‘Renewable Energy Strategy for Bournemouth,

Dorset and Poole to 2020’

Summary of Consultation Responses & Amendments

1.  BACKGROUND

The Local Authorities in Dorset, Bournemouth and Poole together with key stakeholders are in the process of reviewing the Renewable Energy Strategy for the area which was first adopted in 2005. A Consultation Draft, informed by an ‘Issues’ paper[1], a public opinion survey, a technical assessment of renewable energy resources and a stakeholder consultation event held in Dorchester in March 2011, was published in May 2011. Two additional stakeholder events were later held in Bournemouth and Poole during September 2011, with views expressed at these informing the relevant Local Authority Response to the Consultation. The Consultation Draft was sent out to key stakeholders and made available for wider public consultation via the ‘Dorset for You’ Website for a 12 week consultation period, which was subsequently extended by a further 4 weeks. Comments were received by Dorset County Council (DCC), which is co-ordinating the revision of the Strategy on behalf of all the Local Authorities in Dorset, Bournemouth and Poole.

2.  PURPOSE OF THIS DOCUMENT

This Document summarises the responses received to the Consultation Draft, and gives the responses and recommended changes to the Strategy arising from consideration of these comments by the Bournemouth, Dorset and Poole Low Carbon Partnership, an officer group representing each of the Local Authorities and other key stakeholders. These responses and recommended changes will inform the final draft Strategy, which will be put before each Local Authority within Dorset, Bournemouth and Poole for endorsement. It is hoped that by responding positively to comments made during the consultation exercise, the final Strategy will be endorsed not only by the Local Authorities but by many of the organisations and individuals who took the time to comment. Dorset County Council (DCC) would like to thank all those who commented on behalf of all the Local Authorities involved.

3.  SUMMARY OF CONSULTATION RESPONSES

In total 186 responses were received to the Consultation from individuals (149) and stakeholder organisations (37). Many consultees did not respond directly to the Consultation others made multiple comments under a single question.

Over half of all the responses came from individuals supporting one of two campaigns and using a standard or very similar letter. The first expressed concerns about onshore wind, principally landscape issues but also noting concerns such as noise, flicker effect, and impacts on bats, birds etc. The second campaign expressed concerns about importing palm oil and other bio-fuels for use in large scale biomass power plants, such as at Portland.

4. NEW INFORMATION ARISING SINCE THE CONSULTATION DRAFT WAS PUBLISHED

Shortly after the Consultation Draft Strategy was published, the Department of Energy and Climate Change (DECC) published a Renewable Energy Roadmap for the UK to 2020 (July 2011.) Our interpretation of this indicates that at least half of the UK’s 2020 renewable energy target could be met from “national level” renewable energy deployment, such as off-shore wind, biomass electricity (with a large contribution from centralised biomass power stations, most burning imported wood chips or liquid bio-fuels) and renewable transport (the latter mainly based on liquid bio-fuels, also likely to be imported).

This has significant implications for Bournemouth, Dorset and Poole in the sense that it means that, even if we were to take no action locally, it would be reasonable to assume that about half of a 15% target might be contributed from national projects over which we would have limited local control. It also means that some of the figures used to illustrate potential scenarios in the Consultation Draft, including the figure of 180 wind turbines, which was the subject of significant concern, need to be revisited. If the ‘National’ Contribution is taken as a given, Dorset’s Strategy could arguably focus on meeting the remaining half of a 15% target from its own preferred mix of technologies. If relying on the National Contribution is not seen as a desirable option, other renewable technologies would need to be deployed more fully if the area were to meet a 15% target.

As such, while the Road Map certainly does not absolve Dorset of its responsibilities to promote renewable energy, it does help clarify the areas on which the Strategy might usefully focus by helping us differentiating between national resources, which we can expect to be deployed regardless of local action, and the remainder over which we have more influence and control.

5.  CONTROVERSIAL ISSUES

This section covers some of the most controversial issues emerging from the Consultation, and the responses and recommended changes to the strategy arising as a result:

Strong general support versus concern over specific technologies

There is an apparent contradiction in the strong general level of support for renewable energy, which contrasts with the strong opposition in some areas to specific technologies, particularly on-shore wind. Opponents of on-shore wind would say that it is easy to be positive about renewable energy until an industrial scale wind farm is proposed in your neighbourhood. Supporters of on-shore wind would say that parochial objections should be subservient to the over-riding need to reduce reliance on fossil fuels for reasons of climate change, energy security and so on. In this sense renewable energy is like many other forms of potential development, in that, while many regard it as a ‘good thing’ in general they are understandably concerned when it affects them more directly. There is, however, a strongly positive National Policy Commitment to renewable energy, reinforced in many local plans and strategies, which has to be taken into account as the Strategy is finalised and which informs the recommended changes below.

Concerns that imported bio-fuels for large scale power stations is unsustainable

The sustainability of imported bio-fuels/ bio-liquids (i.e. plant derived oils) and imported biomass for electricity generation (mainly woodchips) is a complex and controversial area. The vision and aims of the Strategy emphasise ‘providing local, affordable and secure energy supplies’ and these are regarded as important criteria against which schemes should be tested. It is important to clarify that the Strategy does not and cannot rule out any reliance on imported biomass or bio-liquids where these can be shown to be sustainable; rather, it underlines a commitment to local self-sufficiency as far as possible.

The EU has set out sustainability criteria for bio-liquids used for heat and electricity generation, which must be demonstrated before the energy produced qualifies as a contribution to national renewable energy targets or is eligible to receive national subsidies, such as; Renewable Obligation Certificates (ROCS).

The Department of Energy and Climate Change (DECC) is phasing in similar sustainability standards for biomass (woodchips) over the period March 2011- March 2013[2]. There will be a minimum 60% Greenhouse Gas emission saving for electricity generation using solid biomass or biogas relative to fossil fuel.

However, many concerns remain including the practicality of monitoring the sustainability criteria in remote rural areas in SE Asia and S. America, the food verses fuel debate and security of supply arguments around meeting UK national Renewable Energy Roadmap target through the proposed import of 23.6 million tonnes of woodchips per year by 2020 to be burned in power stations3.

Note that if there is less reliance on imported woodchips and bioliquids there will be a requirement to produce a higher percentage of renewable energy from the UK’s indigenous resources to meet the legally binding 15% renewable energy target by 2020.

Concerns over the purpose of the strategy

Some respondents were concerned that the Strategy might result in specific developments being approved which might otherwise not have been or that the Strategy was proposing the development of particular schemes or numbers of particular technologies in particular locations. The parties to the Renewable Energy Strategy have been clear from the outset that is not the role of the Strategy to support or oppose specific technologies or site specific developments. Rather it is to set out a clear, shared ambition for renewable energy in Dorset and identify where local action should focus to maximise the benefits for Dorset while protecting and enhancing our unique environment.

The Strategy is a non-statutory document, and while it is clearly intended to create a positive and proactive climate for the deployment of renewable energy, decisions on individual schemes will remain, as now, the preserve of local planning authorities and/or government via the planning system. Recommended changes to the Strategy seek to clarify this point.

Desire for exemptions for certain areas from some kinds of development

It was suggested by some respondents that certain areas or even whole Districts within Dorset could be exempt from certain kinds of renewable energy development, specifically on-shore wind. While designated areas like AONBs certainly enjoy protection from (but not complete prohibition of) large scale developments of any kind, it would be unrealistic and unenforceable for the Strategy to propose this for any local authority administrative area. It would also run contrary to the spirit and letter of many national and local plans and strategies. Moreover, the evidence collated in developing the Strategy suggests that, given the low starting point for renewable energy generation in Dorset, the high level of ambition supported by most respondents is unlikely to be achieved by reliance on any one technology, or by ruling out any one technology, particularly those which currently offer potential investors the best return on their investment. The economics of the energy market may be far from perfect, but we can not wait for them to become so before taking action to reduce our contribution to climate change and improve our energy security.

Criticism of the methodology used in the renewable energy resource assessment

Some respondents were critical of the methodology used in the renewable energy resource assessment, particularly CPRE which commissioned a critique of this methodology among other things. The methodology used was, however imperfect, a nationally accepted method which was being used to conduct similar assessments around the country. If the results of this assessment had simply been transferred into the Strategy without reference to other evidence then this would be a legitimate concern. In reality, however, the resource assessment has been one piece of evidence among many which will inform the final Strategy and the recommended changes summarised below should offer further reassurance to those who expressed concern on this point.

6. HEADLINE CHANGES TO THE STRATEGY

Taking into account the responses to consultation, Government policy and the other evidence collated to inform the review, the proposed changes to the Strategy will seek to:

·  Clarify the implications of the Government’s Renewable Energy Road Map by setting a twin-track target for Dorset of 15% including those resources considered as ‘national’ and 7.5% for those resources which are considered as local and which are more within local control. In effect this dramatically reduces the number of renewable energy installations, particularly on-shore wind turbines, which might have been implied by the illustrative scenarios used in the Consultation Draft published in May.

·  Clearly articulate the work which is already underway within Dorset to address many of the concerns raised, particularly the work to develop and implement a methodology for landscape sensitivity analysis and the development of local energy plans identifying renewable resources suited to the local areas needs and constraints.

·  Provide clear, concise information on the range of renewable technologies available clearly explaining their strengths and weaknesses

·  Show the relative and realistic potential of different renewable technologies rather than promoting any one technology over another, reflecting the fact that decisions on individual schemes will remain the preserve of local planning authorities and /or other relevant authorities via the planning system.

7. CHANGES TO THE STRUCTURE OF THE STRATEGY

The overall structure of the final strategy will also be revised in response to the comments received. Key changes are noted below:

·  The Strategy will become a stand alone document collating relevant information into one place

·  The Strategy will have a concise Executive Summary which makes reference to the main body of the report

·  The Strategy will have a section for each of the six priority areas for action (community, economy, technology, planning, leadership and communications). Each of these will be referred to as a ‘ priority area for action’

·  Each ‘priority area’ will be expanded to include – An introductory context, a summary of action already underway, relevant issues, opportunities and barriers.

·  Each section will also outline the ‘strategic actions’ required for the priority area. ‘Strategic actions’ will be based on those within the consultation draft and the consultation responses below.

·  ‘Strategic actions’ will be more concise and reworded to remove any bias in language and to ensure they are high level and long lasting.

·  The ‘unpacking the technologies’ section of the original Bournemouth , Dorset & Poole Renewable energy strategy (2005) will be updated and included as an appendix. This will provide details and opportunities/issues relating to each renewable energy technology.

8. Issues raised and suggested amendments to strategy

Rather than listing each comment made and the recommended response to it, which would risk repetition, this document groups similar comments made by different consultees to which the same response applies. If individual respondents do not recognise their comments they are invited to contact Antony Littlechild at Dorset County Council (email: ) who should be able to provide an explanation of how their comments been taken into account.

Issue & comments / Comments & Suggested amendment / Reference to Final strategy
Q1. Do you agree with the setting of an aspirational target for Bournemouth, Dorset and Poole to generate more than 15% of its total energy needs from renewable energy sources by 2020?
Q2. If not what target would you use instead?
82% of respondents who replied to these questions supported the proposed aspirational target. / Since the publication of the consultation draft the National Renewable Energy Roadmap has been published.
The Strategy will clarify the implications of the Roadmap for Dorset in particular the technologies considered to be national and local and how this could affect the target for Dorset.