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Viability Feasibility

3. VIABILITY / FEASIBILITY
3.1. Any borough wanting to adopt a prescriptive renewable energy planning policy will most likely to be compelled by their UDP/LDF inspector to include a clause in the Justifications stating that if the developer is able to prove that if implementation is either “unfeasible” or “unviable” then they don’t have to do it. This should not be considered as a simple “get out” clause for the developer. The basic principal from the local planning authority perspective is that the onus is on the developer to prove conclusively that the policy is “unviable” or “unfeasible” in this particular instance. Merton would expect a very comprehensive feasibility study confirming this before accepting the developer’s contention. For example, in the case of a prestigious office development where the only technology possible was PVs, it would certainly not be acceptable for a developer to claim that meeting the policy was commercially unviable if they could have clad the outside of the building in PVs instead of more expensive Carrera marble. It should be stressed that in any of the circumstances below this would not mean abandoning the policy, but merely negotiating on the percentage target.

3.2. Conversely, it is reasonable for the LA to interpret this “feasibility/viability” clause as a justification for requiring more than 10% if feasible/viable. Hence the Croydon/Merton 10%(+) branding of the policy.

3.3. There are in reality only four possible reasons why the 10%(+) policy might not be “feasible” or “viable”.

  1. Technical, architectural, engineering and climatic: This will be a very rare event and it is difficult to dream up a scenario where it would be the case if the developer factors the policy requirement into the initial design phase of the building. Retro fitting is invariably the most expensive option.

    Limitations on technologies?
    • PV and solar thermal – building orientation, installation space.
    • Micro-wind – urban wind patterns.
    • Ground Source Heat – height of building, availability of land for loop, sub-surface infrastructure or water that prevents borehole drilling
    • Biomass – load demand, fuel availability, plant space.
    • Biogas – load demand production and storage, plant space.

  2. Financial viability: There may occasionally be a site specific situation where implementing the policy cuts unreasonably into the developers profit margin. One such scenario could be when the only technology possible was large scale PVs installations on a high rise social housing block. If a developer tries to maintain that implementation is too costly, it is very likely that this is simply because they are attempting to retro-fit rather than integrate into the overall design. In such cases this is the developers own fault for not taking the policy seriously enough to start with, and precedents cannot be set where developers think that ignoring the policy enables them to avoid responding to it.

    In general terms, depending upon the type of development and the type of developer, between 3% to 5% additional build cost could be considered reasonable at 2005 national (fossil fuel based) energy costs.

  3. End user payback timeframe: It is conceivable that if the equipment costs are unexpectedly high and have a long payback timeframe like 40 years, then a developer might reasonably claim that it would be unrealistic for the end user to be able to factor that into a conventional business plan. An example would be a shell build speculative commercial developments for light industrial/warehouse/storage units, where the only possible technology was large scale PV installation. However, these payback times will fall as the cost of fossil fuel rises and the cost of the equipment falls with growing economies of scale. Also there are opportunities for earning income from exporting electricity into the national grid, though currently it might be unrealistic to expect occupiers of speculative commercial units to factor such an unfamiliar and complex issue into their business plans.

  4. Public perception and acceptance: Surveys and questionnaires have consistently shown that end users of buildings would prefer to have installed renewables if given the choice. It is disingenuous for house-builders to claim that there is no demand for them when they have never actively promoted the idea. In any case in the light of rising energy bills this contention is unsound. The house-building industry needs to respond to changing circumstances and factor energy efficient house design and renewables into their modus operandi – and a modest downturn in the housing market would result in buyers demanding this anyway.

    Statement of Community Involvement questionnaires have been used in Merton as part of the Mitcham Town Centre sustainable communities planning process. The results have shown overwhelming support by local residents (90%+) to the inclusion of renewable and sustainable energy technologies as part of the regeneration plan.

    Occasionally a situation may occur where residents are resistant to new developments in their community that incorporate renewables. This would only be reasonable if an inappropriately sized wind turbine was proposed. There might be resistance to micro-turbines, but this is likely to be an irrational reaction to the national large scale turbine debate. Urban areas are inherently noisy environments, and small scale turbines will have a minimal impact on the noise landscape. Much less for example than traffic, aircraft, trains, buses, rain on corrugated iron shed roofs, wind chimes, music, banging garden gates, refuse collection at six in the morning, music, cats, dogs, foxes and drunks on the way home from the pub.

    The issue of spoiling conservation areas or local pressure groups militating against the used of renewables, should not intimidate LAs from implementing a 10% policy. It goes without saying that this shouldn’t mean that huge turbines can be erected in the middle of high density housing – but in general terms when considering the potentially catastrophic damage of aggressive climate change, aesthetics is clearly subordinate to the need to protect the environment for future generations.