Objectives of the consultation
The purpose of the consultation was to get stakeholder views and comments on the new draft planning policy which combined and updated the existing planning policy statements on climate change (PPS1 supplement) and renewable energy (PPS22).
This consultation document brought together the Planning and Climate Change supplement to PPS1 with the 2004 PPS22 on Renewable Energy into a new draft PPS on Planning for a Low Carbon Future in a Changing Climate. This new PPS will replace the 2007 and 2004 PPS and it is proposed that it will become a consolidated supplement to PPS1. The consultation closed on 1 June 2010.
To download the consultation documents, please follow the link below.
CIBSE supports the vision of an integrated approach to emissions reduction which is achieved through energy efficiency as well as low carbon energy generation which is consistent with the overall vision of a more sustainable built environment. Sadly, it is one of the few mentions of energy efficiency in the document, which rapidly develops into a statement about renewable energy far more than anything else. This is unfortunate, unbalanced, and will promote perverse outcomes.
CIBSE does not agree with the proposal that regional strategies should set ambitious targets for renewable energy and that targets should be expressed as a minimum amount of installed capacity in Megawatts (MW). This is a very command approach to the delivery of renewable. It is also very unclear how this approach can be implemented if the regional agencies in England are to be scaled back and to focus on business issues.
CIBSE does not support the proposed positive framework for renewable and low carbon energy to be taken into account in determining planning applications.This is another area where the policy omits to consider energy efficiency. We need to be careful that we do not favour buildings which meet the minimum energy efficiency standards of the building regulations, but then install considerable amounts of renewable or low carbon technology, driven by ambitious planning targets. This is not a rational outcome. It is far more cost effective to focus on passive design measures and on energy efficiency first. Once these have been fully addressed, then it may be appropriate to consider renewables. But it is far more economic to invest in efficiency and demand reduction than in renewable, in general. We should not develop planning policies that drive uneconomic energy generation installations.
To read the full CIBSE response, please follow the link below.