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Here Comes the Sun: Where to locate the next generation of solar farm sites
The UK has established a world first in becoming the first major economy to pass a net zero law, which aims to bring all greenhouse gas emissions to net zero by 2050.  To achieve this, development of standalone and integrated solutions will be needed to reduce the emissions associated with energy consumption within all facets of our society. With the COVID-19 pandemic, we have all seen the CO2 reduction impacts that can happen when our economy is effectively shut down, but the key is how do we make this reduction in emissions sustainable as the focus shifts to recovering and subsequently growing the economy with fossil fuel prices at a record low? Solar energy has long been part of the solution. The cost of solar has plummeted by over 70% in the last decade. Only a few weeks ago the UK Solar Trade Association CEO, stated: “Solar is playing a critical role in delivering a fossil-free grid and cleaner, cheaper power to Britain. As we look towards a net zero future, solar will become an increasingly greater part of the energy mix, tackling high power prices, climate change, and biodiversity loss.” Added to this, the UK Government announced earlier this year that it would reintroduce Contracts for Difference subsidies for new solar farm developments in 2021, providing a new route to market for prospective schemes. It is clear that solar PV is both impactful and deliverable in the UK, and with falling prices, improved system efficiency and increased Government support, the technology looks more attractive than ever. But what exactly does it take to deliver a commercially viable solar development?  We know a number of factors need to be considered when identifying a suitable site and that the process of site selection is complex and varied.  So how best to go about it?  This blog begins to unpick the challenges of solar development and explain what it takes to get from a greenfield (or empty roof) to a fully developed commercial installation, focusing on how to identify the most suitable sites for development in the UK. Operational Challenges Identifying networks with available capacity - As the UK network generation make up shifts from the traditional large power generators (oil/gas/coal/nuclear) to a more renewable-led make up, with solar and wind at the fore, how this generation is spread across the network has changed.  Smaller renewable generating sites are connecting within the network as ‘Embedded Generators’ – very different to the traditional large generator connections at the highest level (National Grid) which then filtered down through the network. As this embedded local generation becomes more widespread, we are seeing networks becoming more congested with resultant increases in the connection fees for new generators and program delays as the Network Operators are required to upgrade their networks to accommodate the new connections.  Understanding the current limitations and knowing where national and regional network upgrade works have already taken place is an essential part of robust renewables business planning. Identifying viable connection points – Identifying the type of connection that will be most appropriate for your project is also key.  The size of a project (in terms of output MW) dictates the best option for its connection.  For example, it may be feasible to connect a new 5MW generator to a National Grid substation, but it would certainly not present the most cost-effective solution. Equally, trying to connect a large project, for example 200MW, to a Distribution Network Operator substation is unlikely to deliver the most cost effective/best technical solution.  Knowing the intricacies of the grid connections and developing good links to the network operators is as critical as knowing the land area you have available in the feasibility stage of any project. Achieving a sufficient irradiance level – Another key factor is the irradiance level i.e. the solar resource available at the proposed site. Historically, development north of an imaginary line between the Humber and North Wales has been deemed unworthy of consideration, but the current granularity of irradiance data and economic returns associated with solar means this is now clearly incorrect. There are a significant number of solar PV installations operating successfully north of this line, indeed into Scotland, and a backlog of planning applications for additional generation in the north, indicating that investors and developers see this area as a positive location.  A number of factors have driven this change including: Technology advancements – panels operate with a slightly improved efficiency in cooler temperatures; thus the fall in actual available energy to convert is compensated by improved efficiency of conversion. Panel capacity has improved whilst prices have fallen. Larger capacity panels means installations can be developed using a smaller land area. Assuming suitable topography, this can be as little as 3.5 acres per MWp without adversely impacting row shading. In the north of the UK, and especially into Northern Scotland, daylight hours during the cool summers are significantly longer and the extension of morning and evening light extends the generation period over sites thus compensating for the lower irradiance level at higher latitude. Advances in technology and site search techniques mean that the north of the UK should be on the table.  And with typically lower land prices and further competition for development space in southern areas, appropriately sited solar arrays in the north can give very positive results in terms of site payback. Planning Challenges In pursuing any new solar farm project, one of the greatest challenges is finding a site which is not only operationally viable, but one which can achieve planning permission. Planning policies in Local Plans very rarely include specific land use allocations to support such proposals and, typically, only provide limited policy details as to how renewable energy development – in its broadest sense – will be considered in the determination of individual planning applications.  Planning Practice Guidance does, however, provide a useful steer as to the range of ‘planning considerations’ which Local Planning Authorities should take into account when determining the acceptability of large-scale solar farm schemes. Finding viable solar farm projects which are capable of performing well against all aspects of these considerations is no easy feat and, indeed, proposals which are located within the Green Belt face even greater hurdles in planning terms. Here, there is also the need to demonstrate very special circumstances which paragraph 144 of the NPPF confirms, unequivocally, “will not exist unless the potential harm to the Green Belt by reason of inappropriateness and any other harm, is clearly outweighed by other considerations”. Through careful site selection at the outset, we have been successful in overcoming the policy hurdles and obtaining permissions, including in the Green Belt. Locate:Solar Lichfields, in partnership with ITPEnergised, has developed an innovative, site-finding toolkit (“Locate:Solar”) which seeks to identify suitable and viable solar farm sites by addressing these technical and planning challenges head on. The output is an interactive aerial map, whereby users of the toolkit are able to obtain full details of viable solar farm locations which have been ranked according to their relative level of planning constraints, environmental sensitivities and technical suitability. For developers, this allows new solar farm proposals to be put forward which have the best prospects of securing planning permission, whilst also being able to demonstrate the absence of alternative more suitable sites: a central requirement of national policy. For landowners, Locate:Solar identifies the potential for new solar farm development within a given landholding and, in turn, opportunities to support existing rural businesses and landowners through a regular and reliable new income stream. For local planning authorities, Locate:Solar can identify suitable new renewable energy sites for inclusion in emerging development plans, forming an important, tangible part of the response to the climate change emergency, whilst supporting the principles of sustainable development and rural diversification. ITPEnergised is a specialist renewable energy consultancy enabling projects from concept to operation and asset management. Ruth Fain is an Associate at ITPEnergised. James Cox is an Associate at Lichfields.  

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Planning for climate change: How is Aviation responding?
This blog is the third in Lichfields’ series of blogs examining the climate emergency in planning – it looks at how aviation is responding (pre and post-COVID-19 crisis) and what is clear is that the pressure on aviation to become more sustainable is beginning to return and the time to plan is now. Aviation’s contribution to greenhouse gas (GHG) emissions The global aviation industry produces around 2-3% of all human-induced carbon dioxide (CO2) emissions. In addition to this, aircraft also release non-CO2 emissions (NOx, soot, and water vapour). These non-CO2 emissions roughly equate to the same quantum as the CO2 emissions. In the UK, this combined figure is greater than the global average and commercial departing flights alone account for about 7% of national GHG emissions (CO2 and non-CO2). Has the COVID-19 crisis had an impact? The COVID-19 crisis has seen the aviation industry come to a near standstill. After four (long) months, aviation is slowly making its return to the skies. The week commencing 4 May saw a global rock bottom for the sector, with 29.2 million scheduled seats flying that week – some 80 million fewer seats compared with the same time the year before[1]. In the UK, during that same week and with borders closed and most States advising against all but essential travel, capacity dropped to operating less than 7% of typical activity. Fast forward to 13 July, as traffic is beginning to return with the establishment of travel corridors, UK traffic has seen a bounce back of some capacity but is still operating at only 24% of pre-COVID activity[2]. Looking ahead, an ‘L-shaped’ recovery is anticipated for the sector, taking 3-5 years for a return to pre-COVID traffic levels. With this significant drop off in activity, unsurprisingly there have been reports of temporary reductions in daily global CO2 emissions. For the period January to April 2020, Nature Climate Change cited [3] calculated a decline in CO2 emissions by –60% or –1.7 (–1.3 to –2.2) MtCO2 d−1 for the aviation sector. This equates to 10% of the total global decline in CO2 emissions due to the COVID-19 crisis (the big hitters, where there was significant decline, were the power, industry and surface transport sectors). The decline is considered temporary and the International Monetary Fund (IMF) forecast that global emissions will rebound by +5.8% in 2021 – however it’s not clear what role aviation emissions will have in this initial rebound. Why aviation remains a sector to focus on So, if aviation ‘only’ represents 2-3% of global CO2 emissions, and following a near standstill of activity it can ‘only’ achieve 10% of the global reduction associated with the COVID-19 crisis - why is it a sector to focus on? Broadly speaking, the issue is manifold: The 2-3% figure accounts for CO2 emissions associated with departing flights and doesn’t account for total GHG emissions (CO2 and non-CO2). Nor does it account for emissions arising from aviation-related activity and its wider supply chain (however the latter is often, but not always, captured within other sector inventories). Aviation is identified as one of the fastest growing sources of GHG emissions, and in the UK, aviation is likely to be the largest contributor to UK emissions in 2050. As the sector recovers from the COVID-19 crisis, it will be interesting to see if this remains true for long-term GHG forecasts. Pre-COVID crisis, Aviation was one of the top emitters - if global aviation was a country it would be the sixth largest in the world between Japan and Germany. Aviation is a difficult transport mode to reduce emissions from. It will not a quick exercise given the long lifetime of aircraft and current lack of zero-carbon alternatives – and reducing demand, as evidenced from the COVID-19 crisis, can have serious socio-economic and political implications. How is aviation policy tackling these issues? Aviation policy is agreed globally then it is for the UK to reduce its own emissions through domestic policy. Like with wider climate change initiatives, there is no silver bullet for the aviation sector and a multi-prong approach is required. International agreements Historically, aviation has always been treated differently. Under the Kyoto Protocol (1997) international aviation was excluded from national emission inventories and instead requested that Parties work with the UN aviation agency – the International Civil Aviation Organisation (ICAO) – who has overarching responsibility for global policy on reducing international aviation emissions. The Paris Agreement (2016) also did not specifically reference international aviation but requires all sectors and Parties to pursue a limit in temperature increase to 1.5 C target. ICAO has developed the CORSIA[4] scheme, which stands for ‘Carbon Offsetting and Reduction Scheme for International Aviation’. The scheme’s objective is to make all growth in international flights after 2020 carbon neutral. It was adopted in 2016, commences in 2021 and will address emissions that exceed 2019 baseline levels (it was to be a 2020 baseline however this has been amended due to the COVID-19 crisis). Currently more than 70 countries, representing more than 85% of international aviation activity have volunteered to participate (the scheme will be voluntary until 2026). Measures primarily include offsets and use of alternative fuels. Airlines will have to buy emissions reduction offsets from other sectors to compensate for any increase in their own emissions, or they can opt to use lower carbon CORSIA eligible fuels. CORSIA aims to complement a broader package of measures to achieve sector-wide carbon-neutrality such as increasing fuel efficiency and operational improvements. There are currently no policies in the world (internationally-led or domestically) that seek to directly tackle aviation’s non-CO2 impact. UK Government policy Domestically, the Department for Transport is responsible for most policy on air travel; the Department for Business, Energy and Industrial Strategy is responsible for energy and climate change mitigation policy and major funding of research and development in aviation; and the Treasury oversees fiscal policy affecting aviation. Under the UK’s ‘net-zero’ emissions legislation, net UK GHG emissions must be zero by 2050. Emissions from international travel are currently excluded from the legislation, and the UK Government has yet to clarify how they will be accounted for. The Committee on Climate Change (CCC) has advised Government that emissions should explicitly be included in the UK’s net zero target, and that the UK should increase its efforts to mitigate emissions from aviation – with measures including new technologies such as new aircraft and engines, electric aircraft and alternative low-carbon fuels (battery, hybrid, hydrogen, bio-fuels), more efficient operations, demand reduction and emission off-setting. Other groups, such as local planning authorities and Environmental NGOs, are pushing this agenda. Earlier in the year, the designation of the Airports National Policy Statement (ANPS, the key policy document for the Heathrow North-west runway proposal) was found unlawful by the Court of Appeal as it did not take account of the Paris Agreement. This means that the ANPS has no legal effect unless and until Government reviews the ANPS, and it cannot be relied upon when demonstrating a Development Consent Order (DCO) need case. The timing of this review remains a decision for Government. Aviation continues to not be subject to fuel tax or VAT. Sector-led initiatives There are a number of sector-led initiatives paving the way for change – led by aviation regulators, airport bodies, aerospace and aircraft manufacturers, and advanced technology innovators. Some noteworthy mentions include: The Airport Carbon Accreditation scheme[5], which is an airport-led commitment to reduce carbon emissions with the ultimate goal of becoming carbon neutral. Currently it is the only institutionally-endorsed, carbon management certification standard for airports, with more than 300 airports globally participating. Airbus is working with groups such as Siemens and Rolls Royce to develop next generation electric-powered and zero-emissions aircraft technology. The Civil Aviation Authority, NATS and airport operators are driving forward major Airspace Change proposals across the UK. This will provide the opportunity for more efficient operations and a reduction in fuel use. Post-COVID: is aviation’s future carbon neutral? At the launch of Government’s New Deal[6] in June (‘build back better, build back greener, build back faster’), PM Boris Johnson set out a vision to safeguard the future of the economy and tackle climate change - and for the UK to lead in markets and technologies such as producing the world’s first zero-emission long-haul passenger plane (‘Jet Zero’). But how achievable is this? Technologies are already being progressed for alternative aircraft. It’s thought that hybrid aircraft will be the next step for the industry and could plug the gap until technological requirements for electric aviation have been met. A number of aerospace companies are working on electric aircraft and short to medium range electric flight seems achievable and is on the horizon (with some craft due for certification in 2020/21) – but not yet craft that is comparable to the commercial jets we see in our skies today. Given around 80% of CO2 emissions from aviation come from long-haul flights over 1,500km, the real difference will be from further developments in battery technology and aircraft design. What remains clear is that the pressure on aviation to become more sustainable is beginning to return. The industry will need to grow back and in sustainable manner with a desire to come back better than before. An integrated approach, drawing on the involvement and collaboration of all industry participants will be required, including aerospace and aircraft manufacturers, advance technology innovators, those supporting the funding of R&D, regulators, Government bodies, and at a local level planning authorities and Local Enterprise Partnerships. Lichfields is well placed to help navigate a planning response to the climate change emergency. Contact us for further information.   [1] https://www.oag.com/blog/coronavirus-update-week-seventeen[2] https://www.oag.com/coronavirus-airline-schedules-data[3] https://www.nature.com/articles/s41558-020-0797-x[4] https://www.icao.int/environmental-protection/CORSIA/Pages/default.aspx[5] https://www.airportcarbonaccreditation.org/component/news/news/891.html?view=news[6] https://www.gov.uk/government/news/pm-a-new-deal-for-britain  

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