Comment

Representation ID: 23337

Received: 11/10/2021

Respondent: Bloor Homes

Proposed Policy CC2 requires development of 10 or more dwellings to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. Where there is existing decentralised energy provision in close proximity to the site, the development will be required to connect to it or should be designed to accommodate a subsequent connection if a source
has not yet become operational.

BHL are aware that decentralised energy networks can deliver benefits, including low carbon heat to residents, helping to reduce the carbon footprint. Yet, notwithstanding its merits, there are certain difficulties in its application. For example, in the case of communal heat networks, currently the predominant technology for district-sized communal heating networks is still gas
combined heat and power (‘CHP’). The alternatives of large heat pumps, hydrogen or waste-heat recovery has been relatively slow on the uptake by heat network projects due to the large up-front capital cost. BHL consider that this will remain uneconomic for most heat networks to install low-carbon technologies for the foreseeable future.

Furthermore, BHL are aware of some reports and research that states that biomass renewable energy
plants are one of the biggest single sources of carbon dioxide and PM10 (particulate matter of 10 micrometres and smaller) air pollution of all EU power stations- more so than some of Europe’s Coal Plants. The UK Government treats bioenergy as immediately carbon neutral on the assumption that forest regrowth soaks up the carbon again but recent science disputes its carbon neutrality. BHL considers that more research needs to be done before decentralised energy provision is mandatory in local planning policy.