Part One: Spatial Strategy and Policies (Regulation 19)
Energy Infrastructure
12.13. The NPPF states that plans should take a proactive approach to mitigating and adapting to climate change. Development should be planned for in ways that help eliminate greenhouse gas emissions, such as through consideration of its location, orientation and design.
12.14. To help increase the use and supply of renewable and low carbon energy and heat, plans should provide a positive strategy for energy from these sources. Policy DLP42 sets out how energy infrastructure will be considered, including how opportunities for decentralised energy and communal heating will be identified.
Policy DLP42 Energy Infrastructure
- Decentralised energy networks and communal heating provision
- Any development including ten homes or more, or non-residential floorspace of 1,000 sq. m or more must include opportunities for decentralised energy5 provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat6 or decentralised power networks.
- In instances where on site provision is not possible in accordance with point 1a, where there is existing decentralised energy provision available close to the site, the development will be expected to link into it, or should be designed to accommodate a subsequent connection7 if a source has not yet become operational. Information on this linkage should be included in a design and access or planning statement, which should also explain how access to a decentralised network can be achieved in the future if it is not currently operational or available
- Where developers can demonstrate to the satisfaction of the LPA that a link to an existing or committed decentralised energy source nearby is not feasible or viable, the local authority will support the provision of alternative onsite carbon elimination measures that can be incorporated into the scheme (see Policy DLP47).
- Proposals intended to deliver decentralised networks and related infrastructure will need to prevent or minimise any adverse impacts on the historic environment by ensuring that they protect the significance of heritage assets, including their setting.
Onsite energy provision
- Developers should engage with relevant energy companies and bodies at an early stage in the development process to establish the likely future energy and infrastructure requirements arising from large-scale development proposals including 100 homes or more, or non-residential floorspace of 10,000 sq m or more. Proposals for addressing energy provision on such sites should be developed and agreed between the local planning authority and developer(s) to establish the lowest lifetime carbon energy provision. Information to support the preferred solution(s) should identify and address:
- current and future major sources of demand for heat (e.g. sites such as industrial / manufacturing sites, universities, large-scale sporting or leisure development, hospitals and social housing);
- demands for heat from existing buildings that can be connected to future phases of a heat network;
- major heat supply plant;
- possible opportunities to utilise energy from waste or waste heat from industrial processes;
- opportunities for heat networks;
- opportunities for private wire electricity supply;
- possible land for energy centres and / or energy storage;
- possible heating and cooling network routes;
- infrastructure and land requirements for electricity and gas supplies;
- implementation options for delivering feasible projects, considering issues of procurement, funding and risk, and the role of the public sector.
- Where applicable the local authority will:
- identify any necessary energy infrastructure requirements, including upgrades to existing infrastructure;
- identify existing heating and cooling networks and opportunities for expanding existing networks and establishing new ones.
Heating / hot water systems
- Heat sources for a communal heating system should be chosen to minimise likely emissions and to make best use of any local decentralised networks, in preference to other solutions. These systems should be individually controllable by households and usage should be able to be monitored down to the individual dwelling level.
- Where a communal heating system is provided, development proposals must provide evidence to show that NOx emissions related to energy generation will be equivalent to or lower than those of an ultra-low NOx8 gas boiler.
Justification
12.15. The ways in which heating, and power are delivered to / used in development will need to change to meet the requirements of a net zero carbon future and the intended elimination of greenhouse gas emission. The use of fossil fuels and traditional forms of energy generation will need to be phased out and replaced by net zero carbon, non-polluting and energy-efficient sources. These methods will include the use of heat networks and communal heating systems wherever possible.
12.16. The policy requires that the feasibility of incorporating opportunities for decentralised energy provision is considered for all applicable development proposals. If low-carbon decentralised power and heating systems do not currently exist or are still in the process of being delivered, developers should ensure that new housing and employment schemes are provided with the infrastructure to link into those networks when they become available.
12.17. Where a link to an existing or committed decentralised energy source[46] is not viable, the LPA will support the provision of alternative on-site zero carbon measures. This may include, for example, the provision of built-in renewable energy generation for individual buildings or other forms of decentralised energy provision within the site.
12.18. The Government is intending to introduce Heat Network Zoning in England by 2025 and the connection of certain buildings to heat networks within these zones will become mandatory on adoption of the legislation. This zoning will provide the market with a level of certainty that the demand for heat networks will be there to support investment decisions and growth in the market.
12.19. Within Heat Network Zones, large public-sector buildings, large non-domestic buildings, all new-builds and residential buildings that are already heated via communal systems (such as tower blocks) would be required to connect to the heat network within a given timeframe.
12.20. Heat networks are not limited to a particular energy source and can be delivered with a degree of flexibility to reflect local circumstances. Heat Networks can also be future proofed for transition to other fuels. Government funding is available to support the transition to heat networks and is intended to incentivise heat network market transition to low carbon heat sources via targeted financial support, which will help stimulate the increased deployment of low carbon technologies at scale.
12.21. In the Black Country, "Repowering the Black Country" is a programme of initiatives supporting Black Country businesses to take advantage of global clean growth opportunities and to make the transition to a carbon net zero industrial future. The project will initially develop four zero carbon industrial hubs in the Black Country. Within the next ten years, the aim is to reduce industrial carbon emissions by around 1.3M tCO2.
Heating and hot water systems
12.22. There is a broad hierarchy of provision that should be followed when considering and providing for communal heating systems on major residential schemes and where non-residential development would be of a scale to warrant some element of on-site provision. As an illustration, an appropriate hierarchical approach might be as follows:
- local existing or planned heat networks;
- use available local secondary heat sources (in conjunction with heat pumps, if required, and a lower temperature heating system);
- generate clean heat and / or power from zero-emission sources;
- use of fuel cells. If using natural gas in areas where legal air quality limits are exceeded, all development proposals must provide evidence to show that any emissions related to energy generation will be equivalent to or lower than those of an ultra-low NOx gas boiler;
- use ultra-low NOx gas boilers only if more sustainable alternatives are unavailable;
- ultra-low NOx gas boiler communal or district heating systems, designed to ensure that there is no significant impact on local air quality.
Evidence
- Powering Growth: Black Country Energy Strategy (AECOM) (February 2018)
- West Midlands Regional Energy Strategy (November 2018)
- Black Country Utilities Infrastructure Capacity Study (September 2019)
- Heat and Building Strategy (BEIS, December 2021)
- Repowering the Black Country (Black Country LEP) (2022)
- Dudley Council Climate Action Plan Phase One 2024-2027
Delivery
- Delivery will be secured through the development management processes, specifically through Planning and Design statements, energy plans and evidence accompanying planning applications
- Planning conditions, CIL and Section 106 contributions
[46] Systems can include combined heat and power (CHP), biomass, solar and wind power