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Next Steps to Zero Carbon Homes - Allowable Solutions

Date: 15/10/2013

This response is made on behalf of the Planning Officers Society (POS). The Society represents the most senior professionals and managers of planning functions in the English Local Authorities. It is rightly styled as the credible voice of public sector planning and sets out to

  • be a preferred point of contact for public sector planners where they can access enable public sector planners to work together with Government and partners
  • be a strong and united voice for public sector planners supporting and shaping planning policy and practice in local communities
  • be a preferred point of contact for public sector planners where they can access learning, support and networking opportunities
  • find common ground with other disciplines, organisations and the media to improve the planning process, policy and implementation
  • broaden our membership and create a strong cohort of young planners, representative of the ethnic and gender diversity of the UK.

The Society's aim is to make planning more effective in delivering sustainable development to support the well-being of our communities. This aim is reflected in our consultation response below: 

1.    We welcome a streamlined process for Allowable Solutions which combines national standards with local characteristics, priorities and existing mechanisms. Where, for instance, local authorities have a clear offsetting policy in place, they may want to consider this a preferred delivery option against a regional or national mechanism

2.    Carbon offsetting activities, if planned in consultation with the local authority, could support wider strategies and projects funded through other means thereby maximising economies of scale and timing.

3.    There should be a mechanism to enable the Allowable Solutions to be first spent and implemented in the local authority / community it is generated. In addition to helping local authorities meet their obligations regarding climate change, Allowable Solutions are likely to also deliver other local benefits such as - improvements in local air quality, tackle fuel poverty, support local economic investment and supply chains. This approach fits in with the localism agenda.

4.    The projects the Allowable Solution can be spent on, the price, and the location of delivery should complement other Government strategies and initiatives such as local energy generation, DECC's national heat strategy, measures to address fuel poverty, ECO, and the Green Deal.

5.    More details are needed on the parameters for Allowable Solution projects. For instance;  

  • How will added value be ensured?
  • All projects should have some public benefit.
  • There is an anomaly for developers to retro-fit their own stock, e.g. scheme built in 2015 can be retro-fit with AS funds in 2016. This should be limited to charities, social housing providers.

6.    Price should reflect regional characteristics, and should reflect the cost of delivering projects on-site versus off-site to ensure on-site viable measures are maximised.

7.    For Carbon Compliance, the proposed level is low. Careful consideration needs to be given to 'carbon compliance' and the price of Allowable Solutions to optimise delivery of on-site carbon dioxide reduction measures. The level should not limit the investment and delivery of decentralised energy networks. Compliance level set needs to be clear. The performance gap needs to be addressed to enable schemes are performing as designed and therefore are 'zero carbon'.

Please do not hesitate to contact POS if you have any queries on the response attached.

Sule Nisancioglu, Planning Officers Society


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