Select Committee on Environmental Audit Minutes of Evidence


Letter of submission from RPA, following the Review of Planning Policy Guidance Note 22

  I enclose the RPA's response to the invitation to send in a written submission following the PPG22 workshop held last month.

  I hope you find it useful. If the RPA can be of any further assistance, please do not hesitate to contact me.

  David Byers

  Chief Executive, Renewable Power Association.


  Representations to the Department of Transport, Local Government and the Regions on the review of Planning Policy Guidance Note 22: Renewable Energy.


  The Renewable Power Association (RPA) is a newly established trade association representing producers of renewable energy. Its membership includes renewable electricity generators, fuel suppliers and providers of heat, along with their equipment and service providers.

  The RPA has member companies involved in wind energy, solar, biogas, energy-from-waste, landfill gas, biomass, wave, tidal, marine current and sewage gas industries, together with respected names from the legal, accounting and energy trading communities.

  The RPA works on the large number of generic issues that affect renewable energy producers, irrespective of the technology involved. These include the New Electricity Trading Arrangements, the Renewables Obligation, renewables integration issues, embedded generation, NFFO/SRO contract issues, emissions savings, planning, the Climate Change Levy, etc.

   1.  The RPA participated at the invitation of DTLR in a seminar concerning the review of PPG 22 on 16 January 2002.

   2.  At the conclusion of the seminar participants, who represented industry, government agencies and departments, research organisations, local government and non governmental organisations were invited to submit written representations to DTLR on their views about review of PPG 22.

   3.  The RPA, although a new organisation founded in 2001, has through its member companies considerable experience of the development of renewable energy in the UK. Like all other organisations in the field it sees the current 10 per cent renewable generation by 2010 target as extremely challenging. The rate of deployment will need to increase over seven fold compared to rates seen since 1990. Delivery of the current level of capacity has been slow, disjointed and for the most part difficult. 2010 is not far away in project development timescales and it is important that PPG22 is revised as rapidly as possible, to give a positive tool for the development of renewables. The Scottish equivalent of PPG22, the NPPG6, has been effective and the RPA would encourage DTLR to produce a similarly positive document.

General Comments

  4.  The main influences in the deployment of RE so far in the UK have been the, mainly financial, support mechanisms and the planning system. Progress to date in deployment may be summarised as there being considerable and real support for RE at a national level but that individual projects have had considerable difficulty in gaining planning permission at the local level. Indeed the policy drivers for national support have strengthened considerably as a result of stronger European legislation (the EU Renewables Directive); international efforts to curb climate change and pressures from the Royal Commission on Environmental Pollution and recently the Cabinet Office PIU Energy Review.

  5.  The national drivers for RE include the legally binding contribution the UK has to achieve in meeting its Kyoto and EU RE Directive obligations and for delivering annual RE targets to electricity supply from 2003. The latter is one of the most important measures that will be necessary to meet the international targets. As such the revised PPG must be focused to deliver these requirements.

  6.  Planning has been seen as an obstacle to deployment of RE, rather than as a positive force for encouraging deployment. This belies the true purpose of the planning system—"to regulate the use of land in the public interest"—as such regulation has effectively held up deployment of RE developments, denying the public interest which is to see a much higher level of deployment than that which has to date been achieved. This problem is acknowledged in the DTLR Planning Green Paper and requires urgent attention.

  7.  Furthermore the current system in practice is adversarial and must be changed to reflect the benefits that renewables bring at local, national and international levels. Several decisions have stated or implied a global benefit can only be achieved by a local negative impact but in the majority of cases this is not the case. A partnership approach advocated in the Green Paper is essential to deliver RE projects at the build rate required and the PPG should say this. The existing system, which has led often to public inquiries, is unsatisfactory as it unnecessarily polarises viewpoints, is expensive, time consuming and the only winner is the legal profession.

  8.  That this state of affairs has come about reflects an inability in the planning system to react proactively to the considerable demands placed upon it in by the RE industry. It also reflects some specific problems with the NFFO system—it was made site specific but with limited consideration of whether the sites proposed were capable of gaining planning permission.

  9.  The result has been a level of failure of planning applications for RE projects which is high when compared to other development sectors (eg retail, housing). In response Government and the industry have resorted to solutions such as off shore wind power which largely bypasses the planning system. The RPA's view is that such measures are indicative of an underlying problem which, until it is addressed properly, will continue to dog the successful achievement of the RE targets.

  10.  The RPA believes that review of PPG22 is absolutely necessary to create a better planning framework for the delivery of RE projects over the coming years. However, this alone is not sufficient to address the very real problems faced by industry and local planning authorities in considering RE projects. The Government has recently issued its Green Paper on review of the planning system, entitled "A Fundamental Change". Reforms to many other areas of planning policy, interrelated to RE development through the system of PPGs is necessary to create the conditions for the large scale deployment of RE which the Government, the RE industry, the environmental movement and others wish to see.

  11.  That PPG22 has, in its current form, faults is understood widely. It is perhaps longer than it needs to be, recites general planning procedures unnecessarily, is insufficiently well cross referenced to other PPGs and to Circulars, and contains information about RE technologies which is out of date and in some cases inaccurate. This is not the fault of the PPG but is indicative of general faults in the system of Planning Policy Guidance which is perhaps unwieldy, overly long, and insufficiently reactive to changes in development industry.

  12.  The RPA believes that the RE industry has to be dealt with differently to other types of development which the Government wishes to support. The main difference between RE and, say housing, is that the renewables industry lacks the financial resources required to support long standing and detailed involvement in the planning process. In comparison, the house building industry actually supports regional planning studies through its trade body, the House Builders Federation. As a result every local plan or UDP is subject to representations by the house building industry relating to sites and housing targets.

  13.  Without significant changes in the system for support and control of renewable energy in the planning system, the RPA fears that planning will continue to act as a barrier to RE deployment. Aside from the damage to the RE industry and the government's targets on renewable energy, this will undermine the reputation of the planning system as a force for delivering the government's sustainable development agenda.

  14.  Thought needs to be given to the mechanisms by which the regional targets for RE, which have recently been identified through the Regional Renewable Energy Studies, can be delivered. The idea of translating these regional targets through to district targets in the same way as is done with housing figures is probably unrealistic. A high degree of flexibility is needed to allow for the differences between technologies and the scope for technological innovation.

  15.  In consideration of Regional targets, consideration should be given to how these should relate to other regional objectives such as landscape protection or agricultural diversification. The RPA believes that there should be some parity between the Regional objectives of protecting landscapes and other environments and of providing for the generation of renewable energy. Particularly where landscape or other policies of local importance are protected, PPG22 should give guidance on how the regional objective of delivering RE should be reconciled with this.


  16.  Members of the RPA believe that PPG22 in its current guise is;

    —  out of date;

    —  too long; and

    —  provides little real guidance.

  17.  Therefore a fundamental reform of PPG22 is required. This would appear generally within the spirit of the Government's Green Paper on reforming the planning system. The new PPG22 should be:

    —  shorter and more precise;

    —  written on the basis of current and predicted future technology but not over-descriptive about     technology;

    —  provide guidance both to Local Planning Authorities and developers about best way to     promote renewable energy through the planning system;

    —  capable of being updated annually or bi-annually without the need for fundamental review.

  18.  The purpose of the PPG is as much to assist local planning authorities as it is to assist the industry—so to a certain extent it should contain basic information on RE.

  19.  Experience from planning inquiries shows how little use PPG22 has been either to LPAs or developers in resolving planning issues associated with RE projects.

  20.  In reviewing PPG22, DTLR should see it in the context of national energy policy, specifically the physical developments needed to deliver energy policy. Commonality of approach between procedures and policy guidance for developments promoted through Planning, Electricity, Transport and Works and Private Acts would help. E.g. Offshore wind is seen currently as a "great white hope", largely because of the belief that it can be promoted under T + W Acts procedures. But;

    (i)  LPAs retain a significant role as consultees on T + W Act type procedures;

    (ii)  Projects usually require development on coast, which require planning permission.

  21.  National energy policy has been stated and is clear on the requirement for a major scale-up of renewables. This must not continue to be a matter of debate by decision makers in the planning arena. There should be better weighting of the environmental benefits of renewable energy in planning decisions in comparison with the alternative ie generation from fossil fuel or nuclear sources. The fact that larger power plants are considered by the Secretary of State with the Local Planning Authority merely a statutory consultee has tended to make things more difficult for renewable projects by comparison.

  22.  The emphasis of current PPG22 tends to be on electricity generation and grid connected projects. Whilst these will remain important, Kyoto objectives may also be achieved by small-scale non-grid connected projects and by CHP and heat only projects. PPG22 should address smaller scale as well as larger scale issues.

  23.  Members of the RPA have many ideas about how to facilitate delivery of RE objectives through planning and development control systems:

    (i)  Requirement for percentage number of new houses on a development to have solar panels or passive solar design. Like requirement for percentage social housing. Possibly to be delivered through "community development tax" approach suggested in reform of planning obligations as part of Planning Green Paper.

    (ii)   Developments above a certain size must have eg a wind turbine on site or pay for one elsewhere in the region. Has been tried in LB Merton.

    (iii)  Commercial developments above a certain size to be permitted only if planning obligation entered into to procure percentage of power used from renewable sources.

    (iv)  Enhance understanding of sustainable energy use in consideration of urban regeneration and new urban forms. E.g. considerable effort and policy on achieving green transportation in regeneration areas but little thought so far to, for example, district heating, which may be powered by biofuels or waste.

    (v)   Proactive policy stance in development plans and related documents. Some authorities (eg Bradford) considerably ahead of others in creating RE friendly policy environment and in making links to other areas of policy.

  24.  Relationship with other PPGs. PPG7 Countryside and PPG20 Coast for example are particularly relevant but connection of RE to these is not clear.

  25.  Specifically regarding PPG 7: Countryside and Rural Economy, role of RE as form of agricultural diversification requires detailed consideration. Also there should be a review of whether some forms of RE development may be appropriate in Green Belts. E.g. wind farms, small-scale hydro, small scale solar.

  26.  Within development plans, RE policies should be clearer and more succinct, PPG22 should encourage this. Tendency for pro RE policies to be outnumbered by policies acting against RE. Desire for parity of status of all environment and sustainability policies.

  27.  Only proactive/ positively worded part of current PPG22 concerns areas of search". These have not ended up being used or being useful—need to consider why. Previous tendency to view RE a bit like minerals but increased realisation that unlike minerals RE does not have precisely defined areas of arising—a different approach needed.

  28.  General failure of development plans to have site-specific policies on RE, unless worded negatively. Need to consider why—margins on RE projects not sufficient for developers to fund long lasting local plan involvement perhaps. Alternative approach needed.

  29.  Energy Local Plans—previously discussed sectoral local plans akin to Minerals and Waste Local Plans. Increased move towards this type of planning if District wide Local Plans and UDPs to be replaced by Local Development Frameworks.

  30.  In other utility industry development sectors there has been advice in the form of planning circulars about the appropriate ways for developers and planning authorities to react to development projects. For example, DoE Circular 17/91 on Water Industry Investment advised LPAs to accept that wastewater treatment infrastructure would necessarily be located close to outfalls. No such advice currently exists for RE development although certain parallels can be seem—hydro power can only occur at rivers, wave power at the coast and wind power in exposed locations. In revising PPG22, the RPA therefore believes that DTLR should consider providing similar input either in guidance or as a separate circular.

  31.  The RPA would also welcome a review of the General Permitted Development Order to include minor forms of RE development. It accepts that this is not directly an issue for the revision of PPG22 but considers it to be relevant.

  32.  Finally—current PPG22 has not been a complete disaster. For example the general quality of development plans is considerably better now than five years ago in terms of their coverage of RE. Also deployment of RE has had limited success and general awareness of RE within planning profession is better. So we are building on success, perhaps changing up a gear rather than kick starting a recalcitrant motor.

February 2002

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