It is considered that the policy is rather limiting in seeking the use of renewable energy sources on site or in the locality to acheive the 10% requirement. The Great London Authority has produced an Energy Hierarchy through which energy production from renewables is only categorised as tier 3. The SPD should be flexible to allow for other energy sources in particular reduced carbon technologies.

It is noted that paragraph 4.9 makes provision for a reduction in the 10% requirement if CHP is provided. This should be given greater emphasis in recognition of the alternative approaches which can be used to meet the same aims and objectives.