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Report for

Mr John Wood

Director of Environment

Hertfordshire County Council

County HallHertford

SG13 8DN

Main Contributors

Alan Chaplin

Jenni Heaton

Issued by

Alan Chaplin

Approved by

Entec UK Limited

Atlantic HouseImperial WayReading RG2 0TDEnglandTel: +44 (0) 1189 036061Fax: +44 (0) 1189 036261

Hertfordshire CountyCouncil

HertfordshireEnvironmental Forum

HertfordshireTechnical ChiefOfficers Association

HertfordshireRenewable EnergyStudy

Planning Considerations

July 2005

Entec UK Limited


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s:\common\hannah\energy\entec planning considerations report (july 2005).doc July 2005

Executive Summary

The achievement of sustainable development will require action by many people and

organisations. It will require radical changes in the way we plan and make decisions; in

the way we live and carry out our business. Facing up to these radical changes will

strengthen us as a region now and benefit generations to come. (Source: The East of

England Sustainable Development Framework, October 2001, The East of England

Regional Assembly and The East of England Sustainable Development Round Table)

Entec UK Ltd was engaged by the clients, Hertfordshire County Council, Hertfordshire

Environmental Forum (HEF) and the Hertfordshire Technical Chief Officers Association

(HTCOA), to undertake research to identify the realistic potential for renewable energy

development in the county and to explore the opportunities and constraints to this form of

development.

PPS22 sets out the Governments national land use planning policies for renewable energy. The

ODPM has also produced Planning for Renewable Energy: A Companion Guide to PPS22

offers practical advice as to how these policies can be implemented on the ground. The

Companion Guide also includes examples of best practice.

The East of England Regional Spatial Strategy (December 2004) is currently undergoing review

and a draft version was the subject of consultation from 8 December 2004 to 16 March 2005.

An Examination in Public is scheduled to begin on 13 September 2005.

Renewable energy is used to describe the various ways in which continuous energy flows that

occur naturally in the environment, from the sun, wind, oceans, plants and the fall of water, are

harnessed. Energy from waste is also referred to as renewable energy where it emanates fromwithin the earth.

National policy is to encourage the development and use of renewable energy resources where

they have prospects of being economically viable and environmentally acceptable. The aim is

to reduce the adverse environmental impacts of producing energy from fossil fuels, notably

carbon dioxide (CO) emissions. In addition, renewable energy sources can also contribute

towards the greater diversity and security of the nations energy supply.

The accompanying technical report on renewable energy in Hertfordshire, which has also been

prepared by Entec, concludes that there is the technical potential within Hertfordshire to achieve

the levels of renewable energy production proposed in the East of England Sustainable

Development Round Table Study.

If the 2010 regional targets are to be met, onshore wind must be encouraged, along with all

other forms and scales of renewable energy schemes. In order to meet the 2020 targets,

emerging technologies, such as biomass, will be needed, although the long initiation periods for

bringing such development into operation means that proposals must be brought forward now.

Renewable energy in new development will only make a marginal difference to meeting the

regional targets, but would help encourage more affordable and a greater choice of renewable

energy technologies in the market place, as well as possibly raising public awareness.


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Planning applications for renewable energy projects should be assessed against specific criteria

set out in local development documents, as well as the East of England Regional Spatial

Strategy.

Local planning authorities may include policies in local development documents that require a

percentage of the energy to be used in new residential, commercial or industrial developmentsto come from on-site renewable energy developments.

The opportunity for incorporating renewable energy projects in all new development should be

considered.

Authorities will need to have a clear understanding of energy usage in their areas in order to set

clear baselines and be able to track progress against effective targets.

The options for the planning system in Hertfordshire are set out in terms of three broad ways in

which the planning system might engage in the future in the promotion of renewable energy:

Business as usual;

What is possible; and

Extending the case for renewables.

Business as usual is not considered to be an option if Hertfordshire and the East of England

intend to move towards, yet alone reach, their own targets.

In terms of what is possible, there is the technical potential within Hertfordshire to achieve the

levels of renewable energy production proposed in the East of England Sustainable

Development Round Table Study.

The last option, extended, provides the basis for blue sky thinking by the local authorities in

particular, which might provide a convenient way of kicking off the Local DevelopmentFrameworks that are due to prepared over the next few years.

A number of possible actions and considerations flow from the extended position:

Renewable Energy in New Development

The application of renewable energy as a requirement to (virtually) all new

development, particularly for residential development, appears to offer an

opportunity that should be seriously considered if there is a serious intent to meet

renewable energy targets at the regional and county levels

If this approach was to be adopted, the local authorities would need to think about

seeking to remove, or at least modify, in Policy ENV8, sub-paragraph (c), of thedraft East of England Plan the words above the same threshold, in order to

ensure that a regional policy allows local development documents to require all

developments (or at least all residential development) to incorporate equipment for

renewable power generation so as to provide at least 10% of their predicted energy

requirements.

If this was introduced into the development plan via the new Local Development

Frameworks, possibly just over half of the new dwellings proposed for

Hertfordshire in the current regional plan period to 2021 could become the subject


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of such a renewable energy requirement, so long as the RSS confirmed such an

approach and so long as the local planning authorities introduced the requirement

as a co-ordinated group.

Community Heating and CHP

Community heating schemes and combined heat and power are subjects that thelocal authorities should research in detail in due course if it is considered that there

may be future opportunities for these forms of energy production and distribution,

particularly with regard to the larger scale of developments that will need to be

considered in the county.

Wind Energy

With regard to wind energy, the local authorities should not only consider aiming

for at least 5 additional wind turbines in the county, but also whether the

community is willing to extend its ambitions to accommodating and actively

encouraging around 30 large wind turbines in Hertfordshire.

Planning Application Statements

With regard to energy consumption statements, local planning authorities should

consider whether they should specifically seek written evidence from applicants on

an examination of the options for different heating and power systems when certain

types of development proposals over a particular size are submitted as planning

applications.


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Contents

1. Introduction 1

1.1 The Study 1

1.2 Study Objectives 1

1.3 The Renewable Energy Options Report 1

1.4 Structure of the Report 2

1.4.1 Sections 2

1.4.2 Appendices 3

1.5 The Planning System 31.5.1 National Planning and Policy Statements 3

1.5.2 Regional Planning and Regional Spatial Strategies 4

1.5.3 Local Development Frameworks 4

1.5.4 The Development Plan and the Development Control System 5

2. The National Planning Context 7

2.1 Planning Policy Statement 22 (PPS22): Renewable Energy 7

3. The Regional Planning Context 11

3.1 East of England Regional Spatial Strategy (RSS) 11

3.2 East of England Sustainable Development Round Table,2001 11

3.3 East of England Draft Plan, December 2004 11

3.4 Regional Planning advice for Local DevelopmentFrameworks 13

3.5 Regional Planning Advice on Location 14

3.5.1 Sustainable Communities Plan growth areas 15

3.5.2 Settlements outside growth areas 15

3.5.3 Non-designated landscapes 15

3.5.4 Designated landscapes 15

3.6 Hertfordshire Structure Plan 16

4. The Local Planning Context 17

4.1 PPS12 on LDFs 17


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5. Planning Issues 19

5.1 The Different Forms of RE and their Implications forPlanning 19

5.2 Wind power 195.2.1 Project Initiation 19

5.2.2 Evaluation 20

5.2.3 Implementation 21

5.2.4 Maintenance 21

5.2.5 Decommissioning 21

5.2.6 Smaller Scale Turbines 22

5.2.7 Domestic wind turbines 22

5.3 Biomass energy 22

5.3.1 Co-firing 23

5.3.2 Large-scale power generation 235.3.3 Small to Medium-scale power generation and CHP schemes 25

5.3.4 Power generation from waste 25

5.3.5 Transport fuels 26

5.3.6 EIA requirements 26

5.4 Water power 27

5.5 Solar power 27

5.6 Landfill gas 28

6. Renewable Energy Development in Hertfordshire 29

6.1 The Potential for RE in Hertfordshi re 29

6.2 Meeting the Targets 29

7. Local Planning Approach 31

7.1 The Vision 31

7.2 Sustainability and Plan Objectives 31

7.3 The Wider Context 34

7.4 Woking Borough Council 34

7.5 Cornwall 35

7.5.1 Cornwall Structure Plan 36

7.5.2 The District Local Plans 36

8. Local Planning Policies 39

8.1 Local Planning Policies 39


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8.2 Good Practice 39

8.3 The Assessment of Policies 40

8.4 A General Cri ter ia-based Pol icy 42

8.4.1 Government Guidance 42

8.4.2 Woking Borough Local Plan 42

8.4.3 Penwith Local Plan 43

8.4.4 Rochford District Local Plan 43

8.4.5 Caradon Local Plan 44

8.4.6 Oldham Unitary Development Plan 44

8.4.7 London Borough of Merton 45

8.4.8 Recommended Policy Wording Checklist 46

8.5 A Policy for Renewable Energy in New Development 47


8.5.2 Planning Officers Society 478.5.3 Woking Borough Council 48

8.5.4 London Borough of Merton 48

8.5.5 Oldham Metropolitan Borough Council 49


8.5.7 South East Plan Opinion Poll 52

8.6 A Policy Support ing Small -scale Renewable Energy 53


8.6.2 Community Involvement 53

8.6.3 Community-based Projects 54

8.7 Policies on particular types of Renewable Energy 548.7.1 Government Guidance 54

8.7.2 Penwith Local Plan 54

8.7.3 Oldham Unitary Development Plan 55

8.7.4 Caradon Local Plan 56


8.8 Policies that promote a form of Renewable Energy in anArea 58


8.8.2 Regional and Sub-Regional Considerations 59

8.9 SMART Polic ies 59

9. Planning Appl ications 61

9.1 Planning Applications 61

9.2 Housing Developments 62

9.3 Development Control Issues 63

9.4 Environmental Impact Assessments 64


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1. Introduction

1.1 The Study

Entec UK Ltd was engaged by the clients, Hertfordshire County Council, Hertfordshire

Environmental Forum (HEF) and the Hertfordshire Technical Chief Officers Association

(HTCOA), to undertake research to identify the realistic potential for renewable energy

development in the county and to explore the opportunities and constraints to this form of

development.

1.2 Study Objectives

The objectives of the study were to:

! develop a clear understanding of the constraints and barriers to renewable energy project

development;

! develop realistic renewable energy targets with broad agreement from the key stakeholders;

! identify locational and technological criteria for assessing proposed projects;

! develop scenarios to aid the understanding of policy options and potential implications for

the county;

! develop model policies to inform local development frameworks and development control

decisions;

! improve understanding between planners, developers, potential developers and other key

stakeholders;

! present clear advice on how to maximise the potential direct and indirect benefits of

renewable energy developments; and

! maximise the training potential of this exercise for members and officers in the county.

1.3 The Renewable Energy Options Report

This report should be read with the Renewable Options Report which details the technical

background to renewable energy in Hertfordshire. Together, this and the Options report

represent the response to the objectives of the study and its brief. The Renewable Options

Report was first circulated as an interim consultation document in January 2005 when it

provided key information to stakeholders, illustrated what renewable energy could look like in

Hertfordshire, and identified what barriers are needed to be overcome to enable renewable

energy to happen. The January 2005 report was then updated following a workshop for

stakeholders and published in the form of a separate companion report, entitled Renewable

Energy Options for Hertfordshire.


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Section 7 is an introduction to the local planning approach that authorities can consider,

including some examples of more general approaches to energy matters that certain local

authorities have adopted.

Section 8 sets out an analysis of possible approaches to the construction of local planning

policies, including examples from other authorities. The report provides a framework for localplanning authorities to be able to consider and construct their own wording and set of policies as

part of their Local Development Framework process.

Section 9 provides some basic guidance on dealing with planning applications in relation to

renewable energy proposals, including an example of advice to planning authorities in London.

Section 10 deals briefly with question of monitoring and the systems that will need to be

considered in the future.

Section 11 concludes by examining the options for planning, expressed in the form of business

as usual, possible and extended, including recommendations on future planning policy and

research.

1.4.2 Appendices

The report also contains the following additional information in the form of appendices:

Appendix 1 Recent Renewable Energy Planning Applications in HertfordshireAppendix 2 Examples of Renewable Energy SchemesAppendix 3 Public attitudes to Renewable EnergyAppendix 4 Renewable Energy in an AONBAppendix 5 Code for Sustainable BuildingAppendix 6 Sustainable Building Task Group ReportAppendix 7 Policy ENV8 in the Draft Regional PlanAppendix 8 Information Sources

1.5 The Planning System

In dealing with the role that the local planning system might play in the development of

renewable energy, a brief description of the planning policy context is described below. The

planning system in the UK operates within a hierarchical structure of guidance and plans

covering the national, regional and local levels.

1.5.1 National Planning and Policy Statements

Climate Convention (1997 Kyoto Conference)

Under the Kyoto Protocol, the UK has committed to reduce Greenhouse Gas emissions overall

by 12.5% below 1990 levels by 2008-2012.

Climate Change the UK Programme (2000, UK government)

In order to achieve the above target, the government has set a domestic goal of a 20% reduction

in CO emissions by 2010 set out in the Climate Change Programme.

The Energy White Paper Our energy future creating a low carbon economy (2003)

This white paper set out four key goals:


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! To cut CO emissions by 60%, by about 2050

! To maintain the reliability of energy supplies

! To promote sustainable economic growth

! To ensure every home is adequately and affordably heated

Achieving emissions reductions of these magnitudes will require significant behaviouralchanges, with potentially major impacts on businesses and communities. Substantial

improvements in energy efficiency will be required, but will also have to be accompanied by a

major reduction in fossil fuel usage.

The Energy White Paper also sets a target to supply 10% of the UKs electricity from zero-

carbon, or carbon neutral, renewable sources (such as wind, wave, tidal, hydro and solar power,

and biomass) by 2010, and a target of 20% of the UKs electricity by 2020.

1.5.2 Regional Planning and Regional Spatial Strategies

Under the Planning and Compulsory Purchase Act 2004, existing Regional Planning Guidancedocuments (RPGs) are being replaced by new statutory Regional Spatial Strategies (RSS),

which will form part of the statutory development plan. Each RSS is intended to be more

regionally specific than previous guidance, reflecting regional diversity, and there will be

greater flexibility for a RSS to depart from national policy where that is justified by regional

circumstances.

The East of England Plan is, at the moment, a draft revision to the Regional Spatial Strategy for

the East of England. The formerly approved regional plan is known as Regional Planning

Guidance 14 (RPG14), whilst the new RSS will be referred to as the East of England Plan. The

East of England Plan is the document that sets out the strategy to guide planning and

development in the East of England to the year 2021.

The East of England Plan is dealt with in detail in Section 3 of this report.

1.5.3 Local Development Frameworks

In September 2004 the Planning and Compulsory Purchase Act 2004 introduced significant

changes for development plan preparation. The old system of Structure Plans, Local Plans and

Supplementary Planning Guidance is now being replaced with Local Development Frameworks

(LDFs) for each local planning authority.

Local Development Frameworks are intended to streamline the local planning process, by

incorporating greater flexibility and front loading in the process, by increasing community and

stakeholder involvement, and by promoting sustainability. Local development documents

(which will make up the LDF) will go beyond the development and use of land, to include

policies that influence the nature of places and how they function. These documents are

intended to be developed via a continuous, rather than fixed, interval process. The LDF must be

in general conformity to Regional and National policies.

For renewable energy, regional guidance determines the broad criteria and locations for

development in order to guide the preparation of the local development documents. These

should contain a spatial strategy for renewable energy including type, mix and broad location of

development (with details and maps of specific sites and proposals if relevant).


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LDFs will need to have regard for the resources, in broad terms only, likely to be available for

implementing policies that encourage renewable energy developments.

1.5.4 The Development Plan and the Development Control System

Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that if regard is to be

had to the development plan for the purpose of any determination to be made under the

planning Acts, the determination must be made in accordance with the plan unless material

considerations indicate otherwise.

Where a policy or proposal exists in the development plan (i.e. in the adopted RSS or LDF)

which is relevant to a particular planning application proposal, then the decision-maker must

have regard to that policy or proposal, unless material considerations indicate otherwise.

The LDFs will therefore be crucial in setting the local policies and proposals for their areas,

which in turn will influence how prospective applicants and developers will look at the

opportunities and constraints within each administrative area.


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2. The National Planning Context

2.1 Planning Policy Statement 22 (PPS22): RenewableEnergy

PPS22 sets out the Governments national land use planning policies for renewable energy. The

ODPM has also produced Planning for Renewable Energy: A Companion Guide to PPS22

which offers practical advice as to how these policies can be implemented on the ground. The

Companion Guide also includes examples of best practice. (For PPS22 and the guide, go to

http://www.odpm.gov.uk/stellent/groups/odpm_control/documents/contentservertemplate/odpm

_index.hcst?n=5681&l=3)

The Government is committed to delivering 10% of electricity from renewable sources by 2010

and 20% by 2020. PPS22 aims to strongly encourage the development of renewable energy

schemes, in both urban and rural locations, in order to contribute towards these targets. A range

of sizes of renewable energy developments are anticipated, from domestic through to

commercial scales, and utilising a wide range of different technologies (e.g. biomass, energy

from waste using biological and thermal processes, small hydro, solar electricity, solar heating

and wind).

PPS22 includes a number of key principles relevant to local planning authorities (LPAs) as

follows:

Local Development Documents should contain policies designed to promoteand encourage, rather than restrict, the development of renewable energy

resources.

Planning authorities should set criteria to be applied in assessing planningapplications for renewable energy projects. PPS22 underlines that particular

renewable energy technologies cannot be ruled out or restrained without sufficient

reasoned justification and that poorly justified constraints may be subject to

government intervention.

The wider environmental and economic benefits of renewable energy

proposals are material considerations in determining whether proposals shouldbe granted planning permission.

local planning authorities should not make assumptions about the technical and

commercial feasibility of renewable energy projects.

Small scale projects can provide a limited but valuable contribution to overall

outputs

Local Planning Authorities should foster community involvement in renewable

energy projects


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Development proposals should demonstrate environmental, economic and social

benefits as well as how environmental and social impacts can be minimised

PPS22 and its Companion Guide provide specific advice to LPAs on the preparation of Local

Development Documents. A summary of the key elements, which are of relevance to

Hertfordshire, is set out below.

LPAs should only allocate specific sites for renewable energy in plans where a developer has

already indicated an interest in the site. Plans should set out criteria based policies for assessing

planning applications for renewable energy. It is likely that there will be two types of policy

areas dealt with by criteria-based policies, supported by an overarching policy in the core

strategy. These would relate to:

Standalone renewable energy schemes The Companion Guide states that it is

important that policies address the full range of technologiesand not just those

highlighted in the Regional Spatial Strategy. The policy should address impacts on

landscape, townscape, natural, historical and cultural features (possibly referenced

to a landscape Character and Sensitivity Assessment). There should also bereference to the impacts on the amenity of the area in relation to visual intrusion,

noise, dust, odour and traffic.

Integration in new development PPS22 states that LPAs may includepolicies

that require a percentage of the energy to be used in new residential, commercial

or industrial developments to come from on-site renewable energy developments.

Such policies should ensure that the requirement is only applied to developments

where the installation of renewable energy is viable. They should also be flexible

and not place an undue burden on developers in terms of the proportion or type of

renewable energy to be provided.

PPS22 also provides further policy advice on certain locational considerations. For example, inrelation to nationally recognized designations such as Areas of Outstanding Natural Beauty

(AONB), planning permission should only be granted where it can be demonstrated that the

objectives of the designation will not be compromised by the development. Small-scale

developments should be permitted provided there is no overriding environmental detriment.

With parts of The Chilterns AONB falling within Hertfordshire, an example is provided at

Appendix 4 on planning guidance published within the last year for the Blackdown Hills

AONB on renewable energy and wind turbines.

In Green Belts many renewable energy projects will comprise inappropriate development and

therefore careful consideration needs to be given to the visual impact of the project. Developers

will need to demonstrate very special circumstances, which outweigh any harm, if projects are

to proceed.

PPS22 also points out that LPAs should not adopt a sequential approach in considering

renewable energy projects, as most renewable energy resources can only be developed where

the resource exists. Some previously developed sites may, however, be suitable, particularly

where they are in remote locations unsuitable for other uses. It also states that many type of

renewable energy are capable of being accommodated in urban, as well as rural, areas and

that criteria based policies should reflect this situation.

PPS22 and the Companion Guide advise that Supplementary Planning Documents could play

a critical role in implementing renewable schemes. Topics that such documents might cover


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include design guidance on integrating renewables, or site development briefs where renewable

generation is to be included.


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3. The Regional Planning Context

3.1 East of England Regional Spatial Strategy (RSS)

The East of England Regional Spatial Strategy (December 2004) is currently undergoing review

and a draft version was the subject of consultation from 8 December 2004 to 16 March 2005.

An Examination in Public is scheduled to begin on 13 September 2005. Following the

Examination, the Panel will produce a report on its recommendations and, in the light of these

recommendations, the Secretary of State will propose changes to the draft East of England Plan.

These proposed changes will then be the subject of a further round of consultation before the

Plan is published in its final form by the Secretary of State.

3.2 East of England Sustainable Development RoundTable, 2001

In order to identify suitable regional targets to help meet national targets, the East of England

Sustainable Development Round Table regional partnership commissioned research that

concluded that the renewable energy technologies with the greatest potential for the region are

off-shore and on-shore wind, biomass, bio-fuels and solar power.

Table 3.1 Regional renewable energy targets fo r the East of England 2010 and 2020

2010 2010 2020 2020

Excl. off-shore wind Incl. off-shore wind Excl. off-shore wind Incl. off-shore wind

10% 14% 17% 44%

Although the report in 2001, Making Renewable Energy a Reality: Setting a Challenging

Target for the East of England, highlighted the fact that use of wind power is expected to

contribute significantly to meeting the 2010 target, developments using a range of technologies,

from domestic through to large commercial ventures, will also be required. Many renewable

energy technologies are best suited to small- and medium-scale generation and distribution such

that every area in the region, including those not previously accommodating generationinfrastructure, will need to promote renewable energy development. For those technologies not

yet commercially tested, demonstrator projects would need to be approved now in order to

establish effective operation in time to meet the targets.

3.3 East of England Draft Plan, December 2004

The East of England Regional Spatial Strategy (December 2004), when eventually approved,

will form the statutory framework for local development plans and transport plans produced by


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the local authorities in the region. The draft plan aims to address the four keys areas of

sustainable development, namely:

Social progress which recognises the needs of everybody

Effective protection of the environment

Product use of natural resources

The maintenance of high and stable levels of economic growth and employment.

In order to enable the quantum move required towards the use of renewable energy, there are

many policies within the Spatial Strategy specifically designed to promote its usage. These are

summarised below: -

Policy SS16: Quality in the built environment

Promotion of design excellence, including increased building energy efficiency and use of

renewable energy supplies.

Policy NSR1: Promoting cluster and strategic sites

Renewable energy highlighted as an emerging strategic employment cluster / sector.

Policy NSR5: Transport infrastructure

Transport improvements to support renewable energy generation will be prioritised (subject to

site approval).

Policy GYL1: Economy and regeneration

Promotion of renewable energy employment cluster (utilising existing offshore engineering

skills).

Policy KL1: Kings Lynn sub-region

Attraction of investment in expanding economic sectors, including bio-fuels and other

renewable energy technologies.

Policy T11: Environment and safety

When implementing renewable energy, transport planning, movement corridors and investment

should minimise environmental damage and take into account national designations and

landscape character.

Policy ENV8: Renewable energy and energy efficiency

This is the main policy for the promotion of energy efficiency and renewable energy. The draft

policy and its supporting text, as published in December 2004, is reproduced in full at

Appendix 7.


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3.4 Regional Planning advice for Local DevelopmentFrameworks

The draft version of the East of England Regional Spatial Strategy (December 2004) currently

requires Local Development Documents to: -

Contain policies for promoting and encouraging energy efficiency and renewable

energy, presuming in favour of renewable energy development.

Require developers to maximise energy efficiencies to be gained from sustainable

design and construction, community heating and combined heat and power

schemes

Encourage developers to strive to achieve energy efficiency standards that exceed

minimum standards.

Require energy consumption statements for development proposals above a

threshold of 1000 sq. m., or 50 dwellings, in order to ensure that the technical,environmental and economic feasibility of alternative systems such as

decentralised energy supply systems based on renewable energy

combined head and power (CHP)

district or block heating or cooling, if available

heat pumps, under certain conditions

are considered and taken into account before construction starts.

Require all developments above a threshold of 1000 sq. m., or 50 dwellings, toincorporate equipment for renewable power generation so as to provide at least

10% of their predicted energy requirements.

Specify the locational and other criteria by which applications for renewable

energy developments will be assessed.

Define and relate renewable energy and energy efficiency policies to the

Sustainable Communities Plan Growth Areas, the settlements outside these Growth

Areas, and designated and non-designated landscapes, in accordance with the

detailed guidance provided in the RSS.

Favourably consider the onshore developments associated with offshore energy

generation.

Encourage the use of existing infrastructure and the under-grounding of cables

connecting new plant to the grid, wherever possible.

Encourage methane exploitation from appropriate landfill sites, provided this is not

used to prolong landfill operations beyond currently agreed targets.

Actively encourage the development of community-based schemes in accordancewith the detailed guidance provided in the RSS.


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The RSS considers that supplementary planning guidance and development briefs should be

used by the local planning authorities to support the above policies, where appropriate.

Renewable energy technologies include photovoltaic energy, solar-powered and geo-thermal

water heating, wind (onshore and, where relevant, offshore), energy crops and biomass, energy

from human sewage and agricultural plant and animal waste, but not energy from domestic orindustrial waste, except the harvesting of methane from existing landfill sites.

3.5 Regional Planning Advice on Location

Appendix C of the draft East of England Plan provides further guidance to LPAs on locational

considerations and criteria. This states that Renewable energy developments have to be

located where they are technologically and economically feasible. As this can range from

heavily urbanised to remote rural areas, all parts of the region are potentially suited to some

form of renewable energy technology. Areas of search for renewables are not considered

appropriate at this time asrenewable energy technology is subject to rapid technological change,

with new, and more efficient, equipment constantly coming on-stream.

The Appendix sets out principles for determining locational criteria for renewable energy

development based on:

A regional energy hierarchyi.e. in descending order of priority;

o use less/reduce the need for energy

o use energy more efficiently

o use renewable energy

o use clean and efficient technology for fossil fuel powered heating and co-generation.

A spatial approach - local development documents should define and relate

renewable energy and energy efficiency policies to:

o sub-regional growth areas

o settlements outside growth areas

o non-designated landscapes

o designated landscapes.

Small-scale and community-based schemes appropriate to local need are mostlikely to be permissible in areas which are:

o within or close to settlements

o within suitable landscapes

o close to the origin of the energy resource

o close to groups of buildings (in rural areas).


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LPAs are advised to incorporate detailed criteria related to the following spatial

categoriesin their local development documents.

3.5.1 Sustainable Communities Plan growth areas

These are seen as areas of maximum potential for the development of renewable energy

technologyand the application of energy efficiency measuresby virtue of the opportunities for

new homes, business and commercial developments.

Given the scale and level of development the scope for energy efficiency measures, combined

heat and power (CHP) and district heating schemes presents the region with a significant

prospect of meeting energy saving and climate change/greenhouse gas emission targets.

The major opportunities are seen as energy from sewage waste, wind, solar and methane.

Agricultural land within the growth areas also has potential for energy crops with the added

advantage of reduced transport distances to generation plants that will be easier to locate on

urban / urban edge sites.

3.5.2 Settlements outside growth areas

Whilst development rates will be slower in these areas than the Sustainable Communities Plan

growth areas there is still seen to be significant potential to develop renewable energy and

energy efficiency measures in new development.

Renewable energy technology opportunities will be more limited, with solar and small-scale

wind being most suitable. Settlement edges however, will have potential for larger-scale wind,

energy crops, energy from sewage waste and landfill methane. Towns will also provide

locations for siting generation plants for combusting energy crops from adjacent farms.

3.5.3 Non-designated landscapes

These areas comprise primarily agricultural land and woodland, covering the majority of the

regions area. The non-designated landscapes are likely to be the principal locations for large-

scale developments associated with wind, biomass and agricultural wastes, with their related

combustion plants and infrastructure. They may also be the areas to accommodate smaller-

scale developments, including individual, or small groups of, turbines, hydro schemes and

sewage plant bio-gas installations.

The Appendix states that the potential for using these developments as a focus for

regenerating the rural economy should be a major policy objective of local development

documents.

3.5.4 Designated landscapes

Areas statutorily designated internationally and nationally for the protection of theirlandscape quality, coastal heritage, biodiversity, cultural and heritage interests designations

are not considered to be suitable for the construction of large-scale renewable energy

infrastructure, especially wind-turbines. However, small-scale developments of wind

turbines, energy crops, hydro schemes and bio-gas from small sewage plants may be acceptable.


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Developers should be required to undertake assessments to demonstrate that adverse impacts

can be satisfactorily addressed. They should also show that that there is an overriding need for

the development in terms of local social and economic conditions.

The Appendix also states that Local Development Documents and Supplementary Planning

Documents should specify detailed criteria specifying energy efficiency standards in excess ofthe minimum (using SAP rating, Ecohomes rating or BREEAM (the Building Research

Establishment Environmental Assessment Method). Local planning authorities should require

that all new residential development achieve an NHER of at least 10.

Local Development Documents, supported by supplementary guidance, should also specify

detailed locational criteria related to the following renewable energy technologies; solar

photovoltaic, solar thermal, wind, small scale hydro, biomass and combined heat and power.

These criteria should focus on encouraging the development of such technologies and

mitigating their effects, rather than as a basis for justifying the refusal.

3.6 Hertfordshire Structure Plan

Until the East of England Plan is adopted, the development plan for Hertfordshire will comprise

the adopted Hertfordshire Structure Plan and all relevant adopted Local Plans. Policy 54 deals

with energy generation and states that, where there is a viable choice between development to

generate energy by renewable or non-renewable means, priority will be given to renewable

generation, subject to the other policies of this Plan. Renewable energy developments are

supported subject to their impacts.


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4. The Local Planning Context

4.1 PPS12 on LDFs

Planning Policy Statement 12 (PPS12) on Local Development Frameworks (LDFs) outlines the

new system of development plans. The shift towards community involvement, sustainability

and spatial planning lie at the heart of the change. This approach will require the integration of

environmental, social and economic considerations in the light of local conditions. In order to

improve efficiency and effectiveness of the planning system, there is an emphasis on the

principle of front-loaded and evidence-based decision-making.

The Local Development Frameworks portfolio will consist of : -

A Statement of Community Involvement

Development Plan Documents

A Core Strategy

Policies and proposals on land-use topics (including site-specific allocations)

Area Action Plans

A Proposals Map

Supplementary Planning Documents

Within Hertfordshire, 10 separate local planning authorities (LPAs) will be preparing LDFs, all

of which will need to include the subject of renewable energy development proposals. A Local

Development Scheme, submitted by each LPA, sets out the LDF programme and timetable.

PPS12, in respect of the LDF, talks of LPAs having a proactive positive approach to managing

development that is:

Flexible

Appraised for sustainability

Managed efficiently

Sound and based on robust credible evidence

and that:

Strengthens community and stakeholder involvement

Front-loads the process

PPS12 states that LPAs should adopt a spatial planning approach to LDFs in order to ensure

the most efficient use of landand to approach this objective by balancing competing demands

within the context of sustainable development.


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PPS12 explains that the new form of spatial planning:

Goes beyond traditional land use planning;

Means that planning can consider the wider issues (such as the issues associated

with carbon reduction and renewable energy promotion);

Enables development and land use plans to be brought together with other policies

and programmes; and

Means that there is a need to work collaboratively.


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5. Planning Issues

5.1 The Different Forms of RE and their Implications forPlanning

Renewable energy is used to describe the various ways in which continuous energy flows that

occur naturally in the environment, from the sun, wind, oceans, plants and the fall of water, are

harnessed. Energy from waste is also referred to as renewable energy where it emanates from

within the earth. National policy is to encourage the development and use of renewable energy

resources where they have prospects of being economically viable and environmentally

acceptable. The aim is to reduce the adverse environmental impacts of producing energy from

fossil fuels, notably carbon dioxide (CO) emissions. In addition, renewable energy sources can

also contribute towards the greater diversity and security of the nations energy supply. It mustbe recognised, however, that some renewable energy resources can only be utilised where they

occur and that often their location will be, as a matter of necessity or convenience, in rural areas

and open landscapes. It is the planning system that is left to try to ensure that a balance is

achieved between utilising and, indeed, encouraging the particular energy resource and the need

to take account the potential impact on the local environment and amenities.

5.2 Wind power

5.2.1 Project Initi ation

Wind energy is recognised as one of the most promising renewable resources and the

technology is well advanced. Wind turbines can be deployed singly, in small clusters, or in

larger wind farms. Developers are generally attracted to areas of higher elevation and open

landscapes in order to find the best wind resource with sufficiently high annual mean wind

speeds. Knowledge of the local wind resource is critical to designing a wind energy system and

predicting its output. For domestic installations, a good source of information on local wind

speeds is the NOABL database. For a major wind farm development, a developer would

normally need to seek permission to erect a temporary mast of at least 40 metres in height for

monitoring the wind speeds for a period of between 12 and 18 months.

The scale of the proposed wind power development is seen by developers as crucial to the

planning risk. Many developers have chosen to concentrate on developments over the 50MWthreshold defined by Section 36 of the Electricity Act, which require DTI approval, rather than

rely on the unpredictability of local authority planning approvals. However, Hertfordshire is

probably not best placed to win large-scale development due to local wind conditions.

Similarly, small-scale schemes tend to involve local power distribution and often local

ownership, significantly improving local support. It is the mid-range schemes (5 to 30MW)

which have encountered the most resistance during the planning process. In order to meet the

regional targets, it will be essential to promote schemes of all scales to obtain maximum benefit.

Therefore, it is important that planning policies and guidance are tailored to meet the needs of

each of the various scales of development.


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In order to reduce risk, developers will seek out those local authorities offering favourable

development climates, i.e. those adopting a proactive rather than reactionary stance. The cost of

local educational programmes (for the general public, planning officers and committee

members) has been a significant factor in development appraisals, encouraging developers

towards local authorities that have engaged with the impact of renewable energy as part of their

Agenda 21 work.

5.2.2 Evaluation

Local authorities can significantly increase the likelihood of development proposals coming

forward by producing indicative potential development maps for their areas. These could

indicate not only wind speed data and grid accessibility information, but also safeguarded areas

(e.g. airport/low flying/radar zones, areas of high landscaping sensitivity), transport route

separation zones, communication line-of-site pathways, residential developments and

cumulative wind-farm development separation data. Indications could be given for which areas

could accommodate large schemes, which would be more suitable for mid-range schemes

(depending on the particulars of the site), and which could at best support small-scale schemessubject to sensitive development.

Visual amenity is often a primary factor in planning applications. Individual turbines and wind

farms are highly visible over wide areas and while it might be possible to locate such

developments in sympathy with the landform and existing features in the landscape, regard must

also be paid to their wider landscape impact. (For example, grid connections could be routed

underground, to ameliorate visual impact, though this will considerably add to development

costs and environmental disturbance). There is also a need to consider the potential cumulative

impact that might occur with two or more schemes in an area. i.e. The number, size, layout,

colour, height, profile and cumulative impact of the proposals need to be considered, together

with the impact of additional power lines, fencing, buildings, sub-stations, access tracks

(including surfacing materials, cuttings, embankments, drainage channels), and anemometermasts.

Wind turbines can also cause problems of shadow flicker, reflected light, television and radio

interference and noise, both from the turbine and the blade movement. A suggested minimum

separation could be specified in planning policies between wind turbines and nearby dwellings

in order to prevent issues of visual and noise disturbance, or left variable (but sufficient)

depending on factors such as wind direction or background noise. The potential for noise

generation is generally the biggest factor for deciding how much generating capacity can be

installed at a potential site. During the EIA and site design process, noise minimisation will

often heavily influence the layout and design.

Wind turbines can also affect electromagnetic signals as used by television broadcasting andradio communications, although many options for fixing potential television reception problems

are available. Fixed communication links require a line-of-sight path between the transmitter

and receiver and thus a wind farm can be designed so that turbines are placed away from the

line of sight in order to avoid affecting such communication links. The Radio-communications

Agency (RA) holds a central register of all civil radio communications installations in the UK.

Areas of nature conservation or archaeological importance are normally avoided by developers,

although protected species or habitats might exist at any site. In many cases, archaeological

features are relatively small and in a buried, or ruined, state. It is relatively straightforward for a

wind farm to be designed around such features and proper on-site construction standards will


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ensure that such protected sites remain intact. More significant cultural heritage features and

their settings are, of course, protected from any developments through national and local

planning policy. Due to the large investment in planning and developing wind infrastructure,

larger-scale developers are inclined to avoid areas with designated protection policies in

development plans, such as Green Belts and AONBs, although it is not uncommon to come

across proposals for individual turbines in such areas.

National grid connection, or the lack of it, is becoming an increasingly significant barrier to the

development of many wind farm projects. A connection to the local electricity network, which

can carry away all the generated electricity from the site at an affordable price, is essential for a

successful project. However, small-scale wind power is particularly suitable for remote off-grid

locations where conventional methods of supply are expensive or impractical.

As the proportion of energy generated from wind-power increases, the impact on grid balancing

becomes significant, and use of large-scale energy storage schemes such as hydro-pumping

become necessary. Local use and storage of the generated electricity mitigates this issue,

promoting the location of turbines in industrial or urban locations.

5.2.3 Implementation

Modern commercial wind turbines are extremely large structures, with a 2MW wind turbine

having blades of 40 metres in length that would arrive on site on 47 metre-long lorries. The

erection of a 2MW turbine requires either an 800 tonne mobile crane, or a massive crawler

crane. Traffic generation during construction needs to be considered and the roads to the site

must be able to accommodate the largest vehicles, as well as other construction traffic. It must

also be possible to build roads across the site, which allow the construction traffic to work.

Wind farm access roads and foundations could effect local hydrology, which in turn will have

an influence on local habitats and water abstraction. The restoration of temporary construction

roads back to their original land use could be a matter for planning conditions.

Typically a developer would expect a 9 to 30-month programme to develop a project (i.e. secure

planning consent and reach financial close), with a further 9 to 18-month programme for

construction. These time-scales are of course dependent upon the scale of the project, the site

location and the prevailing public opinion towards the proposal. Significant public opposition or

EIA issues can effectively prevent wind-power development due to excessive development

timescales.

5.2.4 Maintenance

The actual land take with wind turbines is minimal. Whilst wind farms usually extend over

large areas of land, traditional farming is relatively unimpeded and only about 1% to 5% of thewind farm area is normally rendered unusable for farming or other uses by the development.

Equipment maintenance generates little traffic, with most monitoring and control being

performed remotely.

5.2.5 Decommissioning

Since most wind turbines have an operational life of around 20-30 years, consideration should

be given to the future of the site. Turbines can be re-powered with more efficient (possibly

smaller) systems, or replaced, or removed completely. Decommissioning should be the subject


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of appropriate planning conditions that require the reinstatement of the landscape and its

vegetation.

5.2.6 Smaller Scale Turbines

TV (Thames Valley) Energy provide the support for the Countryside Agencys Community

Renewables Initiative covering Berkshire, Buckinghamshire and Oxfordshire. Their

information sheet for community groups and not-for-profit organisations states:

Small wind turbines are sized at a hub height of 25 metres and under. Turbines need

to be mounted on a tower of a height that reduces the blocking effect of the buildings,

residential properties and trees. They are noiseless, but a planning application will be

required. Windspeeds are the vital factor, with wind speeds of 5 m per second and

above, at a height of 10m being recommended. Clearskies grants are available for 50%

of installed capital costs and a 6kW turbine will cost in the region of 19,000. This will

generate approximately 14,000 units of electricity when wind speeds average 5.5m per

second at a hub height of 15m.

5.2.7 Domestic wind turbines

Later this year, British Gas has announced that the company will be commencing a trial

programme of domestic-size wind turbines on houses in Scotland and South West England,

which, if successful, could be expanded to include properties across the whole of the UK. The

vanes extend to 1.75m (about 5ft 9in) from vane tip to vane tip. The structure bolts on to a

property wall or gable-end of a building, similar to a satellite dish, and stands about 2.5 metres

(about 8ft 2in) high. British Gas estimates that the small turbine would produce around 1

kilowatt of electricity, which might cut around one-third of an average household electricity bill

and reduce CO emissions by about half a tonne per annum. The turbine would cost around

1,500, including installation, and would operate in wind speeds as low as three miles per hour.It is the first time a major supplier has tested domestic wind turbines, although some

homeowners have already bought and installed such equipment. Properties taking part in the

trial will be in both urban and rural areas, although it clearly going to be easier to accommodate

such potentially noticeable and intrusive structures on larger and more isolated dwellings. In

many instances, planning permission is likely to be required, for example if the structure is

higher than the apex of the roof of a dwelling. The turbine manufacturer in the trial, Windsave,

would like to see permitted development status for all such devices so that homeowners do not

have to apply for planning permission on an individual basis, although this would appear to be

optimistic and possibly not acceptable to communities where the visual impact of such

equipment is perceived as far more obtrusive than ordinary TV aerials and satellite dishes.

5.3 Biomass energy

Biomass energy covers the full range from large-scale electricity production such as in

commercial co-firing power stations, down to medium and small-scale electricity and heat

production facilities, and domestic heating systems. It also covers transport fuels such as bio-

diesel and bio-ethanol derived from starch and oil crops and waste products.


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5.3.1 Co-firing

Existing coal-fired power stations can burn up to 10% biomass products using existing

technology, (though 5% may be nearer the practical limit due to problems of feedstock

pulverization and combustibility). Co-firing is currently eligible for ROCs as a method of

promoting the production of local feedstocks, however this is likely to end in 2016, increasingfeedstock availability for dedicated biomass energy production.

A wide range of biomass feedstocks have been trialed including specialist wood crops, cereal

crops, olive pips, waste slurries and palm oil, though most are currently being imported due to

lack of appropriate and adequate local fuel supplies.

Increased transportation, associated with the shipment of bulky feedstocks, is the biggest

planning impact of co-firing technology. However, a significant proportion of power stations

currently use rail shipment. Since this method of renewable energy generation is unlikely to

persist once ROC eligibility is removed, significant development in new offsite infrastructure is

unlikely to be economically viable.

5.3.2 Large-scale power generation

In order to be economically viable, biomass plants require large volumes of suitable fuel to be

available at the lowest possible price, which generally means within a relatively close local area

of the installation. Biomass may also be hampered in part from the lack of a wide enough

market for the fuel that it requires to use and which therefore may not be made available in

sufficient quantities within an accessible distance of the plant.

Often biomass development occurs close to energy crop production sites or near specialist

feedstock production such as chicken farms. As technology improvements increase the variety

of viable feedstocks, the range of potential sites will grow.

By far the most obvious and wide-ranging visual impact in the countryside is the growing of theenergy crops, which of course does not require planning permission as such. (Although the

growing of biomass crops does not fall under the control of the planning system, the

Environmental Impact Assessment (EIA) Regulations introduced in February 2002 require land

owners of permanent pastures / semi-natural habitats to inform Defra before converting land to

intensive agriculture. Defra can then undertake an environmental assessment of this change and

can prevent harmful changes from taking place.)

Specialist wood crops such as willow or poplar are grown on a two to three-year rotation period.

Straw and whole crop cereals can also be used, both annual and less-energy intensive perennial

varieties. The growth of such crops could be undertaken on set-aside land and the production

of crops for fuel could prove a valuable form of diversification for local farmers. In order to

meet the targets defined from energy crops significant areas of land would need to be allocated

to energy crop production. This would primarily be agricultural land, though the possibility of

using brownfield land as part of a long-term reclamation process should not be ruled out.

There must be a sufficient supply of the feedstock, of an appropriate quality and over the long-

term, in order to operate the plant. The feedstock quality and consistency must be maintained

throughout the entire life of the project. Grant support is available for the establishment and

growing of energy crops, subject to certain rules, which include being located within a

reasonable distance of the end use (10 mile radius for small installations, 25 miles for large

installations), along with providing a minimum establishment of three hectares. One-off


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payments are also available for the establishment of the crop. In the past, there was a

differential between short rotation coppice (SRC) and miscanthus. However, reform of the

Common Agricultural Policy (CAP) has made the enhanced rate for SRC redundant from 2005.

CAP reform will also lead to replacement of the Arable Area Payments Scheme (AAPS) under

which set-aside payments are made. The AAPS will be replaced by a single payment scheme

from 2005. The current maximum limit for grant aid is 500,000. The establishment and

growing of biomass may be supported through other schemes, including the Woodland Grant

Scheme and the Farm Woodland Premium Scheme (on which there is up-to-date information

available on the Defra web site at www.defra.gov.uk).

Key issues for local planning authorities to consider when evaluating applications for biomass

plant are: -

visual intrusion, including any chimneys, noise from engines, boilers, handling

equipment and traffic,

light pollution from plant operational around the clock,

potential pollution of ground and water courses,

emissions into the air, and

traffic resulting from the transport of the fuel to the site and the subsequentremoval of by-products and any waste.

The kind of questions that would need to be asked about proposals that would generate a

significant amount of traffic would be:

What will be the traffic flows associated with the scheme?

What will be the emissions from the vehicles?

What access routes will be used for the delivery of the crop?

What traffic management controls will be needed and proposed?

What are the fuel handling and temporary storage requirements?

Planning authorities may wish to control the number of vehicle movements of construction and

operational traffic to and from the site in a specified period and, where possible, the route of

such movements, particularly of heavy vehicles, by imposing suitable conditions, or entering

into planning agreements with the developer.

As with all thermal treatment processes, most concerns expressed involve the emission ofpollutants to the atmosphere. (Pollution Prevention and Control for larger biomass plants is

covered by the Environment Agency).

Biomass developments are often seen as high-risk due to the high levels of investment finance

required, potential variability of local fuel supplies and the need for an affordable national grid

connection. However, with the increased interest in renewable energy technology as a

commercial investment and recent changes in the 2004 Energy Act concerning favourable grid

connection charging for renewable energy sources has lessened the financial barriers.


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5.3.3 Small to Medium-scale power generation and CHP schemes

Many biomass plants will be small, only provide heat, and may be easily incorporated into

existing or new buildings. Where they are included in agricultural buildings, they may not

require specific planning permission if they are ancillary to the main use of the site. However,

heat and power generation plants will require planning permission. The generating plant andactivities directly related to it are subject to planning control, but the growing and harvesting the

biomass crops are outside planning control.

Small-scale schemes are now benefiting from maturing feedstock distribution networks, though

transport costs can still be significant for locations remote from centres of production, and costs

associated with storage requirements of sensitive fuels such as wood pellets. Fuel costs remain

high in relation to conventional heating fuels such as natural gas and heating oil, and generally

only warrant consideration for sites with no access to mains gas, and a need for constant heat

production, unless combined with traditional facilities.

CHP installations can improve economic viability by using heat off-take systems for use on

adjacent sites and facilities. These are best designed in at initial installation as retro-fitting costscan be prohibitive. Also the existence of a local market for the waste products e.g. as fertiliser

can significantly reduce running costs. However, unless ROCs are introduced for heat then

commercial CHP development is unlikely to increase significantly.

Biomass boilers for district heating, (where heat rather than energy is sold to consumers), are an

option but currently these are uncommon in the UK. Local authorities could require new

developments to consider the use of district heating, (particularly in thermally-efficient high-

density developments), or could mandate a minimum proportional of biomass heating provision.

The most economically viable schemes at present use standard gas burners combined with solar

(solar covering summer electrical needs, gas providing both electricity and heat in winter).

Typically a developer would expect a 9 to 30-month programme to develop a project (i.e. secure

planning consent and reach financial close), with a further 9 to 18-month programme for

construction. These time-scales are of course dependent upon the scale of the project, the site

location and the prevailing public opinion towards the proposal.

5.3.4 Power generation from waste

Waste products such as chicken litter as used on a commercial basis as a successful feedstock,

and trials are being conducted with other waste products such as used tyres. The digestion of

farm slurry can produce a gas rich in methane, which has in the past been used on a very small

scale to provide energy on the farmyard. It is possible, however, for slurry from several farms

to be concentrated at a sewage-treatment works and there combined with sewage from the main

drainage network before being subjected to digestion to produce bio-gas at an economicallyviable level. The energy produced can be in the form of heat as well as power. The main

planning implications associated with such development include concern over pollutants, traffic

generation, the visual impact of the digester tanks, gas holders and transmission lines and noise

emissions.

In order to be commercially viable, developments utilising waste products need to ensure long-

term feedstock supply contracts. (Typically 50-75% of revenues are derived from gate fees).

Most thermal technologies have limited fuel flexibility, and are unable to track fluctuations in

feedstock quality and availability over the life of the project.


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The major public concern with the use of waste products as a feedstock is with emissions of

pollutants into the atmosphere, with difficult planning applications being referred to Public

Inquiry. Often Local Authority Waste Management Strategies preclude the use of incineration

as a means of final disposal. Such costs and delays are a major disincentive for investors.

5.3.5 Transport fuels

Bio-fuels will undoubtedly become an increasingly important transport fuel. Bio-diesel can be

used alone, or blended with fossil-derived diesel. It can be used with no engine modifications

and bio-diesel can even improve engine life due to increased lubrication. It can be delivered via

the existing fuel infrastructure (e.g. Tesco currently offer a 5% blend). Bio-ethanol can be used

as a supplement in petrol engines, but may require some engine modifications and development

of the nation-wide fuel delivery infrastructure.

The majority of feedstocks used for the production of bio-fuel and commodities traded world-

wide and therefore influenced by international trade agreements, and hence commercial

arrangements tend to be more complicated, particularly when considered against the typical

project investment time-scales of 15-30 years. Currently imported feedstocks such as palm oil

are more economically attractive than indigenous supplies (such as being used in the proposed

Teesside facility), although a bio-diesel pilot plant exists in Ashford using waste cooking oil

feedstock (benefiting from EU legislation forbidding the reuse of waste cooking oil in animal

feed).

Bio-fuels are more expensive to produce than fossil-derived fuels, but changes in the fuel duty

and the increasing cost of a barrel of oil are reducing the margin. Support is also available for

the establishment and growing of certain energy crops. This is significant since the economics

of production are heavily influenced by transport costs, necessitating a local plentiful supply of

feedstock. Major planning issues for fuel production facilities will involve feedstock and fuel

transportation, storage requirements (visual impact, land use, safety etc.) and pollution control(such as environmental contamination).

5.3.6 EIA requirements

All commercial biomass developments are likely to be subject to the need for Environmental

Impact Assessments where situated within a 'sensitive area' or the area of the development

exceeds 0.5 hectares. (Smaller thermal power station schemes would be considered eligible

under Schedule 2, "industrial installations for the production of electricity, steam and hot

water"). Where the process involves the collection, storage and processing of hazardous or non-

hazardous wastes, proximity to controlled waters (within 100 metres) is a relevant consideration

and likewise the collection and storage of combustible gases. The likelihood of significant

effects will generally depend on the scale of the development and the nature of the potentialimpact in terms of discharges, emissions or odour. For installations, (including landfill sites),

used for the deposit, recovery and/or disposal of household, industrial and/or commercial waste

(as defined by the Controlled Waste Regulations 1992), EIA is more likely to be required where

new capacity is created to hold more than 50,000 tonnes per year, or to hold waste on a site of

10 hectares or more.


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5.4 Water power

Whilst older installations are likely to comprise a dam and storage reservoir, new developments

can be small in scale and utilise a natural pool, or head-pond, in order to supply a turbine via a

conduit. Water power normally produces electricity and the turbine can be installed in a

building the size of a domestic garage. Sites with less than a 2 m head tend to not to be cost-

effective, though pre-existing facilities such as at disused mills, especially when incorporated

with on-site energy usage can make refurbishment schemes financially viable. While water

channels and the buildings are likely to be visible, they are not necessarily detrimental to the

landscape and can often be screened. Extensive civil engineering works tend not to be required

for low-head schemes, where often the natural features of the watercourse are utilised, and

problems of noise and traffic movements are normally minimal once construction is complete.

Visual and ecosystem impacts are very much site-specific. For example the risk of interference

with sensitive ecosystems or rare species is likely to be higher in national park or semi-

wilderness areas, and lower on existing weirs on lowland rivers. Input from wildlife of ecology

experts may be required as part of an Environmental Impact Assessment.Renewable energy generated from pre-existing commercial hydro-schemes does not count

towards the regional targets.

5.5 Solar power

Active solar systems are those which collect the suns radiation and transfer it in the form of

heat to water or air. Photovoltaic systems convert the suns energy directly into electricity.

Direct sunlight is not necessary to make these systems effective. Passive solar design uses a

buildings form, fabric and orientation to capture, store and distribute solar energy with a

consequent reduction in demand for additional heat and light. The installation of active solar

systems usually involves fitting solar panels to the roof, photovoltaic cells incorporated into

roof tiles or glazing, or a separate solar collector system in the grounds. The visual impact of

such installations will vary depending upon their context but particular attention should be paid

to their impact in Conservation Areas, on Listed Buildings and in other sensitive locations. This

is a form of energy which can be generated at the point of use and is available everywhere, and

also has only a limited impact in visual terms.

Solar systems often fall within permitted development rights for homeowners (where for

example a solar panel is more or less flush with an existing roof). However, for listed buildings,

conservation areas, buildings in Areas of Outstanding Natural Beauty or National Parks or

covered by Article 4 direction, blocks of flats, (or houses divided into flats), planning

permission may well be required. Photovoltaic products may be more suitable in areas wherevisual amenity is crucial.

Installations require maximum light and avoid possible shadows cast by adjacent buildings,

trees or other obstructions. The visual amenity of installations is good. Active solar thermal

collectors usually take the form of 3-4m collectors mounted on the roof, resembling dark roof

lights, arranged in banks on large-scale commercial premises. Photovoltaic collectors can exist

as panels on roofs or walls, or incorporated into the fabric of the building as external wall

cladding, roofing systems, solar roof slates or built into glass facades or roofs.


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Heat pumps utilising solar heating of the ground are normally free from planning consents, but

are subject to building regulations.

5.6 Landfill gasLandfill gas is mainly a mixture of methane and carbon dioxide that can be used through

combustion for heating and electricity generation. In order to exploit landfill gas, a suitable site

must be available, which must be provided with a gas collection system and the necessary plant

for energy generation. This type of energy source is only available in commercially viable

quantities from extensive landfill sites. As waste is diverted away from landfill, this source of

renewable energy is likely to drop away.


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6. Renewable Energy Development inHertfordshire

6.1 The Potential for RE in Hertfordshire

The accompanying Renewable Energy Options Report, which has also been prepared by Entec,

concludes that there is the technical potential within Hertfordshire to achieve the levels of

renewable energy production proposed in the East of England Sustainable Development Round

Table Study. However, achievement of the technical levels will be dependent upon a range of

external factors, such as developer uptake, aviation objections (potentially on commercial wind

projects) and consumer uptake.

One of the most important factors influencing the uptake is commercial competitiveness

(financial viability) and this is strongly influenced by much wider-ranging global political

factors, national policy and regulations, grant schemes and the fundamental economic viability

of the technologies. Many of these factors will be beyond the direct influence of stakeholders

within Hertfordshire.

However, for the more competitive renewable technologies, such as onshore wind, planning

policy will remain the critical issue for attracting commercial developers. Strong regional and

local level planning policies and increased public awareness can play a major part in attracting

developers and influencing the deployment of renewable technologies in Hertfordshire.

6.2 Meeting the Targets

In order to meet the 2010 targets defined in the East of England Plan onshore wind must be

encouraged, along with all other forms and scales of renewable energy schemes. In order to

meet the 2020 targets, emerging technologies, such as biomass, will need to make a major

impact. Due to the long initiation periods of many of these projects, effort must be expended

now in order to win over public opinion and bring developments forward. Although

requirements for renewable energy in new development will only make a marginal difference to

the direct achievement of targets, it could have an impact on the public perception of renewable

energy and the acceptability of new technologies.

Urban authorities in particular may wish to concentrate efforts on small-scale, building-based

embedded technologies such as solar, photovoltaic and small-scale wind solutions, with limited

large-scale projects on brownfield sites where the opportunity arises. However, rural authorities

may find projects that support the economy and promote employment more beneficial to their

communities.

The results of the assessment of renewable energy generation potential are set out in the

accompanying Renewable Energy Options Report for Hertfordshire and are reproduced below

for ease of reference.


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Table 6.1 Potential renewable energy produc tion in Hertfordshire by 2010

Technology Potentialcapacity

(MW electri cal)

Potentialelectrical

output(GWeh/year)

Potential totalenergy outpu t

(GWh/year)

CO2reduction(tonnes

CO2/year)

WIND

Large Wind Turbines

Existing: 0.225

Possible: 10

Extended: 65

Existing: 0.25

Possible: 25

Extended: 163

Existing: 0.25

Possible: 25

Extended: 163

110

10,800

70,100

BIOMASS

Co-firing in large power plant 31 175 175 168,000

Dedicated CHP facility 17 125 285 94,000

Bio-diesel

Bio-Ethanol

39,000

107,000

Animal Slurries and AnaerobicDigestion

2 14 14 6,000

Sewage sludge (90% drysolids) EFW

4 30 30 13,000

MSW EFW 14 104 104 45,000

Small scale biomass-heatfacilities

N/A N/A 35 9,000

WATER : Hydro Low : 0.1

High : 2.0

Low : 0.6

High : 12.3

Low : 0.6

High : 12.3

260

5,300

WIND : Rooftop Low : 0.3

High : 7

Low : 0.3

High : 7

130

3,000

SOLAR ; Photo-Voltaic Low : 0.5

High : 12

Low : 0.5

High : 12

220

5,200

SOLAR : Thermal/Passive Low : 2

High : 137

500

34,300


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7. Local Planning Approach

7.1 The Vision

It is suggested that local planning authorities first consider whether the plan should start with a

vision for the area that covers the subject of renewable energy. The vision for the Local

Development Framework might be broad in terms of describing future aspirations for the area,

but local planning authorities can decide just how specific they wish to be, including whether a

vision for individual topics, such as renewable energy, might be an appropriate starting point.

However, this will obviously depend upon whether a single vision can be agreed.

Exactly how a local authority will approach the question of renewable energy will inevitably

become a controversial subject if the planning authority contemplates encouraging orpromoting such energy provision within their administrative area, as the Government is

seeking to encourage. Encouraging wind power would inevitably be a possible option if a local

authority were to be proactive in seeking to make a significant contribution to the provision of

renewable energy sources, although controversy could equally apply to other forms of

renewable energy, particularly where significant traffic and/or visual impacts may arise with

such developments.

In order for a local planning authority to test the context for drafting planning policies, it

might be felt appropriate, through the initial community involvement stages of plan making, to

invite views on what the community see as their overall vision for the subject. This could

provide the authority with an idea of the extent of any consensus on what the community

envisages and might accept within their own local area. The key words here are within theirown local area. Whilst it is not difficult to get a general consensus on the virtues that

renewable energy offers to society in general, it is a totally different consideration in how any

one local community sees its role and what that community would be prepared to accept in its

own back-yard.

As a consequence, the choices that are available to each local community need to be articulated

in a way i