The N3P must conform to both national and local government polices. In the case of energy this is led by government, and sometimes international law, as in the Paris Agreement. We have put together the following policy statements in keeping with this and the Joint Local Plan (JLP). They relate to decarbonizing our energy and mitigation of climate change. The references are to the appropriate section of the JLP.
1. Buildings Efficiency & Sustainability (SPT1 & SPT2 DEV34)
Proposals for housing development must demonstrate how the energy requirements of the development will be met from renewable and low carbon energy sources. The NPPF states, “local planning authorities should adopt proactive strategies to mitigate and adapt to climate change (In line with the objectives and provisions of the Climate Change Act 2008).”
Policy N3P.ENV.1 “Developers must demonstrate that all feasible steps have been taken to ensure the buildings are energy-efficient and make maximum use of local renewable energy sources where possible”.
Note: We could actually achieve this NOW by supporting our local community energy organization’s work (Yealm Community Energy) and local Solar Farm, which will generate more clean energy than the total annual consumption of the current parish! This could be written in as a Merton-style rule in the housing policy.
This is particularly important as the homes we build today will still be in use in 2050 when by law our housing stock must be almost zero carbon. It is far more costly to retrofit as regulations tighten, and it can be done now more cheaply and more efficiently (see UK Carbon Plan, HMGov. 2011, p.30). We can achieve Affordable Housing at PassivHaus standards of Zero carbon with south Devon architects. (information is available from firstname.lastname@example.org )
Other NPs have incentivized higher efficiency standards than current Building Regulations demand, and the following policy is suggested for the N3P:
Policy N3P.ENV.2 Where it can be verified that new residential developments have exceeded (verified post occupation) the requirements of Building Regulations part L1A (conservation of heat and power, new dwellings) any Local Authority taxes levied on the development on behalf of the community should be refunded (e.g. Local Infrastructure Levy).
A lot of research has gone into the policies behind the N3P. Most of this will be included in the Community Action Plan, in which the detail behind the N3P will reside. The following policy draws attention to this resource:
Policy N3P.ENV.3 For domestic self-builds and major refurbishments the self-builders will be expected to have complied with any relevant guidance provided by the Community Action Plan.
Policy N3P.ENV.4. “Where possible, domestic & non-domestic buildings should be orientated to have a south-facing roof and constructed so as to be able to accommodate PV solar panels for present or future use. These should be incorporated in the development during construction unless it can be demonstrated that to have done so would have made the development non-viable by independent assessors.”
2. District Heating (DV35)
The government is encouraging the deployment of district heating networks. They can be retrofitted, but are cheaper and easier to install in new developments. This is achieved with a centralised boiler leading off to individual houses providing cheaper and low carbon heating.
Policy N3P.ENV. 5 “New developments (5 or more houses) will be expected to deliver an onsite heat network, unless demonstrated by independent assessors that this would render the development unviable, or where it can be demonstrated that a lower carbon alternative has been put in place e.g. Passivhaus standard of build.”
3. Older Buildings
Improving the comfort of historic buildings by improving their energy efficiency is often thought impossible due to planning difficulties or detracting from the appearance. But this has been done in Bath and North East Somerset, which has a huge stock of historic buildings. They have model policy wording which could be applied in our case. (See also https://historicengland.org.uk/advice/technical-advice/energy-efficiency-and-historic-buildings/ )
Policy N3P.ENV.6. “The sensitive retrofitting of energy efficiency measures in historic buildings will be encouraged, including the retrofitting of listed buildings, and buildings within conservation areas. Historic buildings should be retrofitted in line with current guidance from Historic England”
Policy N3P.ENV.7 “Where an existing building is extended or refurbished, or there is a change of use: thermally efficient building materials; double glazing; cavity wall and loft insulation will be included where technically feasible, and the rest of the property upgraded so that the average SAP* rating will be improved or increased by a grade (e.g. from E to D)”
*Standard Assessment Procedure based on energy efficiency of building.
4. Renewable Energy Policy
The NPPF states: “local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources.”
The Joint Local Plan states in Policy Dev 36 (p.276) that community-led energy efficiency and energy generation projects will be supported where:
- The impacts arising from the proposal are acceptable or can be made acceptable.
- They are community led and there is evidence of community consensus in support of the proposal and/or the proposals are brought forward as part of neighbourhood planning processes.
- The proposals deliver local social and community benefits. There are administrative and financial structures in place to deliver/manage the project and the income stream from it.
The government has promoted community energy, which it defines as being ‘collective action to reduce, purchase, manage and generate energy’. Community energy projects have an emphasis on ‘local engagement, local leadership and control and the local community benefiting collectively from the outcomes’. Community-led action can often tackle challenging issues around energy, with community groups well placed to understand their local areas and to bring people together with common purpose.
Community-led energy development proposals will be required to address impacts of the development in the same way as any commercial scheme. However, the LPAs consider that community-led schemes have the potential to offer significant and greater sustainable development benefits than wholly privately owned and operated developments. These benefits should be elaborated fully in applications for consent.”
Policy N3P.ENV.8 “Renewable energy applications will be approved if their impacts are (or can be) made acceptable to the community visually and in respect of the local AONB and SSI. We wish to at least match at local level the UK’s 2050 Target to reduce GHG emissions by 80% in 2050 from 1990 levels.”
We believe this can be easily achieved by encouraging increasing the energy efficiency of our housing stock, domestic & commercial roof-top solar, and by incorporating the local solar farm in our energy mix.