Memorandum submitted by the East Midlands
Regional Assembly
The East Midlands Regional Assembly is the regional
chamber for the East Midlands. It consists of 111 members drawn
from elected representatives of the regions local authorities,
together with business, social and environmental partners. The
Assembly is responsible for scrutiny of the Regional Development
Agency and is the Housing Planning and Transport body for the
region. The Assembly is also responsible for coordination and
integration of regional strategies.
The East Midlands Regional Assembly, in its
role as regional planning body has been reviewing the Regional
Spatial Strategy. As part of this review a range of studies were
completed to aid the policy making process. Studies of the carbon
footprint and trajectories to 2026 indicated clearly a need to
respond rapidly to the reduction of the carbon emissions of all
new development. (The draft Regional Plan and supporting research
is available on http://www.emra.gov.uk/what-we-do/housing-planning-transport/rss-review/documents
).
Carbon neutral new development is essential
to ensure that there is no overall increase in the East Midlands
carbon footprint. To this end the Draft RSS included policies
for carbon neutral new development. The East Midlands Regional
Assembly, as the regional planning body recognised that delivering
carbon neutrality is a challenge and sees opportunities for bringing
action on current housing stock into the planning process.
Policies in the Draft Plan have been drafted
to be fit for purpose over the plan period. The choice of carbon
neutrality as a target for new development mirrors the recent
signposting from government policy, particularly with the Code
for Sustainable Homes. The Assembly recognises that the challenge
of delivering carbon neutral homes is significant and Policy 38
of the Draft Plan is designed to allow local authorities to develop
appropriate policies for their own location and development market,
recognising the diversity of the regional property market and
the range of different development that might occur across the
region over the Plan period.
Whilst this approach offers flexibility to planners
and developers, it would be helpful to highlight possible approaches
that might be appropriate for more detailed local policy. The
ideal development is one that is designed to reduce the demand
for energy from the building, then use energy efficient appliances
throughout the development and supply all remaining energy needs
from renewable energy sources on or close to the site, reflecting
the energy hierarchy that underpins Policy 38. This development,
would then be a true zero carbon development. However, this ideal
would currently pose a significant burden on developers and it
is not clear that the capacity in skills and supply chains is
yet in place to enable it to be delivered. Developers should still
seek to deliver significant carbon savings through increasing
thermal efficiency and some level of on site renewables on all
developments, but the following options are offered as ways that
carbon neutrality could be delivered:
Developments that cannot deliver 100% renewables
on site practically or without excessive cost could meet carbon
neutrality by:
— The developer could invest in offsite
renewable generation at a capacity that covers the expected energy
usage of the development over a specified life time. This approach
offers the developer a practical way to offset on site emissions
by equivalent generation and may be a cost effective business
approach to carbon neutrality. This approach may be particularly
useful for mixed usages sites, as industrial scale units may provide
a better basis for economic renewable energy supply.
— Local authorities may wish to negotiate
a contribution from developers for the estimated carbon emissions
from the site and use the contribution for improving the thermal
efficiency of existing housing stock within the local authority
area. This approach may be particularly useful for local authorities
with large stocks of housing with poor thermal performance, giving
a resource to dramatically reduce emissions from existing stock.
The local authority could also use the contribution to install
renewable energy at local schools and community facilities, offering
cost effective carbon reductions, community benefits and awareness
raising opportunities.
— Developers may wish to develop some
sites with renewable energy generation that has more capacity
than required by that site. For example by installing a biomass
generation plant close to one site and using the excess generation
capacity to offset the emissions from another site within the
same planning area.
— Developers may wish to enter into
agreements with registered social landlords to offset emissions
from their private developments, through improvements to social
housing stock.
— Ensuring that all homes are signed
up to a recognised green tariff. This approach is comparatively
easy for a developer to achieve, but has the disadvantage that
the occupants of the houses can change to a normal tariff at any
point after occupancy.
— In general offsetting through tree
planting should be the lowest of all options and should not be
used to offset the full balance of carbon emissions from a site.
Where tree planting is offered the trees planted should be native
British trees to support biodiversity gains.
The targets in the Draft Plan include significant
micro-generation quantities to reflect the importance that on
site renewables are likely to play in the next few years. The
research completed to support policy development indicates clearly
that a mixture of large and small scale renewables as well as
energy efficiency are essential for delivery of the 20% by 2020
targets. However, larger scale technologies are generally more
efficient and cost effective at delivering carbon emission reductions
and future policies and drivers could significantly alter the
uptake of micro-generation positively or negatively. The policies
also recognise the role of fossil fuels and other technologies.
LDFs could include policies for the development of both targeted
amounts of onsite renewables and emissions reductions from the
above suggested flexible solutions, with carbon reductions being
delivered within the planning authority area to aid monitoring.
The Regional Assembly will promote these flexible approaches to
local planning authorities.
The East Midlands Regional Assembly feels that
a number of these options provide opportunities for coordinated
action on current housing and could be targeted specifically at
hard to treat homes, that currently fall outside the government
funding regimes. The large scale treatment of existing homes by
developers also offers economies of scale and engages those best
placed to deliver the works. Economic benefits of new business
and supply chains are also likely.
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