Purpose of Energy Statements 1
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LONDON BOROUGH OF EALING ENERGY STATEMENTS – WHAT THEY SHOULD INCLUDE Purpose of Energy Statements 1. Introduction This guidance note provides further detail on addressing the energy hierarchy1 through the provision of an energy assessment to accompany planning applications. The purpose of an energy assessment is to demonstrate that climate change mitigation measures are integral to the scheme’s design and evolution, and that they are appropriate to the context of the development. 2. Guidance on integration with supporting documents for planning applications An energy assessment will always be required, however, where other documents are being submitted as part of a planning application, it may be appropriate to cross- reference these documents, provided cross-referencing is clear and the documents contain sufficient information to allow an assessment of the application. This may include the following: - Design and Access Statement - Sustainability statement/ Sustainability Checklist - Code for Sustainable Homes / BREEAM pre-assessment report - Environmental Impact Assessment All energy assessments should also contain a brief description of the proposed development. This should clearly state the number of each different type of residential unit e.g. 100 flats and 12 houses. It should also summarise the floor area allocated for different non-domestic uses. 3. Outline and full planning applications The applicant should clearly identify whether the proposal relates to an outline or full planning application. All outline planning applications will be expected to set out an energy strategy with commitments, to guide the design and development of a planning application at the detailed stages. Depending on the matters to be considered, applicants should still undertake initial feasibility work on each part of the energy hierarchy set out in this guidance. Ealing Council will secure the strategy through appropriate clauses in the section 106 agreement or through an appropriate planning condition, and require reserved matters applications to demonstrate consistency with the outline strategy. The strategy should include the following: - A target for overall CO2 reductions - A target for CO2 emissions savings through energy demand reduction measures 1 Mayor’s Energy Hierarchy – London Plan 2008 - Commitment to communal heating infrastructure if appropriate for the development. - Investigations of the feasibility and, where viable, commit to the installation of CHP in the proposed development. - Large-scale developments should provide a feasibility assessment to ensure that CHP is sized to minimise CO2 emissions. - Initial feasibility test for renewable energy + commitment to reduce CO2 emissions further through the use of onsite renewable energy generation, where feasible Full planning applications should provide the information set out below. Planning conditions and/or section 106 agreements should be used to secure the implementation of proposed measures, rather than secure feasibility work that should normally underpin a planning application. The technical and economic feasibility of such measures can be influenced by the stage at which they are considered in the design process. 4. Structure and Content of Energy Assessments Executive Summary This should be a non-technical summary setting out and committing to the key measures and CO2 reductions identified as part of the application for each stage of the energy hierarchy. The concept of applying the energy hierarchy in relation to 2010 Building Regulations is illustrated in Figure 1 below. Where the blue bars drop below the red line, this demonstrates savings in regulated CO2 emissions compared to a development that complies with the 2010 Building Regulations. In the example, it can be seen that the development exceeds Building Regulations compliance through energy efficiency alone, with further reductions achieved through CHP and renewable energy. Figure 1. The Energy Hierarchy Completion of the following tables should be undertaken to demonstrate compliance with the energy hierarchy. Carbon dioxide emissions (Tonnes CO2 per annum) Regulated Unregulated Total Building Regulations 2010 Part L Compliant A B C = A + B Development After energy efficiency D E F = D + E measures reduction After CHP G H I = G + H After renewable J K L = J + K energy Table 1. Carbon Dioxide Emissions after each stage of the Energy Hierarchy Carbon dioxide savings (Tonnes CO2 per annum) Carbon dioxide savings (%) Regulated Total Regulated Total Savings from energy efficiency measures A - D C - F (A – D)/A * 100 (C - F)/C*100 reduction Savings from CHP D - G F - I (D – G)/D * 100 (F - I)/F*100 Carbon dioxide savings (Tonnes CO2 per annum) Carbon dioxide savings (%) Regulated Total Regulated Total Saving from renewable G - J I - L (G – J)/G*100 (I - L)/I*100 energy Total Cumulative (A – J)/A*100 (C – L)/C*100 Savings Table 2: Carbon Dioxide Savings from each stage of the Energy Hierarchy Please note: When presenting the summary of the carbon savings being achieved, the Mayor’s proposed carbon reduction targets for new developments, outlined in the adopted London Plan 2011, should also be referenced as a material consideration till our proposed climate change policies in the LDF Development Management2,3 (Initial Proposals) to be adopted. With regards to Ealing Council’s current energy policy, UDP policy 2.9, is now largely superseded by policies in the London Plan 2011. The first and last clauses of policy 2.9 are still broadly applicable, although even these are better covered by policies in the London Plan. With regards to policy 5.2 of the London Plan 2011, the 25% reduction in CO2 over BR2010, for the period of 2010 to 2013, covers only regulated emissions and is preferred to be achieved through 'Lean' measures (passive measures). With regards to the 20% CO2 emissions reduction from on-site renewable energy generation noted in the supporting text below Policy 5.7 of London Plan 2011, is held as a target but not a fundamental requirement. It should be noted though that this target will be sought where it is feasible and viable and where the applicant does not recommend any measures normally applied under stage 2 of the Energy Hierarchy (be clean). This guidance will continue to be updated following the adoption of regional or local policies. After calculating the emissions at each stage of the energy hierarchy, the percentage savings over a 2010 Building Regulations compliant development should be provided (as shown in Table 2 above). 5. Establishing CO2 emissions 5.1 Baseline Energy Consumption This should include a breakdown of both regulated and un-regulated energy use. Regulated energy consumption should be calculated through SAP4/SBEM5 while non- regulated emissions should be also measured. Additional emissions associated with 2 Ealing 2026, Development Management Initial Proposals, September 2010 3 Towards Zero Carbon Development in Ealing, energy evidence base, September 2010 4 SAP is the Government's Standard Assessment Procedure for Energy Rating of Dwellings. SAP 2009 is adopted by government as part of the UK national methodology for calculation of the energy performance of buildings. It is used to demonstrate compliance with building regulations for dwellings - Part L (England and Wales) 5 Simplified Building Energy Model – other building regulation compliant software such as IES or TAS is also acceptable non Building Regulation elements for domestic developments (i.e. cooking and appliances) established by using BREDEM (BRE Domestic Energy Model) or Code for Sustainable Homes guidance and for non-domestic established by using individual end use figures (for example catering and computing) from CIBSE guide baselines (eg CIBSE Guide F), ECON 196, or evidence established through previous development work. In terms of the extent of modelling work required, the applicant should provide a representative sample of domestic properties and/or a print out such as a BRUKL report for non-domestic developments should be provided in an appendix of the energy assessment. A breakdown of the Baseline Carbon Dioxide (CO2) Emissions calculated using standard conversion factors7,8. - Total baseline CO2 emissions taking into account both regulated and un- regulated emission sources. - Baseline emissions should be calculated on a ‘whole energy’ basis which includes the energy consumed in the operation of the space heating/cooling and hot water systems, ventilation, all internal lighting, cooking and all electrical appliances and other small power. - Emissions associated with water and space heating should be calculated from a gas baseline, unless an electrical baseline can be justified. 5.2 Demand Reduction (Be Lean) It is technically possible to exceed Building Regulations requirements (Part L 2010) through demand reduction measures alone (see figure 1). Energy assessments should therefore set out the demand reduction measures specific to the scheme and demonstrate the extent to which they exceed Building Regulations. Measures typically include both architectural and building fabric measures (passive design) and energy efficient services (active design). Introducing demand reduction features is encouraged at the earliest design stage of a development. Demonstration of energy consumption and CO2 emissions reductions resulting from the implementation of the energy efficiency measures over the baseline9 - Provide details and any assumptions made of the energy efficiency measures that will be incorporated into