Keynsham Community Energy has submitted a response to Bath and Northeast Somerset Council’s Local Plan Partial Update. The Update considers a wide range of planning issues, but KCE has responded to the three that are most relevant to our work: sustainable construction, renewable energy (including wind turbines) and electric vehicle charging infrastructure. You can read our full response below:

KCE is a Community Benefit Society set up to provide affordable, clean energy to communities in Keynsham. Our local energy projects offer community investment opportunities as well as reduced energy costs and lower carbon emissions. We are helping to give Keynsham ownership and control over its future energy costs and surety of supply, making it an even better place to live and work.
KCE welcomes B&NES Council’s update to its Local Plan and the emphasis placed on climate change mitigation and environmental quality. KCE supports the updates, particularly the strengthened policies around renewable energy: specifically on wind, sustainable construction and EVs.
KCE was pleased to see that the Local Plan update includes policies on sustainable transport planning and environmental quality.

KCE response to specific areas of the plan

Sustainable construction (DM1, 2 and 3) KCE recommends that B&NES implements the full Future Homes Standard by 2023, not 2025 – showing national leadership. KCE hopes to see the Local Plan following option 2 for residential developments.
KCE would support option 2 for existing buildings and a commitment to 20% reduction in regulated carbon emissions.
One further policy that KCE would like to see in the Local Plan is on larger scale renewables. Where a development site includes land appropriate for the development of larger scale renewables (e.g. ground mount solar) such opportunities should be explored – even if they would go over and above what is required to meet sustainable construction guidelines. For instance, community ownership of such larger scale renewables should be explored. This would unlock community investment to finance a project, and generate community benefit – meaning no additional cost to the developer.

Renewable energy (DM5) KCE welcomes the focus on energy storage (e.g. battery storage) and a prohibition on new gas fired generators. However, the targets for renewable energy have not been changed from the policy in the core strategy approved in 2014. KCE does not believe this goes far enough if B&NES is going to meet its target of net zero.
Local renewable energy is a crucial plank in achieving our net zero goals. Capital costs for installing local renewables are cheaper than large scale offshore wind (for example). A local energy infrastructure keeps energy bills down, and because it’s closer to where demand lies, it reduces transmission costs and losses. Profits made by community energy companies are ploughed back into the community via a community benefit fund.
What holds local, community energy back is constraints on the grid. If B&NES were to increase targets for local energy generation, it would signal to Western Power Distribution that it needs to invest in expanding grid capacity. This needs to happen anyway if we’re to accelerate the shift to EVs and heat pumps for heating our homes.

Wind energy (DM6 & 7) KCE strongly supports this new policy. Onshore wind is the cheapest of all forms of renewable energy, and balances generation and demand (as wind generates electricity at night). KCE notes that B&NES wishes to avoid wind generation in areas of high sensitivity. However, KCE would urge B&NES not to be afraid of putting turbines where people can see them. Surely they are less of a blot on the landscape than a gas fired power station?
It follows that KCE strongly advocates that B&NES option 2, allowing turbines in areas of moderate-high impact. This will protect those areas of the highest impact but provide the ability to select those sites that are best suited to wind energy and so be able to deliver what is needed with the fewest number of sites.
In addition, KCE recommends that B&NES spells out what it means by ‘community support’. At the very least, such clarification should point out that community support does not mean 100% support. Otherwise, one person or a small group might be able to stop an otherwise well supported and appropriate development.
It should be possible to draft guidance that highlights a range of factors that you might expect to see (or not see) in a project that has community support, without having to try and define what it means in absolute terms, which could be misleading and unhelpful in itself.
One of the indicators of community support should include project ownership by a not-for-profit community energy enterprise (a Community Benefit Society for example), with an asset lock that protects any asset for community benefit. Ownership by this sort of organisation offers local accountability, opportunities for local investment in the project, involvement and influence in the organisation’s governance and the opportunity to recycle surplus cash as benefit back into the local community.

Electric Vehicles (DM8) Policy on electric vehicle charging is important and welcome.
KCE supports option 1b for minor Residential Developments, and options 2b and 3b for major residential development and non-residential development with more than 10 parking bays, requiring 100% active charging facilities. This is because we need to encourage new homeowners to buy electric cars as soon as possible. If in five or ten years new charging technology is required, then the active charging facilities can be replaced.