First Implementation
Submitted by admin on April 4, 2006 - 02:27.
7. FIRST IMPLEMENTATION
2-4 Willow Lane, Mitcham, Surrey
Developer – Chancerygate - http://www.chancerygate.com
Technical director for the developer:
Chris Boyd Cadogan Engineering 0141 270 7060 C.Boyd@cadoganconsultants.co.uk
Amended from internal LBM briefing Nov 04
7.1. Willow Lane was a 4,500sqm speculative commercial development comprising of 10 units of varying sizes that are likely to be occupied by a mixture of storage and distribution, light fabrication, partial offices, light manufacturing etc. The developer was Chancerygate, and they commissioned Cadogan Engineering consultants to undertake the feasibility study for responding to policy PE13. Planning permission was granted on 19th Aug 04.
This was the first time in the UK that a developer had been compelled to respond to a prescriptive renewable energy policy. Careful consideration needed to be given to the implementation of this policy, as this component of the application ensured that the Willow Lane development was unique. A number of issues, some unexpected, arose throughout the process and Merton liaised closely with many other boroughs, the GLA/LDA, various agencies, working parties, businesses and organizations etc.
Because of the renewable energy policies and proposals in the Mayor of London’s Spatial Development and Energy Strategies, and the new PPS22 guidance that establishes the legality of such policies, Merton was aware that there was considerable interest in this particular case, and as such, considered both the site specific and wider strategic issues involved.
Scope of policy
The policy wording is: “ALL NEW NON-RESIDENTIAL DEVELOPMENT ABOVE A THRESHOLD OF 1,000 SQM WILL BE EXPECTED TO INCORPORATE RENEWABLE ENERGY PRODUCTION EQUIPMENT TO PROVIDE AT LEAST 10% OF PREDICTED ENERGY REQUIREMENTS. “
7.2. Calculation methodologies
When implementing the policy it is reasonable to assess the energy/carbon requirements for the basic building services such as lighting and heating. It is also realistic to include office equipment such as computers, photocopiers, kettles, fridges, fax machines etc (BRECSU stuff). However, it is clearly impractical and unreasonable to include energy required for manufacturing or mechanised processes.
7.2.1. Energy/Carbon - clarification of policy interpretation
The policy should be interpreted through carbon emissions rather than raw energy usage. The London Plan, relating to the Mayor’s strategy is also being interpreted as referring to the total “Primary energy demand” of a development and that this will be measured in terms of the “Carbon burden of the energy demand and use”. This interpretation will ensure that the market is not distorted, electric heating is not encouraged, and the strategy gives due credit to reductions in CO2 emissions from the use of renewable energy resources.
To explain further: Heating with gas produces less CO2 emissions than heating with electricity. Regardless of which energy is used it takes about 17,000 kilowatt hours per annum to heat an average 3 bed mid-terraced house. Therefore if the policy is to generate 10% of 17,000 kWhpa (1,700 kWhpa) then it will amount to the same amount of renewables on the roof whether gas or electricity is used.
However, if the electrical energy is converted into kilograms of CO2 emissions per annum then an average home heated by gas emits about 4,500 kilograms of CO2 per annum as compared to 7,000 kgCO2pa for one heated by electricity. This is because gas for heating your home comes direct from the North Sea to your boiler, whereas electricity to heat your home comes from the gas being first piped to a power station where it is burnt to drive a generating turbine, and then as the electricity is carried down miles of copper cables to your home it looses some of its energy in the form of heat.
Therefore if we interpret the policy as requiring renewable energy to cut CO2 emissions by at least 10% then it will take a lot more equipment on the roof than it would to generate 10% of the raw energy needs. This will act as a deterrent for developers who may be tempted to install electric heating into new buildings, which is often a cheaper capital outlay.
Electric heating should also be discouraged because it is much more expensive for the end user resulting in fuel poverty and undermining the competitiveness of local businesses by increasing their monthly energy bills.
7.2.2. Energy/Carbon calculation methodology: Determined by current Building Regs.
7.2.3. Establishing baselines - general
The baseline used for calculating the predicted CO2 emissions of the development come from the Energy Consumption (ECON) Guides (in this case “Energy Efficiency in Industrial Buildings”, Sites Guide 18 and Benchmarking Tool for Industrial Buildings Guide 81), published (or listed) on the Carbon Trust website. A more comprehensive list of kilowatt hours per annum per square meter was compiled by Faber Maunsell for the London Renewables Toolkit – page 107: http://tinyurl.com/zdjh9
7.2.4. However, there is an urgent need to redefine the CO2 baseline data on which to anchor the policy because all these ECON guides are out of date with some going back as far as the 1980s. The other baselines available are the CIBSE guides, though these are composites of other data sets and are also completely out of date because like the ECON guides they make no allowances for the new Building Regs that demand a far higher standard of energy efficiency. Therefore there is a pressing need for the Government to commission new benchmark and “best practice” guides. Until they are in place it is only possible to use a rule of thumb approach to accounting for Part L of the B Regs – which is to deduct about 8% from the ECON guides kWhpa per m2 figure.
7.2.5. An alternative to generic building type guides is to concentrate on the specific building itself. The idea would be that a forensic assessment is made of the predicted CO2 emissions of the building, and that this is used as a benchmark for determining the 10%(+) policy. This is a sound approach – with a couple of caveats:
It is impossible to determine how many, and which of, of the 10 units will ultimately install water boilers. If some of them do not, then the wind turbines and PVs will generate more than the policy expectation of 10%.
If all the units are heated then the proposal above will deliver a CO2 reduction of 6.2%, which is clearly not sufficient for LBM to claim that they have successfully implemented the policy. The 10% could only be achieved if the final occupant installs energy efficient (condensing) boilers instead of conventional ones, and energy efficient lighting systems. This is only relevant of course if they want heating and comprehensive lighting. If it’s a white goods storage facility then they are unlikely to.
7.6.1. Therefore LBM required the developer to provide a cash fund as part of a section 106 agreement, that could be accessed by the final occupier to cover their additional costs of upgrading from conventional to condensing boilers, and from conventional to energy efficient lighting systems. Subject to final unit cost clarification the fund will need to be approximately £6,000. (It should be noted that from April 2005 CORGI registered heating engineers and companies will only be allowed to install condensing boilers and as such a new baseline will be established and this will need to be factored into the CO2 emission calculations.)
7.6.2. If the retrofit condensing boiler approach is progressed then the minimum level of overall CO2 reduction will be 17.6% of which 7.5% will come from on site renewable energy equipment. (This figure was collectively agreed by LBM as being acceptable at a corporate and political level. It should be stressed however, that the flexibility allowed in this specific case does not set a precedent that allows developers to assume that the 10% target has been abandoned. In any future cases 10% is the initial expectation. A developer will have to present a very robust argument as to why this target is not realistically achievable.)
The realistic maximum achievable is a total CO2 reduction of 21% of which 13% would come from renewable energy. Taking into consideration the average number of units likely to be used for storage and distribution, and therefore not requiring heating systems, it is reasonable to speculate that the most likely result will be a CO2 reduction of 19% of which 11.2% will come from renewable energy equipment. This is a reasonable “swings & roundabouts” approach to implementing the policy when dealing with shell build speculative commercial developments.
7.7. Advantages of this proposal
The Principal Environment Officer (with responsibility for implementing the policy) submitted the following to the DC officer dealing with the case.
“This is the first time that a developer has been required to respond to a prescriptive renewable energy policy in the UK. In view of this LBM has consulted widely with technical experts, the Greater London Authority and with officers, Councillors and interested individuals in Merton.
In line with GLA and Central Government thinking, LBM is interpreting the policy in terms of carbon emissions rather than raw energy usage. The London Plan, relating to the Mayor’s strategy is being interpreted (by GLA officers) as referring to the total “Primary energy demand” of a development and that this will be measured in terms of the “carbon burden of the energy demand and use”. This interpretation will ensure that the market is not distorted, electric heating is not encouraged, and the strategy gives due credit to reductions in CO2 emissions from the use of renewable energy resources, (Faber Maunsell Energy Consultancy report on behalf of GLA and DTI).
In response to PE13 the developer proposes to incorporate a combination of micro-wind turbines, photovoltaic solar panels, passive stack ventilation, and water saving taps and toilets and, custom designed recycling facilities, and use of recycled construction materials. However, the above measures alone will not completely deliver sufficient CO2 savings.
Therefore, the developer should be required to set aside a cash fund for 2 years as part of a section 106 planning agreement, that can be accessed by the final occupiers of the 10 commercial units, to cover their additional costs of upgrading from conventional to condensing boilers, and from conventional to energy efficient lighting systems.
The developer should also be required to liaise with LBM to ensure that only condensing boilers and energy efficient lighting systems are installed in any units that intend to install any form of water based heating or mains powered lighting. It is the view of the Business and Environmental Partnerships Unit and Plans and Projects section, that the proposed infrastructure measures, along with the set aside fund, adequately meets the expectations laid out in policies PE13 of the adopted UDP.”
7.8.1. Enforcement
This is discharged in the form of a Planning Condition stating that: “No works in relation to the development shall commence on site until the Local Planning Authority is satisfied that the proposed renewable energy equipment will cut CO2 emissions by at least 10%, and that their day to day operation provide energy for the development.”
7.9. General comments
7.9.1. Implementation – walking before running
At the time of writing, the idea of a prescriptive renewable energy planning policy is still fragile in the collective conscious of National, Regional and Local government. Many individuals and organisations in the business community are either openly hostile to, or understandably cautious of, such policies, arguing that they could compromise economic growth. With this in mind LBM resisted adopting a “demanding” or confrontational approach with respect to the Willow Lane (or in the short term, any other) development. Such thinking is in line with the LBM UDP inspector’s guidance that asked for the word “required” to be replaced by “expected”. At the risk of engaging in semantics it was felt that the word “expected” implied a degree of flexibility which might be more appropriate considering the radical nature of the policy.
7.9.2. With respect to Willow Lane, LBM accepted that by adopting a flexible approach it could have been perceived as having relinquished 2.5% of the 10% (if all the 10 units ended up being heated), and thus expose itself to the accusation of having been “weak”. It is also possible that if it appears to be letting the developer “off the hook” by not requiring full compliance, it could set a precedent for other boroughs that could possibly result in the 10% target being abandoned for something lower, ultimately reducing carbon savings in the long term. Developers should understand that by demonstrating flexibility in this (or any other) case, Merton does not imply that the 10% target is merely a figure to be bargained down from. Despite reservations, LBM concluded that by adopting a flexible, and subtle approach, it would be able to implement the policy successfully despite the uncertainties surrounding the occupation and energy usage/carbon emissions.
7.10. Consultation
Atmospheric conditions do not remain static over a specific geographical area, and therefore the potential benefits to Merton residents are inextricably linked to the widespread adoption of similar policies by other Local Authorities and Regional and National Governments. Collective action is the only way to deliver major CO2 reductions and as such Merton consulted widely with others on how to implement the policy. This consultation has been widened and become increasingly sophisticated as the national debate gathers pace, and more authorities adopt the policy. Germany, Spain and Portugal have a similar national policy so consultation with them was important. There is also a focus on academic institutes. Below is a list of consultees:
7.11. Implementation conclusion
The internationally recognised Sustainable Development orthodoxy is to adopt the precautionary principle in relation to climate change. In practice this means that whilst some sceptical individuals demand the right to continue the scientific debate, it is prudent to adopt remediation measures in the event that the worst-case scenario proves to be the reality. Similarly, the same principle should be adopted with respect to implementing this local renewable energy policy, at least until it is embedded more securely into the mainstream. To use a colloquialism - it’s always best to go easy on a first date! (LBM June 04)
7.11.2. Since the initial implementation phase has passed it is interesting to see that contrary to some expectations, Chancerygate is enthusiastic about the policy, seeing it as an opportunity for them to get ahead of the game in designing, building and marketing low carbon developments for the future, and they are now coming back with plans to build their second, third and forth development in the borough. The remorseless rise in grid energy prices means that they are increasingly confident that they can market the units at a premium. (AH LBM Jan 06) ___________________________________________________________
PE13/PPS22 lobbying:
Seb Berry – Renewable Power (Energy) Association (Solar Century)Joanna Collins – Sustainable Development Commission (Green Alliance)
Implementation:
Claire Bonham-Carter – Faber Maunsell
Eddy Taylor – LB Croydon
2-4 Willow Lane, Mitcham, Surrey
Developer – Chancerygate - http://www.chancerygate.com
Technical director for the developer:
Chris Boyd Cadogan Engineering 0141 270 7060 C.Boyd@cadoganconsultants.co.uk
Amended from internal LBM briefing Nov 04
7.1. Willow Lane was a 4,500sqm speculative commercial development comprising of 10 units of varying sizes that are likely to be occupied by a mixture of storage and distribution, light fabrication, partial offices, light manufacturing etc. The developer was Chancerygate, and they commissioned Cadogan Engineering consultants to undertake the feasibility study for responding to policy PE13. Planning permission was granted on 19th Aug 04.
This was the first time in the UK that a developer had been compelled to respond to a prescriptive renewable energy policy. Careful consideration needed to be given to the implementation of this policy, as this component of the application ensured that the Willow Lane development was unique. A number of issues, some unexpected, arose throughout the process and Merton liaised closely with many other boroughs, the GLA/LDA, various agencies, working parties, businesses and organizations etc.
Because of the renewable energy policies and proposals in the Mayor of London’s Spatial Development and Energy Strategies, and the new PPS22 guidance that establishes the legality of such policies, Merton was aware that there was considerable interest in this particular case, and as such, considered both the site specific and wider strategic issues involved.
Scope of policy
The policy wording is: “ALL NEW NON-RESIDENTIAL DEVELOPMENT ABOVE A THRESHOLD OF 1,000 SQM WILL BE EXPECTED TO INCORPORATE RENEWABLE ENERGY PRODUCTION EQUIPMENT TO PROVIDE AT LEAST 10% OF PREDICTED ENERGY REQUIREMENTS. “
7.2. Calculation methodologies
When implementing the policy it is reasonable to assess the energy/carbon requirements for the basic building services such as lighting and heating. It is also realistic to include office equipment such as computers, photocopiers, kettles, fridges, fax machines etc (BRECSU stuff). However, it is clearly impractical and unreasonable to include energy required for manufacturing or mechanised processes.
7.2.1. Energy/Carbon - clarification of policy interpretation
The policy should be interpreted through carbon emissions rather than raw energy usage. The London Plan, relating to the Mayor’s strategy is also being interpreted as referring to the total “Primary energy demand” of a development and that this will be measured in terms of the “Carbon burden of the energy demand and use”. This interpretation will ensure that the market is not distorted, electric heating is not encouraged, and the strategy gives due credit to reductions in CO2 emissions from the use of renewable energy resources.
To explain further: Heating with gas produces less CO2 emissions than heating with electricity. Regardless of which energy is used it takes about 17,000 kilowatt hours per annum to heat an average 3 bed mid-terraced house. Therefore if the policy is to generate 10% of 17,000 kWhpa (1,700 kWhpa) then it will amount to the same amount of renewables on the roof whether gas or electricity is used.
However, if the electrical energy is converted into kilograms of CO2 emissions per annum then an average home heated by gas emits about 4,500 kilograms of CO2 per annum as compared to 7,000 kgCO2pa for one heated by electricity. This is because gas for heating your home comes direct from the North Sea to your boiler, whereas electricity to heat your home comes from the gas being first piped to a power station where it is burnt to drive a generating turbine, and then as the electricity is carried down miles of copper cables to your home it looses some of its energy in the form of heat.
Therefore if we interpret the policy as requiring renewable energy to cut CO2 emissions by at least 10% then it will take a lot more equipment on the roof than it would to generate 10% of the raw energy needs. This will act as a deterrent for developers who may be tempted to install electric heating into new buildings, which is often a cheaper capital outlay.
Electric heating should also be discouraged because it is much more expensive for the end user resulting in fuel poverty and undermining the competitiveness of local businesses by increasing their monthly energy bills.
7.2.2. Energy/Carbon calculation methodology: Determined by current Building Regs.
- Electric energy - 1 kwhpa = 0.43 kilograms of CO2 per annum (revised at 0.46)
- Gas energy - 1 kwhpa = 0.19 kilograms of CO2 per annum
7.2.3. Establishing baselines - general
The baseline used for calculating the predicted CO2 emissions of the development come from the Energy Consumption (ECON) Guides (in this case “Energy Efficiency in Industrial Buildings”, Sites Guide 18 and Benchmarking Tool for Industrial Buildings Guide 81), published (or listed) on the Carbon Trust website. A more comprehensive list of kilowatt hours per annum per square meter was compiled by Faber Maunsell for the London Renewables Toolkit – page 107: http://tinyurl.com/zdjh9
7.2.4. However, there is an urgent need to redefine the CO2 baseline data on which to anchor the policy because all these ECON guides are out of date with some going back as far as the 1980s. The other baselines available are the CIBSE guides, though these are composites of other data sets and are also completely out of date because like the ECON guides they make no allowances for the new Building Regs that demand a far higher standard of energy efficiency. Therefore there is a pressing need for the Government to commission new benchmark and “best practice” guides. Until they are in place it is only possible to use a rule of thumb approach to accounting for Part L of the B Regs – which is to deduct about 8% from the ECON guides kWhpa per m2 figure.
7.2.5. An alternative to generic building type guides is to concentrate on the specific building itself. The idea would be that a forensic assessment is made of the predicted CO2 emissions of the building, and that this is used as a benchmark for determining the 10%(+) policy. This is a sound approach – with a couple of caveats:
- First: it is likely that the process (probably in the form of software toolkits being developed by the BRE, GLA and others) to carry out the assessments will be extremely complex – too complex for small developers and local authorities without the resources to outsource the task to dedicated energy consultants. In the initial pre-application phase it will only be possible to identify basic CO2 figures anyway, and a simple excel spreadsheet will suffice.
- Second: there is the temptation to become fixated by this subject. The advice to local planning departments is to recognise that renewable energy is like any other specialist technical subject and inevitably prone to being populated by geeks, anoraks and obsessives. They rightly take a great pride in getting to the bottom of things – but this can sometimes be at the expense of everyday comprehension.
Despite these reservations, the site-specific CO2 assessment approach is without doubt best for large and/or complex developments, but there is always a danger that fixating on it can become a wearying impediment. Mainstreaming renewables is the best way to cut CO2 emissions, and the best way to do that is to engender a culture where doing so is effortless, methodical and to the point of being unworthy of particular mention.
7.3. Willow Lane CO2 emissions
With reference to the Willow Lane, as a speculative development, it was impossible to establish a baseline energy/carbon footprint. Without knowing who the end users were going to be it was impossible to determine how much heating might be needed. As such it rules out water heating renewable technologies that might normally be used to pre-heat water for central heating and showers etc. This logic also applies to Ground Source Heat Exchange systems and Combined Heat & Power Units. Unlike electricity generating technologies it is impossible to sell the hot water on to a third party. The developer did not install heating (water boilers), or comprehensive lighting systems in the individual units, leaving the option of installing these to the final occupant. As such this confirms that the only energy/CO2 baseline agreeable with Chancerygate was the electrical energy usage, and that only electricity generating technology can be used to meet the policy in this specific case.
7.3.1. Merton and Cadogan agreed that the original carbon footprint = 108,200 kilograms of CO2 emissions per annum.
Therefore (in theory) LBM expected the developer to cut that carbon footprint by 10% (10,820 kilograms of CO2) through the use of renewable energy equipment. If however, the predicted CO2 emissions were reduced through the use of energy saving measures in the design of the building, then the CO2 reduction required through the use of renewable energy to meet the 10% would fall proportionately. With this in mind the policy should be considered as an incentive for the developer to design a more energy efficient building.
7.4 Water
Although water usage is not normally factored into a building’s carbon footprint, it is an issue of increasing importance. Atmospheric carbon is the accepted cause of global climate change, with water shortages one of the results of it. The Environment Agency is keen to see water saving measures incorporated into new building developments, and the installation of duel flush toilets, efficient taps and showers in the Willow Lane development will save around 700,000 litres per year. The current Building Research Establishment data on CO2/water is: 1 kWhpa per 1,000 litres of purified water. However, the projected increase in this ratio will likely triple to 3kWhpa per 1,000 litres by 2020. This will be as a consequence of increasing UK water shortages and the inevitable increase in infrastructure and power needed to maintain supply. With reference to the lifecycle of the Willow Lane development I have settled on a (conservative) ratio of: 2 kWhpa per 1,000 litres of water.
7.5 Infrastructure implementation proposal
Additional energy saving measures
- Water saving infrastructure
- Passive stack ventilation
- Install wind turbines x 10
- Install 5kWs of PV solar panels
It is impossible to determine how many, and which of, of the 10 units will ultimately install water boilers. If some of them do not, then the wind turbines and PVs will generate more than the policy expectation of 10%.
If all the units are heated then the proposal above will deliver a CO2 reduction of 6.2%, which is clearly not sufficient for LBM to claim that they have successfully implemented the policy. The 10% could only be achieved if the final occupant installs energy efficient (condensing) boilers instead of conventional ones, and energy efficient lighting systems. This is only relevant of course if they want heating and comprehensive lighting. If it’s a white goods storage facility then they are unlikely to.
7.6.1. Therefore LBM required the developer to provide a cash fund as part of a section 106 agreement, that could be accessed by the final occupier to cover their additional costs of upgrading from conventional to condensing boilers, and from conventional to energy efficient lighting systems. Subject to final unit cost clarification the fund will need to be approximately £6,000. (It should be noted that from April 2005 CORGI registered heating engineers and companies will only be allowed to install condensing boilers and as such a new baseline will be established and this will need to be factored into the CO2 emission calculations.)
7.6.2. If the retrofit condensing boiler approach is progressed then the minimum level of overall CO2 reduction will be 17.6% of which 7.5% will come from on site renewable energy equipment. (This figure was collectively agreed by LBM as being acceptable at a corporate and political level. It should be stressed however, that the flexibility allowed in this specific case does not set a precedent that allows developers to assume that the 10% target has been abandoned. In any future cases 10% is the initial expectation. A developer will have to present a very robust argument as to why this target is not realistically achievable.)
The realistic maximum achievable is a total CO2 reduction of 21% of which 13% would come from renewable energy. Taking into consideration the average number of units likely to be used for storage and distribution, and therefore not requiring heating systems, it is reasonable to speculate that the most likely result will be a CO2 reduction of 19% of which 11.2% will come from renewable energy equipment. This is a reasonable “swings & roundabouts” approach to implementing the policy when dealing with shell build speculative commercial developments.
7.7. Advantages of this proposal
- It provides an opportunity to possibly exceed the 10% renewable energy target if not all the units install heating systems.
- If some of the units do not ultimately have heating systems, then the developer could claim that they were being forced into providing more than 10% from renewables.
- Until technical evaluation proves otherwise, the current models of micro-wind turbines appear to be an efficient way of generating electricity for the capital outlay. It may also be that the technology that has limited application potential in urban areas, and the proposal to install 10 of them on an industrial park will provide an opportunity for further evaluation.
- The units to be installed (Windsave) are approx 1.5 meters in diameter and are sited on 4 meter high supports. They are extremely quiet (35db), and unobtrusive.
- Only 5 of the 10 units are orientated to suit PVs. The installation of 5kWs of (Poly-crystalline) photovoltaic panels will cover about 50sqm. It is likely therefore that the developer will install the complete 5kW system on only one of the five suitable units as this would cost less than installing 1kW on all five. This may raise the possibility of generating excess electricity if the unit is ultimately occupied by a low energy user.
- Water. Although the incorporation of water use into the carbon “footprint” has little effect on the overall figures, the issue is nevertheless of increasing importance (see above).
- It delivers an interesting range of measures, and can be promoted as a good example of a renewable energy/energy saving development.
- It proves that the policy can be successfully implemented in collaboration and partnership with a developer without confrontation and bad feeling, thus alleviating one of the key concerns of the ODPM, DTI, GLA and other local planning authorities.
- Considering the location of the site, and the current economic circumstances of London and the SE, it is reasonable for LBM to maintain that requiring additional photovoltaics at a cost of approx £70,000, might not compromise the commercial viability of this particular development.
- Because this is the first time the policy has been responded to in the UK, LBM should take the opportunity to prove that it is possible to implement the policy without compromising the viability of the development.
The Principal Environment Officer (with responsibility for implementing the policy) submitted the following to the DC officer dealing with the case.
“This is the first time that a developer has been required to respond to a prescriptive renewable energy policy in the UK. In view of this LBM has consulted widely with technical experts, the Greater London Authority and with officers, Councillors and interested individuals in Merton.
In line with GLA and Central Government thinking, LBM is interpreting the policy in terms of carbon emissions rather than raw energy usage. The London Plan, relating to the Mayor’s strategy is being interpreted (by GLA officers) as referring to the total “Primary energy demand” of a development and that this will be measured in terms of the “carbon burden of the energy demand and use”. This interpretation will ensure that the market is not distorted, electric heating is not encouraged, and the strategy gives due credit to reductions in CO2 emissions from the use of renewable energy resources, (Faber Maunsell Energy Consultancy report on behalf of GLA and DTI).
In response to PE13 the developer proposes to incorporate a combination of micro-wind turbines, photovoltaic solar panels, passive stack ventilation, and water saving taps and toilets and, custom designed recycling facilities, and use of recycled construction materials. However, the above measures alone will not completely deliver sufficient CO2 savings.
Therefore, the developer should be required to set aside a cash fund for 2 years as part of a section 106 planning agreement, that can be accessed by the final occupiers of the 10 commercial units, to cover their additional costs of upgrading from conventional to condensing boilers, and from conventional to energy efficient lighting systems.
The developer should also be required to liaise with LBM to ensure that only condensing boilers and energy efficient lighting systems are installed in any units that intend to install any form of water based heating or mains powered lighting. It is the view of the Business and Environmental Partnerships Unit and Plans and Projects section, that the proposed infrastructure measures, along with the set aside fund, adequately meets the expectations laid out in policies PE13 of the adopted UDP.”
7.8.1. Enforcement
This is discharged in the form of a Planning Condition stating that: “No works in relation to the development shall commence on site until the Local Planning Authority is satisfied that the proposed renewable energy equipment will cut CO2 emissions by at least 10%, and that their day to day operation provide energy for the development.”
7.9. General comments
7.9.1. Implementation – walking before running
At the time of writing, the idea of a prescriptive renewable energy planning policy is still fragile in the collective conscious of National, Regional and Local government. Many individuals and organisations in the business community are either openly hostile to, or understandably cautious of, such policies, arguing that they could compromise economic growth. With this in mind LBM resisted adopting a “demanding” or confrontational approach with respect to the Willow Lane (or in the short term, any other) development. Such thinking is in line with the LBM UDP inspector’s guidance that asked for the word “required” to be replaced by “expected”. At the risk of engaging in semantics it was felt that the word “expected” implied a degree of flexibility which might be more appropriate considering the radical nature of the policy.
7.9.2. With respect to Willow Lane, LBM accepted that by adopting a flexible approach it could have been perceived as having relinquished 2.5% of the 10% (if all the 10 units ended up being heated), and thus expose itself to the accusation of having been “weak”. It is also possible that if it appears to be letting the developer “off the hook” by not requiring full compliance, it could set a precedent for other boroughs that could possibly result in the 10% target being abandoned for something lower, ultimately reducing carbon savings in the long term. Developers should understand that by demonstrating flexibility in this (or any other) case, Merton does not imply that the 10% target is merely a figure to be bargained down from. Despite reservations, LBM concluded that by adopting a flexible, and subtle approach, it would be able to implement the policy successfully despite the uncertainties surrounding the occupation and energy usage/carbon emissions.
7.10. Consultation
Atmospheric conditions do not remain static over a specific geographical area, and therefore the potential benefits to Merton residents are inextricably linked to the widespread adoption of similar policies by other Local Authorities and Regional and National Governments. Collective action is the only way to deliver major CO2 reductions and as such Merton consulted widely with others on how to implement the policy. This consultation has been widened and become increasingly sophisticated as the national debate gathers pace, and more authorities adopt the policy. Germany, Spain and Portugal have a similar national policy so consultation with them was important. There is also a focus on academic institutes. Below is a list of consultees:
| LB of Croydon | Faber Maunsell |
| LB of Bromley | Fulcrum First |
| LB of Barking & Dagenham | Max Fordham |
| Other UK planning authorities | Bill Dunster Architects |
| Greater London Authority, LDA and LEP | Energy for Sustainable Development (ESD) |
| ODPM | Sustainable Energy Action (SEA) |
| DTI | Tata Energy Research Institute (India) |
| DEfRA | Fraunhofer Institut Solare (Germany) |
| PRASEG | Badenova Energy Services (Germany) |
| Environment Agency | Catalonian Institute of Energy |
| Energy Saving Trust | Instituto Superior Tecnico (Portugal) |
| Carbon Trust | Oxford University ECI and Begbroke Directorate |
| Engineering and Physical Science RC | UCL (Bartlett Institute) |
| Renewable Power Association | Imperial College |
| Combined Heat & Power Association | London School of Economics |
| Green Alliance | De Montfort University |
| National Society for Clean Air | Worcester Polytechnic Institute (Mass) |
| Solar Century | Massachusetts Institute of Technology |
| Arup | Columbia University (New York) |
7.11. Implementation conclusion
The internationally recognised Sustainable Development orthodoxy is to adopt the precautionary principle in relation to climate change. In practice this means that whilst some sceptical individuals demand the right to continue the scientific debate, it is prudent to adopt remediation measures in the event that the worst-case scenario proves to be the reality. Similarly, the same principle should be adopted with respect to implementing this local renewable energy policy, at least until it is embedded more securely into the mainstream. To use a colloquialism - it’s always best to go easy on a first date! (LBM June 04)
7.11.2. Since the initial implementation phase has passed it is interesting to see that contrary to some expectations, Chancerygate is enthusiastic about the policy, seeing it as an opportunity for them to get ahead of the game in designing, building and marketing low carbon developments for the future, and they are now coming back with plans to build their second, third and forth development in the borough. The remorseless rise in grid energy prices means that they are increasingly confident that they can market the units at a premium. (AH LBM Jan 06) ___________________________________________________________
PE13/PPS22 lobbying:
Seb Berry – Renewable Power (Energy) Association (Solar Century)Joanna Collins – Sustainable Development Commission (Green Alliance)
Implementation:
Claire Bonham-Carter – Faber Maunsell
Eddy Taylor – LB Croydon
