Permitted development rights for small scale renewable and low carbon energy technologies, and electric vehicle charging infrastructure (DCLG)

Submission from ALGAO:England

5 February 2010

Response by the Association of Local Government Archaeology Officers to the Communities and Local Government Consultation:-
Permitted development rights for small scale renewable and low carbon energy technologies, and electric vehicle charging infrastructure

ALGAO is the national body representing local government archaeology services at County, District, Metropolitan, Unitary and National Park authority level. These provide advice to all the District, Unitary and other local government bodies in the country. ALGAO: England co-ordinates the views of its member authorities (106 in total) and presents them to government and to other national organisations. It also acts as an advisor to the Local Government Association (LGA) on archaeological matters. The range of interests of our members embraces all aspects of the historic environment, including archaeology, buildings and the historic landscape.

The historic environment is vulnerable to change, once destroyed archaeological evidence is lost for ever. Mitigation strategies can be developed for historic assets that are under threat, the broad approach is set out in PPG15: Planning and the Historic Environment (1994); and PPG 16: Planning and Archaeology (1990). Where preservation in situ cannot be achieved recording of archaeology by excavation or building analysis is possible. The historic environment can make a positive contribution to planning for new development and new communities, and a sense of place, but needs to be assessed and integrated into the planning process from the start.

We welcome this opportunity to comment on the Government’s proposals in this important area. We share and support the Government’s concerns to tackle climate change. Microgeneration should make its contribution to this effort, and we recognise the value of this measure, amongst others. We believe that there are ways to successfully implement the various techniques for microgeneration which will be sympathetic to urban design, and the historic environment in particular. Some further thought is needed to clarify guidance, particularly in regard to the impact of construction on below ground archaeology.

Our comments need to be viewed in the context of increasing extension of permitted development rights, which threaten in places to accrue into considerable damage to the historic environment through piecemeal actions.

We welcome the recognition, in section 2.40, that excavation for ground source heat pumps could harm important archaeological sites; and that the construction of other technologies, particularly wind turbines, might also have an impact. We therefore welcome the fact that ground source heat pumps are not to be permitted domestic development.

Whilst we welcome that the erection of wind turbines within the curtilage of a listed building or on a scheduled monument would require the appropriate consents, our concerns also extend to the erection of free-standing wind turbines in non-designated locations.

Q3: We do not agree that the construction of a free-standing wind turbine on non-domestic premises should be permitted development

We note that it is proposed to extend permitted development rights for ground source heat pumps installations on non-domestic premises of up to 0.5 hectare. In our view this is an unacceptable potential threat of damage to the buried, but often not protected, archaeology of this country. We are aware of at least one case where a ground source heat pump trench has dug through a scheduled monument, as the installer failed to make due enquiries of the historic potential of the site.

We are not satisfied that the provisions set out in 2.41 are adequate to alert an installer to the potential of archaeology being at risk on a site they may be considering.

The justification in section 4.11 that ground source heat pumps should not exceed 0.5 ha solely on the grounds of: To protect against risks of disturbance
to ecology and groundwater drainage
is extremely disappointing, and overlooks the archaeological concerns. No mention is made of the potential threat to scheduled monuments.

Q5 We do not agree with this proposal, and advocate that permitted development rights are not extended to ground source heat pumps, whether horizontal or vertical, in non-domestic lcoations.

We feel the planning context ensures proper consideration for the potential impacts that these might incur. For instance, a pre-application initial appraisal of the historic environment of a site, as recommended in PPG 16, should establish if there are archaeological concerns about the location of such installations, or not.

ALGAO Planning and Legislation Committee

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