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Solar panels on protected heritage

Nov 3, 2022

Solar panels on protected heritage

BELGIUM-FLANDERS

Due to the energy crisis and the sharply rising energy bills, our minister is contemplating a radical adjustment of our policy on solar panels on roofs of (protected) heritage. Very briefly explained, our current policy is: no solar panels on roofs of protected buildings when they are visible from the public domain. Our minister would like to move to a position where solar panels are allowed on all roof segments, even if they are visible from the street.

With a view to making a sound decision, we would like to know:

–  What is your current policy on solar panels in heritage context?
–  Are you struggling with the same increasing pressure regarding solar panels?
–  Do you foresee a relaxation in policy on solar panels? If yes, do you have already an idea of your revised rules? Or do you have other solutions in mind, like electricity cost compensation for owners of historic buildings,…

 I would be grateful if you could get back to me in the next couple of days, as our minister would like to take a decision in the very near future as well.

BULGARIA

What is your current policy on solar panels in heritage context?
Our cultural heritage law does not allow solar panels to be placed on roofs of protected buildings. Depending on the area, they might also not be allowed to be placed on any roof in historic centers. External thermal insolation is also not allowed to be placed on historical heritage buildings. If a building – immovable cultural heritage needs to be isolated, we can use external thermal plaster or internal isolation eventually. If a solar panel is placed on a secondary building it should not be visible from the street or from a higher place.
There are some exceptions for solar panels though. It depends on the historical period to which the building belongs. So we can conclude that each case is considered individually.

Are you struggling with the same increasing pressure regarding solar panels?
Yes, there is a pressure. There is an increasing number of owners of cultural heritage properties that want to place solar panels on their roofs.

Do you foresee a relaxation in policy on solar panels?
Not in the next years.

If yes, do you have already an idea of your revised rules? Or do you have other solutions in mind, like electricity cost compensation for owners of historic buildings,…
For the moment there are no such compensations. But the Plan for recovery and development of Bulgaria envisages investments in renewable energy sources for the next few years.

CZECH REPUBLIC

We are currently dealing with the challenges in respect of the installations of the solar panels on the roofs of Heritage protected buildings. Below please find briefly answered questions. National Heritage Institute of the Czech Republic will also pay attention to this problematic issue in the upcoming International Conference „Challenges of Contemporary European Heritage Care“ that will be held on the occasion of the Czech Presidency of the Council of the European Union. The conference will take place 9 – 11 November 2022 in Prague. You can find more information about the conference and registration on this link https://www.npu.cz/cs/o-nas/projekty/po-stopachslechtickych-rodu/87148-challenges-of-contemporary-european-heritage-c

What is your current policy on solar panels in heritage context? 

In the Czech Republic, there is also a pressure to allow installation of the solar panels without limitations. In spite of that, we currently succeeded to achieve that the solar panels cannot be installed on the roofs of the Cultural Heritage buildings and in the Heritage protected reserves. Installation of the solar panels can be allowed only on the base of individual assessment according the criteria, which were defined in advance. In short, the criteria are: 

  • solar panels must not be visually exposed from the public place or from distant views 
  • solar panels must not reduce the Heritage value of the Cultural Heritage building or Heritage protected reserve. National Heritage Institute issued a Methodology that sets conditions upon which the installation of the solar panels is or is not possible. This Methodology is accessible on our website. Unfortunately it is only in the Czech language. Fotovoltaika – Národní památkový ústav (npu.cz) 

Are you struggling with the same increasing pressure regarding solar panels? Yes, we are also dealing with the increasing pressure regarding solar panels. 

Do you foresee a relaxation in policy on solar panels? If yes, do you have already an idea of your revised rules? Or do you have other solutions in mind, like electricity cost compensation for owners of historic buildings,…
As stated above, we managed to handle the legislative change so far.

 

CYPRUS

What a current issue!! We are facing the same pressures. As a rule, the current policy states that it is not allowed to place solar panels on roofs of protected buildings. Depending on the area, they might also not be allowed to be placed on any roof in historic centers. However, due to the real need to cut down on electricity, there may be exemptions. For example, solar panels may be placed on roofs of additions of protected buildings (but not on the main protected building regardless of whether it is visible from the street) or on the roofs of secondary dwellings. In all cases they should not be visible from the street or major viewpoints. Moreover, they may be allowed on contemporary pergolas and car ports. There is a case by case examination of applications. This is more likely to be included as guidance in the revised policy expected to be issued by the end of the year. Another solution is the “energy communities” policy. This means that a whole historic community may construct a solar park for its needs and each individual household will be connected via virtual metering. The legislation is in place but we still haven’t had a case where this possibility is exploited. This is valid for any village regardless of the altitude whereas commercial solar parks are not allowed on an altitude above (I think) 850m. This is a subject that interests me a lot. I would also like to know how other countries are dealing with it. I am available for further discussion. 

FINLAND

Indeed, solar panels are a very current topic at the moment. Below some points of view from Finland / Finnish Heritage Agency. We’d be most interested in the results of this query and current situation in other European countries. 

Solar energy in historic environments in Finland

 Interest in solar energy has been growing rapidly in Finland as well. The reasons are similar to those in other countries: the desire to produce energy more sustainably, close to where it is used, as well as the rise in energy prices and the pursuit of energy self-sufficiency. Households and companies are encouraged to invest in solar energy e.g. with the government’s loan guarantee. We do not have any kind of electricity cost compensation for owners of historic buildings. The Finnish Heritage Agency (FHA) and the museums with regional responsibility take more and more often a stand on the question if solar panels are suitable for listed buildings and historic settings. For now, there is no separate national guidance especially for protected buildings on solar energy, but the FHA has started to prepare guidance for protection professionals. The FHA’s starting point for sustainable forms of energy production is positive and looking for casespecific solutions in heritage sites. In its recently completed Sustainable Development Action Program, the Finnish Museum Agency has committed to take different dimensions of sustainability into account in its operations. The FHA evaluates solutions regarding renewable forms of energy primarily in relation to the cultural-historical and landscape values of each protected building, structure or target complex, as well as possible protection regulations. One essential starting point is also that the lifetime of all solar collectors is shorter than that of protected buildings, and therefore the panels should be removable or replacable in a way that does not damage the buildings and their structures. In assessing the solutions, the FHA takes into account e.g. 

  • whether the building’s key characteristics can withstand an addition such as solar panels, whether the proposed solution is possible from this point of view, or if not, whether it is possible to find alternative solutions; 
  • aspects of construct and materials, can the e.g. traditional structure and materials withstand the solar panels; 
  • where to place the panels, directly in connection to the building or separately e.g. as a solar panel park (site-specific planning); 
  • if necessary, it is also assessed whether the panels have landscape or cityscape effects. In a successful solution, the panels do not bring a highly visible, new subject or change to the character of the protected building or to the building complex or to the valuable cultural landscape. 
  • At some cases, solar panels can also be part of a natural continuum of technological innovations, fit the character of the place and bring a positive addition to it, e.g. industrial heritage sites. 

Some comments and additional points of view to think about are: 

  • The rapid technological development of solar energy utilization and the increase in the number of different alternatives also speak in favour of careful site-specific planning. 
  • In certain historic wooden towns (WHS Old Rauma, Old Town Porvoo) no solar panels are allowed at the moment. This might change as the technology develops further. 
  • Cultural heritage sites are often also tourist destinations. Sustainable energy solutions are part of the growing sustainable tourism. 
  • At the same time, it is also necessary to think about ways to reduce energy consumption at the level of a building and building complex. The introduction of solar panels should be considered as part of the overall energy consumption and production of the building of any kind. 

Rakennussuojelu nyt: Aurinkoenergia historiallisissa ympäristöissä – Museovirasto

 

GERMANY

Yes, indeed! There is the same discussion and the same activity in rather all German States in „empowering“ the Cultural Heritage Acts „for the needs of modern times“!!! 

In rather all of the sixteen German state the laws on the protection of historical monuments are being “improved” in terms of energy efficiency, following the requirements of the Federal Republic of Germany f. e. in the new Federal Energyy Efficiency Act (§ 2 sent. 1 EEG). For example, the state of Baden-Württemberg will in future make it easier to install photovoltaic systems on listed buildings. Anyone, who wants to install a solar system on or on top of a cultural monument generally needs a permit under the law on the protection of historical monuments. According to the new guidelines of February 2022, however, this approval is now to be “regularly granted”, if the solar systems are subordinate to the covered roof surface and are installed over as large an area as possible and in matching colors. 

Many owners of listed buildings, especially churches, want to make a contribution to climate protection. This wish is to be taken into account with the new guidelines. In the future, a photovoltaic system can only be rejected, if the listed building is significantly impaired. In the individual case assessment, it should also be taken into account, for example, whether the solar system keeps a sufficient distance from the edge of the roof or whether it is largely adapted to the color of the roof. 

The following points form the basis for the individual case decision: 

It must be examined whether alternative sites, for example on subordinate outbuildings, are better suited for construction. If there are artistic protection reasons for the cultural monument, it must be examined and separately justified whether there is a significant impairment of the appearance and/or a significant substance intervention in the construction of solar systems. In this case, the installation cannot be approved as a rule. Solar installations must be subordinate to the covered roof area. Cultural monuments that lie within the protection area of an already recognized or potential UNESCO World Heritage Site remain unaffected by the guidelines. 

Accordingly, the Free State of Bavaria is currently amending its monument protection law. If the measure serves the extraction of renewable energies or the energetic improvement, the permission in the case of the planned change of an architectural monument or in the proximity of an architectural monument can be refused in the future only, as far as overriding reasons of the monument protection are opposed to and these cannot be taken into account by ancillary provisions on the type of implementation. 

“The high-speed train” has already successfully begun in Germany to simply roll over the first “values” which became sacred again to our societies after 1945. The state laws for the protection of the substance of our structural and archaeological cultural heritage are being transformed into laws for the protection to damage and destroy the architectural monuments, all under the guise of “the good deed”, above all the saving of our climate and our energy supply. In the German States, therefore, one begins “logically” to act with the approx. 1-2% of all built structures, not with the 98- 99%. In any case, the roof landscapes that characterize towns and landscapes, will be rather completely lost. What does it matter! In Europe one followed in the middle of the century the fetish of the “the car-fair city” with not rarely more devastating consequences than by the destruction of World war II! 

I ask for your indulgence for these somewhat personal, despite all understanding for balance of interests and concerns unfortunately more than true words.

And sorry that the links are always only in German language. 

ITALY

What is your current policy on solar panels in heritage context?
No solar panels on roofs of protected buildings when they are visible from the public domain. 

Are you struggling with the same increasing pressure regarding solar panels? Yes the pressure is very high and Ministry of Culture is struggling more than other institutions. 

Do you foresee a relaxation in policy on solar panels?
Not in the next years 

If yes, do you have already an idea of your revised rules? Or do you have other solutions in mind, like electricity cost compensation for owners of historic buildings,…
The italian government is planning new compensations

MALTA

What is your current policy on solar panels in heritage context?
Malta has planning guidelines on solar panels on buildings located within historic cores (not solely scheduled), and that any proposal for such panels will be considered on a case by case basis, and may be acceptable if these do not have a negative visual impact. 

Are you struggling with the same increasing pressure regarding solar panels? Yes, especially in very sensitive sites, such as the old medieval capitals of Malta and Gozo (both called Rabat incidentally). Government has a strong position on green energy, and the use of PV panels is encouraged. Unfortunately, in the past many panels have been installed without obtaining of necessary permissions. Drone imagery has shown that previously inconspicuous PV panels that had been installed within these cities, if not designed well, have a negative impact on aerial views of the cities. 

Do you foresee a relaxation in policy on solar panels? If yes, do you have already an idea of your revised rules? Or do you have other solutions in mind, like electricity cost compensation for owners of historic buildings,…
The current policies are enough to allow the installation of solar panels if well designed. There was a case where electricity compensation was recommended to owners of a historic building within a medieval city in Gozo, or sharing of ownership of PV panels within a planned solar farm. I’m not aware that our recommendation was accepted.

NORWAY

Thank you for this interesting request for advice regarding the policies for the installation of solar panels on roofs of (protected) heritage. I can inform you that the Norwegian Directorate for Cultural Heritage (Riksantikvaren) is also working on these subjects. We have not yet finalised our policy but we expect to do so by end October/early November. We will get back to you with more information then. 

SCOTLAND

Historic Environment Scotland does not have a policy that engages with this topic specifically. We do have guidance on micro-renewables, which is what we would refer to in advice on cases involving solar panels. (Link here: https://www.historicenvironment.scot/archives-and-research/publications/publication/?publicationId=7604a41c-077c-42ab-941f-a60b009a4f95)

 The relevant paragraph says:

“Installation of solar panels on the principal elevation of a historic building should be avoided because of the detrimental visual impact. Therefore, if historic buildings face south, their main roof slopes may be inappropriate as locations for solar panels. Alternative solutions should be explored, such as installation on secondary roof slopes, on locations hidden from main views, or on surrounding areas such as sheds, gardens or fields. Panels have been successfully installed behind parapet walls or on the south-facing inside rise of M-shaped roofs.”

 However, our advice would always focus on whether installation of panels would affect the cultural significance of the asset. Decisions would therefore depend on the individual asset and the factors contributing to its cultural significance. This would involve considering what the most important views of an asset or building are, and how they are affected. Where we think that solar panels may have significant effects we may offer advice on alternatives, such as ground-mounted panels.

 We are regularly consulted on applications to install solar panels, but have not tracked a particular trend in this application type. We cannot easily get figures for this, but our Planning, Consents and Advice Service have noted that consultations on solar panels seem to be increasingly common.

 We have also recently granted consent for the installation of solar panels on the National War Memorial at Edinburgh Castle. There is an article about this on our website: https://www.historicenvironment.scot/about-us/news/bright-future-for-edinburgh-castle-as-solar-panels-installed/

 We do not currently have any plans to publish new policy on this topic. However, we intend to include climate adaptation and mitigation measures as considerations in all of our new and revised guidance.

Other useful insight: A Q&A session made by Historic Environment Scotland’s Technical Research team on micro-renewables: https://www.youtube.com/watch?v=aMKG-Cb9KWQ

SWEDEN

Solar panels on culture heritage is an important and current question in Sweden. So far, we have no policies in this field but we are interested in take part of good practices and example from other countries. 

THE NETHERLANDS

Here is the Dutch answer, unfortunately some policy letters are in Dutch only.

The actual policy in the Netherlands concerning using solar panels on national monuments is based upon several decisions made in July 2020. From that moment on the policy on solar cells and panels was eased and more relaxed in order to provide owners of monuments more space and opportunities to use cells from a sustainable point of view. The (EU) Climate Deals were leading in this. Without doubt, monuments can play a significant role in energy-saving and in a cleaner energy charging. 

From that moment on it was no longer the main and decisive issue if solar panels are visible from public space or not. But rather whether the panels are disturbing or effecting the values of the monument in a negative way. As a result, our Cultural Heritage Agency gives more positive permits and advises now. Panels can be removed afterwards easily, if applicable. 

For sure, unbalanced and visual disruptive and disturbing changes due to panels are still forbidden. Moreover, panels on monuments in protected village and townscapes, in historical ensembles or in historical estates or parks will not receive a positive advice either. These cases will be restricted and handled with extra caution. 

Lately we published at least three brochures on this matter. They are in Dutch and can be found: 

RCE versoepelt adviesbeleid zonnepanelen | Nieuwsbericht | Rijksdienst voor het Cultureel Erfgoed 

Advieslijn zonnepanelen op rijksmonumenten | Richtlijn | Rijksdienst voor het Cultureel Erfgoed 

– Also there is a special policy for private households and smaller businesses and entrepreneurs, the so called MKB-regeling of the Ministry for Climate https://www.rijksoverheid.nl/actueel/nieuws/2021/08/02/mkb-ondernemers-krijgen-steun-bij-verduurzaming But this is not yet useful for monument owners. – And policy on sustainability and compensating energy costs: https://www.cultureelerfgoed.nl/onderwerpen/duurzaamheid/maatregelen-om-te-verduurzamen/installaties/elektriciteit-opwekken

If there are countries where monument owners are compensated for energy costs, we would like to know that for sure. Maybe we will change our policy in this matter too. Keep us posted, please. 

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A European Heritage Summit was first organized in London on 26–28 April 2006 by Dr. Simon Thurley, former Chief Executive Officer of English Heritage. The mission of the Summit was to gather for the first time the European cultural heritage leaders who had the opportunity to exchange their experience and initiate common actions. It was attended by 23 European states which agreed in the Final Statement to continue to meet annually as a forum of European heritage heads, known as the “European Heritage Heads Forum”. Future hosting countries are chosen by general agreement at the annual meeting.

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