Thank You for Consulting Us About the Draft Supplementary Planning Document on Renewable Energy

Mr R Cottrill

Director of Planning

Tunbridge Wells Borough Council

Town Hall

Tunbridge Wells

Kent TN1 1RS8 December 2006

Dear Mr Cottrill

Thank you for consulting us about the Draft Supplementary Planning Document on Renewable Energy.

The Civic Society welcomes this report, which builds on the strategy for the conservation of Kent’s environment and resources in the Kent and Medway Structure Plan. It sets out clearly the advantages of renewable energy and the sources of it that can be readily integrated into building design. It provides a clear policy statement of the Council’s intention to seek a 10% reduction in carbon emissions from major new building and refurbishment, and guidance on the methodology for calculating this.

The draft is described as `a key document in reducing carbon emissions`, but this possibly over-states its significance. Even within the context of limiting carbon emissions from buildings, it seems largely directed at residential building, and only at building use not building construction. It is thus not surprising that its most specific recommendations are for reduced consumption and passive measures, insulation etc, already well-covered by the current Part L of the Building Regulations.

Moreover with the policy only applicable to major building proposals subject to development control, there is no effect on emissions from the vast majority of existing buildings. For example a ten percent reduction in carbon emissions from say two per cent of the building stock over ten years would have a negligible impact on total emissions, and one easily offset by increases in emissions from transport.

There is a useful appendix on the potential of different sources of renewable energy, though in the context of a town like Tunbridge Wells this probably exaggerates the potential of wind generation (besides quoting figures from the notoriously optimistic `wind lobby`), as opposed to biomass, most obviously wood in this area – a scaleable technology within reach of many householders. The Civic Society would have serious misgivings about the widespread adoption of rooftop windmills.

Section 3 of the report implies that the required reduction in notional emissions could be achieved by on-site generation, but there is a curious lack of specific reference to this. It would be generally helpful to have guidance on the Council’s policy towards micro-generation within homes, or better still small-scale stand-alone generation or Combined Heat and Power. Broadly the report doesn’t deal with what the Council will do, as opposed to what it expects others to do.

We welcome the report’s relating of climate change and carbon emissions to the much larger inter-connected issue of resource use. While carbon emissions are prominent at present because they are measurable, and there are Government policies and treaty obligations attached to them, the national if not worldwide imperative is to make better use of what we’ve got. Tunbridge Wells is as well placed as anywhere to take a bold initiative over this, and to link its renewable energy objectives to other policy priorities.

We trust you will find these comments constructive.

Yours sincerely

Alastair Tod