise. However, the FHS is only proposed to take effect from 2025 and there is no legal guarantee of even that date being met. There has been an uplift in Building Regulations as a step towards FHS having taken place in 2022 which changes Part L of the Building Regulations to reduce carbon emissions by 31% for new homes through a set of reformed insulation and air tightness requirements.

Design principles

The following design expectations should be considered and in the following order:

  • Orientation of buildings – such as positioning buildings to maximise opportunities for solar gain, and minimise winter cold wind heat loss whilst also addressing the risk of overheating;
  • Form of buildings – creating buildings that are more efficient to heat and stay warm in colder conditions and stay cool in warmer conditions because of their shape and design;
  • Fabric of buildings – using materials and building techniques that reduce heat and energy needs. Ideally, this could also consider using materials with a lower embodied carbon content and/or high practical recyclable content;
  • Heat supply – net zero carbon content of heat supply (for example, this means no connection to the gas network or use of oil or bottled gas);
  • Renewable energy generated – generating enough energy from renewable sources onsite (and preferably on plot).

Passivhaus

Where Passivhaus certification is being sought, a ‘pre-construction compliance check’ completed by a Passivhaus certifier will be required, secured by condition and upon completion, a Quality Approved Passivhaus certification for each dwelling/ building will be required.

Retrofit

The UK’s Committee on Climate Change has identified retrofitting existing homes as one of five priorities for government action (CCC, 2019). The policy encourages applicants to improve the energy efficiency of the existing building if appropriate to do so.

Heritage assets

Historic England (Heritage Counts) research shows that sympathetic refurbishment and retrofit can reduce the carbon emissions of historic buildings by over 60% by 2050. The Heritage Counts research also demonstrates that the speed at which carbon is reduced in buildings has a greater impact than the scale of retrofit showing that the sooner actions are taken, the more effectively we can address carbon in buildings.

The retrofit of historic buildings to enhance their energy efficiency would be welcomed subject to it meeting the tests. The Authority will assess the impact of the adaptations, taking regard of the significance of the historic asset and the character, historic interest, setting and integrity of the elements of the asset likely to be affected[74]. The ‘whole-house approach[75]’ is encouraged for use in historic buildings and it is likely that the measures taken in a listed building will need to be bespoke, taking into account the construction and special characteristics of the building.

Guidance

Further guidance on designing new development to minimise energy consumption is provided in the Broads Authority’s Sustainability Guide[76].

The Broads Authority may want to consider the Net Zero Carbon Toolkit when looking at the design of new homes and the retrofitting of existing homes: www.greensuffolk.org/net-zero-carbon-toolkit-housing/.

Reasonable alternative options

No specific policy

Original policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: Preferred Option. 4 positives. 0 negatives. 0 ?

B: Original policy. 4 positives. 0 negatives. 0 ?

C: No specific policy. 0 positives. 0 negatives. 4 ?

How has the existing policy been used since adoption in May 2019?

This policy has been used on occasion, but the Annual Monitoring Reports have identified that it needs applying more consistently.

Why have the alternative options been discounted?

With a changing climate, the cost-of-living crisis and energy security issues, a policy which seeks energy efficiency is favoured. The changes to the original in relation to encouraging retrofit are preferred for the same reasons.

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Policy PODM19: Renewable and low carbon energy

  1. Renewable/low carbon energy proposals shall be of a scale and design appropriate to the locality and shall not, either individually or cumulatively, have an adverse impact on the distinctive landscape, cultural heritage, biodiversity, recreational experience or special qualities of the Broads or the local amenity[77]. The Broads Landscape Sensitivity Study[78] (or successor document) will provide guidance on this. The impact of ancillary infrastructure, including power lines, onshore infrastructure for offshore wind turbines/farms, sub-stations, storage buildings, wharves and access roads, will form part of the evaluation.
  2. Wherever possible, renewable energy proposals should utilise previously developed sites and result in environmental improvements over the current condition of the site.
  3. The developer will also be required to restore the land to its original use and remove any renewable energy equipment when it is redundant.
  4. Proposals for solar farms on agricultural land are required to use poorer quality agriculture land.
  5. Battery storage proposals will need to address relevant policy considerations, such as landscape impact and impact on the special qualities of the Broads.

Reasoned Justification

It is widely acknowledged that tackling the challenges posed by climate change will necessitate a radical increase in the proportion of energy generated from renewable sources. The UK Renewable Energy Strategy (2009) includes the UK’s legally binding renewable energy target of 15% by 2020[79]. This is part of a wider suite of strategies within the UK Low Carbon Transition Plan. The Authority must ensure that the causes of climate change are addressed at the local level. This will, however, need to be undertaken within the context of the special circumstances pertaining to the Broads.

Landscape impact of proposals

A range of renewable energy technologies may be suitable for the Broads, including solar photovoltaic cells, ground and water and air source heat pumps and wind turbines[80]. However, the sensitivity of the Broads landscape means that large-scale renewable energy developments are generally inappropriate. Where wind turbines, solar photovoltaics cells or other large-scale renewable energy developments are proposed, applications should be accompanied by a landscape and visual impact assessment of the impact of the development from a full range of viewpoints, including from the waterways, and is completed in accordance with the Guidelines for Landscape and Visual Impact Assessment published by the Landscape Institute and Institute of Environmental Management and Assessments[81].

Wind turbines

The NPPF 2023 (paragraph 163, footnote 58) says: ‘Except for applications for the repowering and life-extension of existing wind turbines, a planning application for wind energy development involving one or more turbines should not be considered acceptable unless it is in an area identified as suitable for wind energy development in the development plan or a supplementary planning document; and, following consultation, it can be demonstrated that the planning impacts identified by the affected local community have been appropriately addressed and the proposal has community support’.

The Landscape Sensitivity Study concluded that wind turbines are tall structures that have the potential to detract from the mainly open and low-lying character of the Broads landscape, particularly when they are in large groups or sited in prominent locations.

For wind turbines to come forward in the Broads, suitable areas need to be identified in the Local Plan. We are looking into this, but the Landscape Sensitivity Study identifies that the Broads is sensitive to wind turbines.

Specific Question 2: Do you have any thoughts on the suitability of wind turbines in the Broads?

Any deployment of battery storage is highly likely to be closely associated with either solar energy systems or wind energy, and therefore the suitability would be restricted to where these technologies would be considered appropriate.

Renewable/low carbon proposals outside of the Broads

The Authority will not support proposals for renewable energy development that are sited outside but close to the Broads executive boundary that would have an adverse impact on the Broads environment, the special qualities of the Broads and the special landscape setting and character.

Reasonable alternative options

No policy

Original policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: Policy – Preferred Option. 11 positives. 0 negatives. 1 ? Overall, positive.

B: No policy. 0 positives. 0 negatives. 12 ?

C: Original policy. 11 positives. 0 negatives. 1 ?Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has been used and applications have been determined in accordance with it.

Why have the alternative options been discounted?

Given the special qualities of the Broads, a policy is preferred. The changes that relate to quality of agricultural land and the special qualities of the Broads make the policy stronger.

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