TUNBRIDGE WELLS BOROUGH Local Development Framework

Transcription

1 TUNBRIDGE WELLS BOROUGH Local Development Framework SUSTAINABILITY APPRAISAL FOR THE RENEWABLE ENERGY SPD October 2006

2 This document is available in large copy prints, audio cassette, Braille or languages other than English. If you require the document in one of these formats please contact: Planning Services Strategy and Planning Policy Tunbridge Wells Borough Council Town Hall Civic Way Royal Tunbridge Wells Kent TN1 1RS Telephone: or

3 CONTENTS NON-TECHNICAL SUMMARY INTRODUCTION The Purpose and Structure of this Report Requirements of the SEA Directive BACKGROUND SA/ SEA Requirements The Building Integrated Renewable Energy SPD SUSTAINABILITY APPRAISAL METHODOLOGY Overview Consultation SUSTAINABILITY OBJECTIVES, BASELINE DESCRIPTION AND CONTEXT Relevant Plans, Programmes and Strategies Renewable Energy Baseline for the Borough Baseline information applicable to the SPD Key sustainability issues The SA Framework for the SPD TESTING THE PLAN OBJECTIVES COMMENTARY ON THE ASSESSMENT WHERE COMPATABILITY IS UNCLEAR ASSESSING OPTIONS FOR THE SPD Appraising the Effects of Alternatives Appraising the Effects of a Saved Policy APPRAISAL OF THE DRAFT SPD Results of the SA The Effects of the SPD Benefits Adverse Effects Secondary, Cumulative and Synergistic Effects MITIGATING MEASURES Uncertainties SPD IMPLEMENTATION AND MONITORING PROPOSALS GLOSSARY AND ABBREVIATIONS TABLES TABLE 1: TABLE 2: TABLE 3: KEY ISSUES FOR THE SPD AND SA... ERROR! BOOKMARK NOT DEFINED. BASELINE INFORMATION SUMMARY... ERROR! BOOKMARK NOT DEFINED. SA FRAMEWORK... ERROR! BOOKMARK NOT DEFINED.

4 NON-TECHNICAL SUMMARY INTRODUCTION AND INVITATION TO COMMENT This Sustainability Appraisal has been undertaken for the Building Integrated Renewable Energy Supplementary Planning Document (SPD). It aims to ensure that sustainability considerations i.e. the social, environmental and economic effects are taken into account into the plan making process. This SA Report follows on from the scoping stage and is published for consultation alongside the Consultation Draft Building Integrated Renewable Energy SPD. Your views are invited now, particularly in relation to the alternative options considered (section 6 of this report) and the appraisal of the Building Integrated Renewable Energy SPD (section 7 of this report). If you would like to make any comments, please forward your responses marked Sustainability Appraisal of the Building Integrated Renewable Energy SPD to: Strategy and Development Service Tunbridge Wells Borough Council Town Hall Tunbridge Wells Kent TN1 1RS Alternatively, consultation responses may be ed to: strategy@tunbridgewells.gov.uk and should be clearly marked Sustainability Appraisal of the Building Integrated Renewable Energy SPD. BACKGROUND AND METHODOLOGY The Building Integrated Renewable Energy SPD, when adopted, will form part of the suite of Local Development Documents, referred to as the Local Development Framework. It provides guidance on the technologies available and how developers and householders can use renewable energy within new developments and conversions. The following legislation is applicable to this Sustainability Appraisal: The Planning and Compulsory Purchase Act (2004); and The European Directive 2001/EC, known as the Strategic Environmental Assessment (SEA) Directive The SA and the Report have been carried out/ produced in line with the Government guidance document Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents published in November SUSTAINABILITY OBJECTIVES, BASELINE DESCRIPTION AND CONTEXT This Section of the Report describes the key plans and programmes and sustainability issues applicable to the Building Integrated Renewable Energy SPD. International, national, regional and local policies, plans, programmes and strategy documents relevant to the SPD were reviewed as part of the SA scoping process to determine the objectives and targets relevant to the LDF, and to identify synergies and opportunities as well as conflicts and challenges. The full list of documents studied and the review of relevant plans, programmes and strategies are presented in the SA Scoping Report which was issued for consultation in September 2005 and is available on the Tunbridge Wells website at In addition specific documents relevant to this SPD have been reviewed to ensure there were no major inconsistencies between policies contained in the documents and those of the SPD. An extensive search of baseline data was undertaken at the scoping stage and is contained in the scoping report and appendices. Information relevant to this SPD was drawn from this review and

5 supplemented with additional information relevant to this SPD. Key sustainability issues were identified and are summarised below: The key economic issues relevant to the Building Integrated Renewable Energy SPD relate to the possibility of renewable energy stimulating investment, cutting costs, stimulating the local market for environmental technology and helping to broaden the Borough s economic base. Renewable energy may be considered inexpensive when the invisible costs of fossil fuel use are considered. The key social issues relate to the renewable energy helping to improve the quality of housing and create decent homes. There should be lower running costs for the occupants of buildings, which incorporate renewable technology, and this should help to tackle fuel poverty. The key environmental issues relate to the high quality diverse and distinctive landscape of the Borough. Therefore, proposals for renewable energy generation must have regard to these key environmental factors. Renewable energy sources have the potential to provide a clean, secure and affordable source of electricity helping to reduce the threat of global warming and climate change. To provide a systematic way of evaluating the plan, the appraisal process identifies a number of relevant Sustainability Objectives. These are as follows: - To ensure that everyone has the opportunity to live in a decent, sustainable constructed and affordable home; To improve the health and well-being of the population & reduce inequalities in health; To improve accessibility to all services and facilities, including employment, education, health services, shopping, green space, culture, leisure, recreation (CLR) facilities and a sustainable tourism sector; To reduce pollution (to land, air and soil) and maintain and improve the water quality of the Borough s rivers, and to achieve sustainable water resources management; To address the causes of climate change through reducing emissions of greenhouse gases; To conserve and enhance the Borough s diversity; To protect, enhance and make accessible for enjoyment, the Borough s countryside and historic environment; To reduce the impact of resource consumption by using sustainable produced and local products and reducing waste generation and disposal; To increase energy efficiency, and the proportion of energy generated from renewable sources in the Borough; To ensure high and stable levels of employment so everyone can benefit from the economic growth of the Borough; and To stimulate and sustain economic growth and competitiveness across the Borough. TESTING THE PLAN OPTIONS AND ASSESSING THE OPTIONS The South East Plan contains a number of core policies, which promote or expect renewable energy. Policy EN1: Development Design for Energy Efficiency and Renewable Energy, states that local authorities may develop policy, which encourages developers to submit an assessment of a development s energy demand and provide at least 10% of the development s energy demand from renewable sources : Other pertinent policies include CC2: Climate Change, CC4: Sustainable Construction and EN6: Development Criteria.

6 Tunbridge Wells Borough Council has recently adopted the Kent Design SPD, which is supplementary to the policies in the Kent and Medway Structure Plan. Kent Design SPD encourages local authorities to promote renewable energy in design briefs and supplementary planning documents. Strategic Objective 2 of the adopted Tunbridge Wells Borough Local Plan 2006 is to conserve finite non-renewable resources such as energy. Alternative options considered as part of this appraisal are as follows: Option A Provide additional planning guidance on renewable energy provision in the Borough by means of a Supplementary Planning Document; and Option B Do nothing, i.e. rely on the existing national, regional, County and local planning policy to provide for renewable energy. The SPD provides a more detailed local framework. The existing policy framework alone does not provide sufficient detail for sustainability issues such as helping to improve health and well-being through helping to reduce fuel poverty. The assessment of Options A and B demonstrates that providing additional planning guidance on renewable energy by means of a Supplementary Planning Document will ensure more sustainable future development and would provide major benefits for a number of Sustainability Objectives. APPRAISAL OF THE DRAFT SPD, MITIGATION AND MONITORING The SPD provides essential guidance that ensures the implementation of policy EN1 of the South East Plan, policies NR1 and NR3 of the Kent and Medway Structure Plan (KMSP), and Strategic Objective 2 of the Local Plan contribute more positively to sustainable development. The assessment highlights that overall, the SPD provides a number of benefits. These relate to: promoting the use of renewable technology; reducing fuel poverty thereby improving health and well-being; improved accessibility to services; reducing air pollution; helping to address the causes of climate change; protecting the Borough s countryside and historic environment; reducing the impact of resource consumption; increasing energy efficiency and the proportion of energy generated from renewable sources in the Borough; ensuring high and stable levels of employment and stimulating and sustaining economic growth and competitiveness across the Borough. Gaps in the SPD were identified. These relate to: the lack of a specific recognition that potential health benefits could be achieved. The SPD should also consider how renewable technologies can conserve and enhance the Borough s biodiversity assets, as otherwise there may be a missed opportunity if the SPD only seeks to protect what already exists. To maximise the benefits of the SPD and prevent any adverse effects, a number of mitigation measures have been put forward. These include the SPD incorporating guidance on: the potential health benefits that could be achieved; how the SPD should seek to operate in conjunction with other initiatives to maximise impact in areas where particular problems have been identified; further guidance to ensure that all development proposal are guided by climate proofing principles; how the SPD should recognise the opportunity to conserve and enhance the boroughs biodiversity assets; the sensitivity of other locations such as Green Belt; the recognition that renewable energy has the possibility of stimulating the local market for environment technology and energy services and creating jobs, which could help to broaden the Borough s economic base, and the recognition that the incorporation of renewable energy should help to stimulate and sustain competitiveness across the Borough. Specific monitoring proposals will be put forward at Stage E of the SA process. However, it is anticipated that a number of factors will be able to be monitored through the proportion of energy used in new development, which comes from on site renewables.

7 1. INTRODUCTION In order to promote renewable energy provision within new developments and conversions in Tunbridge Wells Borough, Tunbridge Wells Borough Council has produced a guidance document, known as the Building Integrated Renewable Energy Supplementary Planning Document (SPD). The SPD provides a more detailed local framework. This Sustainability Appraisal (SA) of the Building Integrated Renewable Energy SPD has been undertaken to ensure the integration of sustainability considerations into the plan making process. Sustainability encompasses environmental, social and economic components. SA aims to contribute towards sustainability by appraising a plan or strategy against environmental, social and economic objectives. The SA has applied the Strategic Environmental Assessment (SEA) requirements to ensure compliance with the European Union Directive 2001/42/EC and meets the Office of the Deputy Prime Minister s (ODPM) requirement for SA of SPDs. The Office of the Deputy Prime Minister (now known as the Department for Communities and Local Government) advocates a combined SA/SEA process, and this is the approach that has been adopted. From hereon, SA is used to represent the combined SA/SEA process. 1.1 THE PURPOSE AND STRUCTURE OF THIS REPORT This SA Report presents the findings of the SA carried out on Tunbridge Wells Borough Council s Building Integrated Renewable Energy SPD. It follows the methodology and framework set out in the SA Scoping Report for Tunbridge Wells Borough Local Development Framework (LDF), issued for consultation in August This Report documents the SA process; that is, to review previous work undertaken, assess the effects of the SPD and propose methods of mitigating adverse impacts, maximising beneficial impacts and presenting proposals for monitoring the effects of the SPD. The report is structured as follows: Section 2 provides the background to the SA Report, including the requirements for SEA/SA, and the objectives of the Building Integrated Renewable Energy SPD; Section 3 outlines the SA methodology and the consultation process; Section 4 addresses the Sustainability Objectives, the renewable energy baseline context, key sustainability issues and the SA Framework used in the assessment of the SPD; Section 5 assesses the compatibility of the SPD objectives against the SA Framework; Section 6 describes the assessment of alternative options, including the do-nothing approach versus producing an SPD for renewable energy, and appraising the effects of existing policies; and Section 7 presents the potential beneficial and adverse effects of the SPD, including cumulative, synergistic and secondary effects, mitigation measures and uncertainties. 1

8 1.2 REQUIREMENTS OF THE SEA DIRECTIVE Table 1 sets out the requirements of the SEA Directive and signposts relevant Sections of the report where these requirements are fulfilled. Table 1: SEA Requirements and where these are addressed in this report. Requirements a) An outline of the contents, main objectives of the plan or programme, and relationships with other relevant plans and programmes. b) The relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme. Where covered in SA Report Section 2.2 Section 4.2, 6.1 and 6.2 c) The environmental characteristics of areas likely to be significantly affected. Section 4.2 d) Any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC e) The environmental protection objectives, established at international, Community or national level, which are relevant to the plan or programme and the way those objectives and any environmental, considerations have been taken into account during its preparation. f) The likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors. These effects should include secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative. g) The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme. h) An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information. i) A description of measures envisaged concerning monitoring in accordance with Article 10. j) A non-technical summary of the information provided under the above headings Section 4.2 Section 4.1 Section 7.1 and 7.2 Section 8 Section 6.1 and 6.2 Section 9 Non-Technical Summary The report shall include the information that may reasonably be required taking into account current knowledge and methods of assessment, the contents and level of detail in the plan or programme, its stage in the decisionmaking process and the extent to which certain matters are more appropriately assessed at different levels in that process to avoid duplication of the assessment (Art. 5.2). 1

9 Requirements Consultation: Where covered in SA Report Section 3.2 Authorities with environmental responsibility, when deciding on the scope and level of detail of the information to be included in the environmental report (Art. 5.4). Authorities with environmental responsibility and the public shall be given an early and effective opportunity within appropriate time frames to express their opinion on the draft plan or programme and the accompanying environmental report before the adoption of the plan or programme (Art. 6.1, 6.2). Section 3.2 Other EU Member States, where the implementation of the plan or programme is likely to have significant effects on the environment of that country (Art. 7). Taking the environmental report and the results of the consultations into account in decision-making (Art. 8) Provision of information on the decision: When the plan or programme is adopted, the public and any countries consulted under Art.7 shall be informed and the following made available to those so informed: To be completed after consultation To be completed after consultation The plan or programme as adopted; A statement summarising how environmental considerations have been integrated into the plan or programme and how the environmental report pursuant to Article 5, the opinions expressed pursuant to Article 6 and the results of consultations entered into pursuant to Article 7 have been taken into account in accordance with Article 8, and the reasons for choosing the plan or programme as adopted, in the light of the other reasonable alternatives dealt with; and The measures decided concerning monitoring (Art. 9 and 10) Monitoring of the significant environmental effects of the plan s or programme s implementation (Art. 10) Quality assurance: environmental reports should be of a sufficient standard to meet the requirements of the SEA Directive Section 9 This table seeks to signpost sections of the report that fulfil the SEA Directive 2

10 2. BACKGROUND 2.1 SA/ SEA REQUIREMENTS The Planning and Compulsory Purchase Act (2004) requires Sustainability appraisals (SAs) to be carried out on Supplementary Planning Documents (SPDs). The SA should also fully comply with the requirements of the European Directive 2001/EC, known as the Strategic Environmental Assessment (SEA) Directive. SEA and SA are very closely linked. The SEA Directive requires the assessment of the effects of certain plans and policies on the environment. The Planning and Compulsory Purchase Act (2004) extends this assessment of environmental effects to also incorporate economic and social aspects. This document follows the core guidance as set out in Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents published by the former Office of the Deputy Prime Minister in November The guidance was designed to integrate the requirements of the SEA legislation into SA. Consequently, by following the guidance, a combined SA/SEA was undertaken. 2.2 THE BUILDING INTEGRATED RENEWABLE ENERGY SPD The Building Integrated Renewable Energy supplements various policies/objectives and will form part of the suite of Local Development Documents comprising the Local Development Framework. The SPD is intended to provide guidance on the technologies available and how developers and householders can use renewable energy within new developments and conversions. The objectives of the SPD are as follows: - To encourage sustainable construction practices; To establish appropriate targets for renewable energy generation to meet established policy and statutory guidance; To provide information on renewable technologies and guidance on their application; To encourage design solutions for renewable energy sources which minimise impact on the character and appearance of the local environment, particularly in sensitive areas. 3. SUSTAINABILITY APPRAISAL METHODOLOGY 3.1 OVERVIEW The ODPM guidance (November 2005) provides detail on the process of implementing SA. Figure 1, overleaf, outlines the SA methodology and illustrates how SA fits into the SPD plan preparation process. Stage A of the process draws on previous work contained in the SA Scoping Report, published in August 2006, which in turn drew on the work contained in the first SA Scoping Report that was issued for consultation and then adopted by Cabinet in November As 1

11 the earlier Scoping Report (November 2005) did not specifically relate to the Building Integrated Renewable Energy SPD, a further Scoping Report was produced and issued for consultation in August/September 2006 to: - Reassess the context and objectives. This included reviewing those planning and other relevant documents to ensure that the most up-to-date documents were referred to, as well as teasing out contextual information and objectives relevant to the Building Integrated Renewable energy SPD. The review also sought to identify other plans, programmes and strategies that are relevant; Provide additional environmental, social and economic baseline information that was specific to the SPD; Review the SA objectives and sub-objectives to ensure that these were appropriate to the SPD. The Scoping Report issued for consultation in August/September 2006 should therefore be read in conjunction with the earlier Scoping Report and accompanying appendices. During the initial scoping stage, the SA Framework for the LDF was developed and key sustainability issues were highlighted following a review of relevant plans and policies and baseline data. Part 2 of the Scoping Report identifies the Sustainability Objectives of relevance to the Building Integrated Renewable Energy SPD. These were used in the SA Framework of the SPD, as detailed in Section 4.3 of this SA Report. Key issues contained in the Scoping Report, applicable to Stage A of this SA of the Building Integrated Renewable Energy SPD have been summarised in Section 4 of this SA Report. The information has been updated, with additional information added, where relevant following receipt of consultation responses to the Scoping Report. However, the focus of this SA Report is on Stages B, C and D, as shown in Figure 1. This Report forms Stage C of the SA process; documenting the findings of Stage B Developing and Refining Options and Assessing Effects and will accompany the draft SPD at the public participation stage of the process under Regulation 17 of the Town and Country Planning (Local Development) (England) Regulations 2004 (Stage D). 2

12 Figure 1: The SPD Preparation Process in Relation to the SA Process 3.2 CONSULTATION In accordance with ODPM guidance, a copy of the SA Scoping Report (August 2006) was sent out to the four Environmental bodies: - Countryside Agency; English Heritage; English Nature; Environment Agency. 3

13 The only comments on the SA Scoping Report (August 2006) were made by English Nature who welcomed the scope of the proposed Sustainability Appraisal and had no comments to make in relation to the Scoping Report. All four statutory environmental consultation bodies must be consulted on the SA and SPD. Other community groups and social and economic bodies will also be consulted. The guidance advises that relevant SA commentary on the likely significant effects of the options is available at the same time as the draft SPD. This is provided in Section 7 of this SA Report. Following advice in Planning Policy Statement 12 (PPS 12) for SPDs, it is necessary to ensure that significant sustainability effects of the SPD are consulted on at the same time as the draft SPD. This is also provided in Section 7 of this SA Report. 4

14 4. SUSTAINABILITY OBJECTIVES, BASELINE DESCRIPTION AND CONTEXT 4.1 RELEVANT PLANS, PROGRAMMES AND STRATEGIES The SPD may be influenced, in various ways, by other plans and programmes, and by external sustainability objectives, such as those laid down in policies or legislation. International, national, regional and local policies, plans, programmes and strategy documents relevant to the SPD were reviewed as part of the SA scoping process to determine the objectives and targets relevant to the LDF, and to identify synergies and opportunities as well as conflicts and challenges. The list of documents reviewed can be seen in the first Scoping Report (November 2005) and also in the further Scoping Report (August 2006), the latter of which was specifically related to the Building Integrated Renewable Energy SPD. These documents included: - Energy Review Report; Draft South East Plan; State of the Environment Report; Kent and Medway Structure Plan; Kent Health and Affordable Warmth Strategy; Tunbridge Wells Local Plan; Tunbridge Wells Borough Environment Strategy; and Tunbridge Wells Borough Council Carbon Management Action Plan. 4.2 RENEWABLE ENERGY BASELINE FOR THE BOROUGH An extensive search for baseline data was undertaken at the Scoping stage. A large amount of baseline information is contained in the first Scoping Report (November 2005). Further research was undertaken and additional baseline information was presented in the further Scoping Report (August 2006), which related specifically to the Building Integrated Renewable Energy SPD. This information was representative of the current situation in Tunbridge Wells Borough. Limitations of the data result from a lack of available information on certain baseline issues, such as a lack of information for earlier years, which is required to ascertain trends in renewable energy provision. Furthermore, much of this information is not available at the Borough level. The baseline information is presented below Baseline information applicable to the SPD Average energy consumption in the home (all tenures) across the Borough is gigajoules of energy. Current surveys do not measure what proportion of annual household energy usage is derived from renewable sources. 5

15 There are approximately 125,000 households in Kent who are in fuel poverty, i.e. who spend more than 10% of their income to meet fuel costs. The number of approved planning applications incorporating renewable energy installations within the Borough is currently unavailable although mechanisms for future monitoring are under investigation Key sustainability issues Key sustainability issues for Tunbridge Wells Borough and those specifically relating to renewable energy were identified in the SA Scoping Report (August 2006). To set the context for this SA, the latter are presented below. Economic Information in the first Scoping Report recognised that there had been a net loss of economic floor space ( employment land ) in the Borough between 1998 and The Borough s narrowing economic base is also of note, with an increasing amount of employment being service sector based. Growth has occurred in relatively low-paid service industry jobs, including in retail and restaurants, which has required people to travel into the Borough, as residents of the Borough are generally highly skilled. There is the potential for the Borough to become a dormitory, with a limited range of local employment and where people live in the Borough but work elsewhere. Renewable energy has the possibility of stimulating investment, cutting costs, stimulating the local market for environmental technology and energy services and creating jobs and opportunities for training. Some of these jobs would be in manufacturing, which would help to broaden the Borough s economic base. Diversification in agriculture and forestry may take place if energy crops such as willow coppice are grown and wood fuel may come from sustainably managed forests. This has the opportunity to generate rural employment opportunities. All renewable energy sources, apart from biomass products, are free. The payback period for renewables is longer than, for example, other energy efficient measures such as installing cavity wall insulation and there are some concerns about the lifespan of technologies, e.g. photovoltaics are generally guaranteed for around years, although they are expected to last longer. However, although collection equipment does require initial investment, fuel cost savings should always be made. If the invisible costs of fossil fuel use, such as global warming, depletion of limited resources and extraction pollution are considered, then renewable energy systems may be considered inexpensive. The price of the systems should come down as technologies and the market develops. There should also be economies of scale, particularly for larger development schemes. Renewable energy is also a future proofing strategy against future fuel price and climate change levy increases. Legislative changes and new grant schemes will also have an effect on the relative attractiveness of renewable energy technologies. Prospective purchasers of developments that incorporate renewable technology may be prepared to pay a premium. Where life cycle costings are used, renewable should certainly increase value. Some mortgage providers offer green mortgages, for which the presence of renewables could be an advantage. 6

16 Social The first Scoping Report recognised that Tunbridge Wells is a Borough of high housing demand, limited housing supply and high costs and that the situation is likely to get worse if the regional economy in the South-East continues to overheat. This is still a key consideration. The incorporation of renewable energy should help to improve the quality of housing and create decent homes. While there is an initial capital cost to the individual, the use of renewable energy can help to protect householders and businesses against fuel price rises. Maintenance requirements for certain types of renewable technologies, such as photovoltaics and wind turbines, should be minimal. There should be lower running costs for the occupants of buildings as heating and cooling bills decrease, and/or electricity bills decrease. There is also the opportunity to sell electricity back to the grid. The use of renewable technologies should help to tackle fuel poverty, along with the associated health problems and winter deaths for vulnerable people. This in turn will help to relieve pressure on the health service. For local communities, renewable energy offers increased local employment through the use of local materials and labour. As some of the technologies, such as Combined Heat and Power (CHP) are more suited to larger developments, they may require buy-in from the community, which should improve community cohesion. Raising awareness of renewable energy technologies may help to increase awareness of other green agenda issues. There may be an increased sense of community through use of public spaces and amenities, particularly if an architectural feature is made of renewable technologies. There is increasing concern about future supplies of fossil fuels and particularly the UK s increasing reliance on importing gas supplies. The incorporation of renewable energy technologies should enable the Borough to become more self-sufficient in terms of energy production. Environmental The Scoping Report identified the opportunity to safeguard, and potentially to improve, the local environment and contribute to the long-term protection of the wider environment through the increased use of renewable energy generation in conjunction with measures to minimise energy usage. When promoting this opportunity, the SPD must be mindful of the environmental character of the Borough, as follows. Tunbridge Wells Borough has a diverse and distinctive landscape with more than 70% of its area being covered by the High Weald Area of Outstanding Natural Beauty (AONB) and 30% being designated as Green Belt. In terms of biodiversity, the Borough currently contains 10 Sites of Special Scientific Interest (SSSIs) and four Local Nature Reserves, as well as extensive areas of woodland. Such areas support a wealth of native species, many of which are protected by European and national legislation. Similarly valuable is the Borough s built environment. Its rich architectural heritage contains over 3,000 Listed Buildings and 25 designated Conservation Areas. In light of the above, proposals for renewable energy generation must have regard for the sensitive natural and cultural environment in which they are made. Renewable energy sources have the potential to provide a clean, secure and affordable source of electricity and, furthermore, 7

17 to reduce the threat of global warming and climate change. An increase in energy generation from such sources should therefore be actively pursued and the SPD should seek to advise applicants on how progress may be made without compromising the Borough s existing heritage and environmental assets. 4.3 THE SA FRAMEWORK FOR THE SPD The updated SA Framework for the LDF was included in the SA Scoping Report (August 2006). The SA objectives relevant to the SPD are 1, 2, 6, 8, 9, 10, 11, 13, 14, 15 and 16. They are presented in Table 2, below, along with the rationale for their inclusion. All other Objectives (3, 4, 5, 7, 12) are not applicable to the Building Integrated Renewable Energy SPD as the SPD will have a neutral effect on these Objectives and have consequently been removed from the SA Framework for this Appraisal. 8

18 Table 2: SA Framework for the Renewable Energy SPD Sustainability Objective Objective 1. To ensure that everyone has the opportunity to live in a decent, sustainably constructed and affordable home Objective 2. To improve the health and wellbeing of the population & reduce inequalities in health Objective 6. To improve accessibility to all services and facilities, including employment, education, health services, shopping, green space, culture, leisure, recreation (CLR) facilities and a sustainable tourism sector Objective 8. To reduce pollution (to land, air and soil) and maintain and improve the water quality of the Borough s rivers, and to achieve sustainable water resources management; Objective 9. To address the causes of climate change through reducing emissions of greenhouse gases Objective 10. To conserve and enhance the Borough s biodiversity Objective 11. To protect, enhance and make accessible for enjoyment, the Borough s countryside and historic environment Objective 13. To reduce the impact of resource consumption by using sustainably produced and local products and reducing waste generation and disposal Objective 14. To increase energy efficiency, and the proportion of energy generated from renewable sources in the Borough Objective 15. To ensure high and stable levels of employment so everyone can benefit from the economic growth of the Borough Objective 16. To stimulate and sustain economic growth and competitiveness across the Borough Explanation and Comments The SPD should ensure that new builds and conversions are sustainably constructed The use of renewable technologies should help to tackle fuel poverty and improve thermal comfort along with associated health problems, thus helping to reduce inequalities in health The use of renewable technologies should help to improve accessibility to services through people becoming more selfsufficient in terms of the sources of energy production. Also offer greater customer choice through access to alternative energy sources. The SPD should help to reduce pollution to air as it should lead to a reduction in the emission of carbon dioxide. Also by reducing reliance on fossil fuel and the associated pollution with their extraction and distribution. Renewable energy should help to reduce the cause of climate change by reducing the emissions of carbon dioxide The SPD may affect biodiversity in terms of where new facilities are located. Through promoting the use of woodchip fuels it should improve the use and management of local forests and therefore their biodiversity. The SPD could impact on the Borough s countryside and historic environment, depending on the choice of energy source, where installations are sited and their design. The SPD should reduce the impact of resource consumption through not relying on fossil fuels, as well as helping to reduce waste generation and disposal, which occurs through extraction of fossil fuels The SPD should increase the proportion of energy generated from renewable sources in the Borough The SPD should help to stimulate the local market for wood-fuel products, environmental technologies and specialist energy services By stimulating the local market for environmental technology and energy services, this should lead to economic growth and competitiveness 9

19 5. TESTING THE PLAN OBJECTIVES The SPD objectives provide the context for the options of the SPD. They outline the purpose of the SPD and its aims. It is important that the objectives of the SPD are in line with sustainability principles, therefore they have been tested against the SA Framework. The results are presented in Table 3, below. The SPD objectives are as follows:- To encourage sustainable construction practices; To establish appropriate targets for renewable energy generation to meet established policy and statutory guidance; To provide information on renewable technologies and guidance on their application; To encourage design solutions for renewable energy sources which minimise impact on the character and appearance of the local environment, particularly in sensitive areas. Table 3: Testing the SPD objectives against the SA Framework SPD Objectives Sustainability Objectives 1. To encourage sustainable construction practices 2. To establish appropriate targets for renewable energy generation to meet established policy and statutory guidance 3. To provide information on renewable technologies and guidance on their application 4. To encourage design solutions for renewable energy sources which minimise impact on the character and appearance of the local environment, particularly in sensitive areas. OBJ 1? OBJ OBJ 6 - OBJ 8 OBJ 9 OBJ 10? OBJ 11? - OBJ 13 OBJ 14 OBJ OBJ Key Objectives are compatible? Compatibility is unclear and may depend on how the objective is implemented X Objectives are incompatible - No obvious relation between the objectives 10

20 The appraisal revealed all four objectives of the SPD to be broadly in accordance with the SA Objectives. However, some of the SA Objectives are not addressed, which are of relevance to the SPD, such as SA Objective 2 on health. This may reduce the overall sustainability of the SPD. 5.1 COMMENTARY ON THE ASSESSMENT WHERE COMPATABILITY IS UNCLEAR SA Objective 1 versus SPD objective 1 while the SPD should help to ensure that everyone has a sustainably constructed and decent home, sustainable construction practices may mean that the initial cost of properties are higher. This will affect affordability, although over time capital costs may be recouped due to lower revenue costs, e.g. lower fuel bills. SA Objective 10 versus SPD objective 1 there is a potential conflict between these objectives as some renewable technologies are not necessarily considered visually aesthetic. Therefore, their siting should be carefully considered particular in sensitive areas such as SSSIs and AONB. SA Objective 11 versus SPD objective 1 Renewable technologies should be considered carefully, particularly when used on Listed Buildings and/or in Conservation Areas. 11

21 6. ASSESSING OPTIONS FOR THE SPD 6.1 APPRAISING THE EFFECTS OF ALTERNATIVES The SEA requirements relevant to the consideration of alternatives are provided below. The ODPM guidance (2005) states that it is essential to set out to improve on the situation which would exist if there were no SPD. To test this, options considered include the no plan or business as usual. The consideration of alternatives is synonymous with the term options in this SA report. SEA Directive: The Environmental Report should consider reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme and give an outline of the reasons for selecting the alternatives dealt with (Article 5.1 and Annex 1) The SEA requirements relevant to the consideration of alternatives are provided below. The ODPM guidance (2005) states that it is essential to set out to improve on the situation which would exist if there were no SPD. To test this, options considered include the no plan or business as usual. The consideration of alternatives is synonymous with the term options in this SA report. Although there are a number of policies in the Draft South East Plan relevant to renewable energy, the main policy is EN1. The principle policies relevant in the adopted Kent and Medway Structure Plan (2006) are NR1 and NR3. Strategic Objective 2 of the adopted Local Plan (2006) is relevant to renewable energy. To be consistent with government guidance on SA, alternatives or options to these higher level policies have not been considered in the SPD preparation. Two options were identified for this SPD and each was addressed by the SA. The options appraisal considers the need for an SPD through evaluation of the principle of the SPD against the SA Framework: Option A Provide additional planning guidance on renewable energy provision in the Borough by means of a Supplementary Planning Document; and Option B The do nothing approach, whereby the existing national, regional, county and local planning policy context is relied upon to provide for renewable energy provision. 12

22 Table 4: Sustainability Implications and Recommendations of the Options Option Sustainability Implications Recommendations Option A - The supplementary document is not anticipated to The SPD provides increased guidance on Provide an have an adverse effect on any of the Sustainability renewable energy provision in the Borough. SPD Objectives. The SPD does however generate a number of major positive effects, relating to sustainable construction (Objective 1), climate change (Objective 9), resource consumption (Objective 13) and the proportion of energy generated from renewable sources (Objective 14). The SPD is anticipated to have a positive effect on all Sustainability Objectives. It has major positive effects on four objectives and has a minor positive effect on all remaining objectives. As such it is considered more likely to encourage the take up of renewable energy than existing policy alone. The production of an SPD to supplement the existing policy context is considered to be the more sustainable option. Option B Do Nothing Relying on the existing national, regional, and county planning policy context is also not anticipated to have an adverse effect on any of the SA Objectives. However, the positive effects will be limited in some cases, such as for health (Objective 2), accessibility to services (Objective 6), biodiversity (Objective 10), countryside and historic environment (Objective 11), employment (Objective 14) and economic growth (Objective 15) than if the SPD were provided. The policies alone will generate fewer major positive effects, than if the SPD were produced. The existing policy context is weak on a number of sustainability issues. In particular, existing policies do not indicate how to achieve energy efficiency and use of renewables. The existing policies create less significant positive effects and contribute less to the sustainability objectives than the SPD. The above comparison of the two alternative options demonstrates that Option A Provide additional planning guidance on renewable energy provision in the Borough by means of a Supplementary Planning Document, will strengthen the existing policies. Therefore, this will increase the likelihood of ensuring that renewable energy is incorporated within developments, than relying on higher level policies alone. The SPD provides benefits for a number of Sustainability Objectives. 6.2 APPRAISING THE EFFECTS OF A SAVED POLICY When undertaking an SA for a SPD that is linked to saved policies, the ODPM guidance states that it is not necessary to document the significant effects of the saved plan as a whole or alternatives, as these should already have been considered during the preparation of a saved plan. However, the SA does need to set out the likely significant social, environment and economic effects of those policies, which the SPD is helping to implement. The appraisal of the South East Plan policy EN1, policies NR1 and NR3 of the Kent and Medway Structure Plan (KMSP), and Strategic Objective 2 of the Local Plan has therefore been undertaken to establish the current baseline situation i.e. the social, environmental and economic effects, against which the effects of the SPD can be measured. This has been done in the appraisal undertaken on Option B as part of the alternative options appraisal, which assesses the existing saved policies against the sustainability Objectives as required by the guidance. The appraisal is presented in Section 7.1. The appraisal lists the relevant SA Objectives and sub-objectives used in the appraisal followed by a table presenting the appraisal of Options A and B, together with comments and explanations of the outcome of the appraisal for clarity and transparency. 13

23 7. APPRAISAL OF THE DRAFT SPD SEA Directive SEA Directive Prediction of effects involves: Identifying the changes to the environmental baseline which are predicted to arise from the plan or programme, including alternatives. The predicted effects of alternatives can be compared with each other, or with no plan or programme and/or business as usual scenarios where these exist, and against the SEA objectives. Describing these changes in terms of their magnitude, their geographical scale, the time period over which they will occur, whether they are not permanent or temporary, positive or negative, probable or improbable, frequent or rare, and whether or not there are secondary, cumulative, and/or synergistic effects. 7.1 RESULTS OF THE SA Key to Impact Appraisal Magnitude Option has a major positive impact on the SA Objective Option has a minor positive impact on the SA Objective - Option has a neutral impact on the SA objective Option has a minor negative impact on the SA Objective Option has a major negative impact on the SA Objective? Impact is uncertain Timing ST Short Term (during the construction of new development) MT Medium Term (5 to 10 years post completion of new development) LT Long Term (Over 10 years post completion of new residential development) Likelihood - High, Medium or Low Scale Local, regional, national or global Permanence Temporary or permanent Effect Secondary, cumulative or synergistic effects. Monitoring Proposals for monitoring the effects of the SPD. 14

24 SA OBJECTIVE 1 - TO ENSURE THAT EVERYONE HAS THE OPPORTUNITY TO LIVE IN A DECENT, SUSTAINABLE CONSTRUCTED AND AFFORDABLE HOME Sub-objectives 1.1 Will it increase the amount of housing across the Borough to meet local needs? 1.2 Will it increase the supply of affordable housing both in numbers and as a proportion of total housing stock? 1.3 Will it reduce the percentage of unfit/non-decent homes in the Borough? 1.4 Will it ensure the provision of housing to serve the needs of rural areas? 1.5 Will it promote the adoption of sustainable design and construction practices in housing (e.g. energy/water/land/materials efficiency, incorporation of biodiversity/natural assets, etc)? 1.6 Will it promote the development of mixed communities through a range of housing sizes, types, tenures and levels of affordability to reflect changes in population? Objective 1. To ensure that everyone has the opportunity to live in a decent, sustainable constructed and affordable home Policy Assessment of Effects Explanation and Comments ST MT LT EN1 in SE Plan, NR1 and NR3 in KMSP, Strategic Objective (SO) 2 in Local Plan Policy EN1 encourages developers to provide at least 10% of the development s energy demand from renewable sources. Polices NR1 and NR3 encourage energy conservation and the incorporation of renewable energy production. Strategic Objective 2 of the Local Plan seek to encourage finite non-renewable sources such as energy but does not contain further policy guidance. These policies will therefore lead to minor positive effects in the short to long term. SPD Guidelines The SPD will help to promote the adoption of sustainable design and construction practices through making developers and householders aware of renewable technology that can be incorporated within new developments and conversions. Awareness of the SPD should increase over time and renewable technologies should become cheaper. Therefore, the minor positive effects in the short and medium time should increase to a major positive effect in the long term. Recommendations: None required Likelihood: High Scale: Local Permanence: Permanent Effects: Potential to improve the quality of housing in the Borough and to raise awareness of other measures to improve quality Monitoring: None. The SPD will not result in a significant sustainability impact with regard to Objective 1.