10% Renewables Requirement

[Adam2]

Hi, as part of my planning approval there is a condition:

 

8 Prior to the commencement of the development hereby permitted, details of the use of on-site
renewable energy sources to meet a minimum of 10% of predicted energy use of the residential
development, shall be submitted to and approved in writing by the Local Planning Authority and
subsequently implemented, retained and maintained.

Reason:
In the interests of delivering a sustainable scheme and reducing reliance on centralised energy
supply and in accordance with Policies PCS31, PCS32 and PCS35 of the Poole Core Strategy
adopted 2009 and guidance contained within Section 10 - Meeting the challenge of climate change,
flooding and coastal change of the National Planning Policy Framework (March 2012)

 

We're expecting to use an ASHP for UFH and DHW as well an MVHR + will have a reasonable degree of solar gain. Would appreciate thoughts on how this applies to the above as we're not wanting PV or solar thermal - these would seem to be more obviously "on-site renewable energy sources". Using ASHP, MVHR should contribute towards a greater than 10% reduction in predicted energy use. 

 

Appreciate your experiences with any similar conditions and how you documented meeting them (without PV, solar thermal, other more obvious on-site renewable energy sources).

 

Thanks

Adam

[Mr Punter]

ASHP and MVHR are not renewable energy sources.  Solar PV seems most sensible unless you are constrained by Conservation Area, Listed Building or design practicality issues, in which case write to ask that the condition be removed or deemed satisfied.

[ProDave]

Arguably an ASHP IS "renewable" energy because it is extracting heat from the air to heat the house and hot water.

 

Have you had a SAP assesment done of the proposed house yet? That will tell you the expected energy usage.

 

What have you against solar PV? By far the easiest way to achieve self generated power.

[ADLIan]

I often see this planning requirement - sometimes asking for a general 10% improvement (allowing the use any measure to reduce CO2 emissions) and sometimes specifying that it must be achieved using 'renewables'.

 

I would check with the Planning Dept as to what they will allow here as often heat pumps, combined heat & power and biomass are acceptable (perhaps strictly not 'renewables' however). MVHR is not classed as a 'renewable'.

 

A heat pump should get your 10% reduction very easily!

[Stones]

Yes, seen this condition numerous times.  Generally speaking, fitting an ASHP was the easy answer / accepted and approved by the planning authority.

[Adam2]

54 minutes ago, Mr Punter said:

ASHP and MVHR are not renewable energy sources.  Solar PV seems most sensible unless you are constrained by Conservation Area, Listed Building or design practicality issues, in which case write to ask that the condition be removed or deemed satisfied.

 

Thanks - yes that was my initial thought. PV is not good due to mono-pitch roof going wrong way and some shading on flat area. 

Then I was thinking if you get RHI for ASHP then maybe all is OK ?

 

27 minutes ago, ProDave said:

Have you had a SAP assesment done of the proposed house yet? That will tell you the expected energy usage.

 

We're doing a bit of a redesign so will being on to that in 2-3 weeks

 

Thanks also @ADLIan and @Stones - reassuring. Will check with planning as there is nothing I can find on their policy docs providing more detail. If the SAP specifies X as a heating and DHW requirement and the ASHP use reduces this by >10% that should be a simple doc to submit and have approved. And less cost to achieve than I just saw as a quote from a firm my architect went out to get a quote for a report on this ! Spending other people's money is easy for them - I like them just not aligned to my cost management ideas ?

[Alex C]

Not sure on the spec of your build but my council planners agreed to remove this when I told them I was building a passive spec house. They were happy to be shown I would be using far less energy to heat the house than a normal building reg standard new build.

[willbish]

30 minutes ago, Adam2 said:

that should be a simple doc to submit and have approved

Agreed. I had v similar condition and sent the LPA my own document which didn't spark any response. Of course the format was plagiarised from a similar planning application!

Happy to send you both if you would like.

[Ferdinand]

I would be surprised if this condition passes muster under the six tests, as it imposes a method ... provide 10% renewables. It seems rather inept.

 

The best form of saving under the R hierarchy is probably Remove, not Reduce or Renewable. So surely this would be met by eg adding in enough insulation to be 10% better than Building Regs basic?

 

Then the 10% renewables are not required since the energy is not being used at all.

 

Has one ever been appealed?

 

F

Edited January 17, 2019 by Ferdinand

[Temp]

Perhaps worth looking at the policy documents cited to see if they mention heat pumps.

 

If the COP of the ASHP is say 3 then it consumes 1kW for every 3KW delivered. So compared to electric rads/immersion heater you could argue your ASHP delivers 66% of the heating/dhw from a renewable source.

 

Aside: Here it says that an EPC doesn't have an option for both "PV and ASHP" or has that changed?..

http://www.greenbuildingforum.co.uk/newforum/comments.php?DiscussionID=12156

[Adam2]

19 hours ago, willbish said:

Agreed. I had v similar condition and sent the LPA my own document which didn't spark any response. Of course the format was plagiarised from a similar planning application!

Happy to send you both if you would like.

Thanks if you could that would be appreciated ?

[Adam2]

19 hours ago, Ferdinand said:

The best form of saving under the R hierarchy is probably Remove, not Reduce or Renewable. So surely this would be met by eg adding in enough insulation to be 10% better than Building Regs basic?

Yes agree - they really need to develop a more appropriate policy as many may well not think to challenge so may ultimately be led down the path of a less effective fabric/overall design