This depends alot on how costs are calculated. There is an argument for requiring full life cycle costings.

As the economic benefits of some renewable energy systems are less certain than the energy benefits this paragraph may provide a larger loophole than intended. It might, for example, be used to avoid the requirement for affordable housing or other similar planning gains.

Supports sustainable development and construction techniques as an important principle for the district and recognises the significance and wider implications of a commitment to reducing climate change through the planning system.

Objects that the SPD will be applied to all development irrespective of the scale of development. This approach differs from emerging policy SR3 in the RSS (Preferred Options) which only requires 10% for developments of 10 dwellings or 1000 sqm and Policy DP13 which only requires 10% in appropriate residential and non residential developments. To accord with RSS and Local Plan policy paragraphs 1.4 and 4.2 should be amended to clarify that the SPD only applies to significant developments.

The submission of an Energy Statement should not be necessary for all planning applications and the format of each statement may vary as not all categories in paragraph 3.2 will be attainable. A uniform approach should not be adopted as the submission and format of the statement should be dependant on the scale and nature of the proposal.

Welcomes the use of preapplication discussions to help ensure certainty for the developer as well as the Council.

Welcome the recognition that meeting the 10% requirement may not be appropriate for all developments and supports that the SPD recognises the difficulties faced on constrained town centre locations.

Support the inclusion of para 4.6 which identifies the importance of maintaining financial viability and not undermining the the delivery of development.

Support the inclusion of para 4.4 which identifies the potential conflict between the provision of renewable technology and the preservation of the historic environment.

Supports the recognition that the installation of renewables can detract from the historic integrity of the building but appreciates that with careful consideration some installations may be appropriate with the historic environment.

Renewables toolkit should be attached as an appendix and consulted on separately prior to the adoption of the SPD.