NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.

Energy - Heat

Proposed key objectives of NPF4: To maximise the contribution of renewable heat generation and systems to deliver renewable heat (such as district heating, electrical network upgrades) and reduce the cost of delivering this transition (such as supporting heat and electrical storage systems) to meeting our net zero targets in a sustainable way.

There was general support for decarbonisation of heat, although this was suggested to be one of the biggest challenges for achieving Scotland's net-zero carbon target and to require widespread roll-out of low carbon heating for homes. It was suggested that the increased grid capacity required for the electrification of heat should be a priority at both regional and national levels.

There was support for LHEES to become a statutory duty through NPF4 and calls for clarification of the relationships between LHEES, LDPS and LHSs. The importance of renewable heat network zones identified in LHEES being integrated into LDPs was highlighted, as was the need for a clear delivery plan.

It was reported that although LDPs may incorporate policies regarding heat networks, major housebuilders often argue these are not feasible for technical or economic reasons. Stronger policy was suggested to be necessary to allow local authorities to 'require' developments to contribute to net-zero rather than just to 'encourage' them to do so. It was also argued that if developers are not required to deliver zero carbon developments, competitive bidding for land will put those who seek to do so at a disadvantage. Using NPF4 to provide greater clarity on the role of the planning system in reducing carbon emissions from new development was suggested to be important in support of strengthening of Building Standards, and the need for alignment of new planning guidance with new Building Standards was noted.

There was support for heat networks and a welcome for the Heat Networks (Scotland) Bill. A national heat network policy to support planning authorities in requiring heat networks within new development was also proposed. The need for master planning of district energy and a framework for projects involving multiple landowners, properties and utility companies was also suggested to be necessary in order to create networks between adjoining uses and developments. It was argued statutory powers are required to connect across land not in Council ownership outwith the development site.

It was also noted that when the Heat Networks Bill comes into effect, the district heating industry will be conveyed with similar rights of servitude as other utilities and that this should be recognised by NPF4.

There was agreement that NPF4 should raise the profile for heat networks and create a favourable planning regime for the roll out of renewable heating across Scotland, and a suggestion this should be considered a National Development. However, it was also observed that district heating will not be viable in some areas - particularly where population densities are low - and it was argued that the focus of NPF4 should be on low carbon heat in general and taking a flexible approach going forward. Identifying the optimal measures for each location was suggested to be important.

Among comments on reasons that delivery of heat networks has been limited to date were that they may be seen as too complicated and not cost-effective, and are not popular with the general public. It was suggested that Historic Environment Scotland's review of its estate is welcome and could be used as a case study. A Development, Property or Land Management Company respondent noted concern that customers can become trapped into expensive schemes with long-term and expensive maintenance requirements and are unable to switch supplier.

Suggestions with respect to promoting heat networks included:

  • A presumption in favour of heat network projects.
  • Amending permitted development rights around the installation of heat network pipes to align heat network operators with other utility providers.
  • A National Green-Blue Infrastructure Network would highlight the opportunities for renewable heat networks at a national, regional and local scale, including the currently untapped energy potential of Scotland parks and greenspaces.
  • Consideration for permitting zero carbon development in locations that would otherwise be considered unacceptable - such as on green belt sites.
  • Eliminating business rates for heat networks.
  • Providing centralised expertise to planning authorities to assess proposed schemes.

Several respondents made specific recommendations with respect to requirements for new developments, including that:

  • An energy statement should be required for new developments, and relevant standards should be defined. The statement should set out how renewable heat/heat networks will be used and should be clear that a strong justification is required for not making use of renewable heat/heat networks.
  • Intentional and consequential venting of heat to atmosphere should be restricted in all new developments with limits set at as low a level as possible.
  • All proposals for new development should provide their primary heating requirements from renewable sources and assess their suitability for connecting to a nearby renewable heat network, where one is or is likely to be available.
  • Connections to renewable heat networks should be required for new developments located within heat network zones or should be required for larger developments.
  • NPF4 requirements in relation to renewable heat networks should apply to all scales of development and to consequential improvements.
  • Development could be 'future proofed' if suitable networks are not immediately available/viable.

It was argued that the infrastructure associated with heat networks should be recognised in the same way as that associated with other utilities and should be noted in LDPs. Recognition of the need to retrofit such infrastructure within mature urban environments was suggested to be of particular importance.

With respect to existing properties, it was suggested a substantial price differential may be needed to encourage individual installations which could be disruptive, and it was recommended that NPF4 consider how to encourage retrofitting. It was also argued that retrofitting should not be rushed, to ensure measures are appropriate and do not need to be replaced in the short term.

Other low carbon technologies

Although the majority of responses concerned heat networks, there were also limited references to other forms of low-carbon heating such as:

  • Heat pumps: Specific suggestions included: large ground source heat pumps to serve several houses; water source heat pumps; and hybrid heat pumps.
  • Hydrogen: There were calls for a high-level hydrogen policy supporting uses of hydrogen as an alternative fuel for purposes including heating, cooking, transport and for industry, although it was noted that the technology is still relatively immature. Continued support for research and development, in tandem with development of commercial applications was suggested, and the challenges associated with hydrogen storage and the infrastructure for hydrogen networks were noted. Identifying opportunities for local generation of hydrogen was also proposed.

Points on energy from waste are considered under the Waste theme.



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