Planning applications
206. Throughout our inquiry, the renewables industry
expressed its support for the Planning Bill.[210]
A common concern, however, was that the IPC would only decide
on onshore developments with a capacity of 50 MW or greater and
offshore projects with a capacity of 100 MW or more.[211]
207. In the onshore sector, 30-40 per cent of renewable
projects currently submitted for planning determination are thought
to fall below the 50 MW threshold required for IPC consideration.[212]
Further, sites with the potential to support a 50 MW wind farm
are relatively rare in England and Wales, and many of these will
have been developed before the IPC comes into operation. It is
therefore likely that a significant proportion of future renewable
proposals, in particular onshore wind developments, will not be
eligible for consent under the IPC.
208. The 100 MW threshold for IPC consideration of
renewable installations in the offshore sector is also a point
of concern. Wave and tidal devices are very much in the early
development and demonstration phase of their life-cycle, and device
developers are looking to deploy small-scale pilot projects.[213]
These projects will not only fall below the 100 MW threshold,
but are likely to be less than 50 MW in capacity. Given these
circumstances, the Renewable Energy Association has called for
the offshore limit to be brought in line with that for the onshore
sector (50 MW), and for consideration to be given to a further
lowering of this limit.[214]
209. We are concerned that measures introduced
in the Planning Bill will not materially affect the speed at which
consenting decisions for smaller projects are reached. We urge
the Department for Communities and Local Government to reconsider
whether the thresholds for IPC consideration of onshore and offshore
developments are appropriate.
Planning Policy Statement 22 (PPS22)
210. In considering energy infrastructure projects
under 50MW, local authorities are required to consult guidance
laid out in Planning Policy Statement 22 (PPS22). An underlying
principle of PPS22 is that:
Regional spatial strategies and local development
documents should contain policies designed to promote and encourage,
rather than restrict, the development of renewable energy resources.
Regional planning bodies and local planning authorities should
recognise the full range of renewable energy sources, their differing
characteristics, locational requirements and the potential for
exploiting them subject to appropriate environmental safeguards.[215]
211. In their submission, the BWEA stated that 'renewable
projects are often rejected for reasons that contravene PPS22'.[216]
When we asked Kevin McCullough, RWE Innogy, to give us an industry
perspective on the utility of PPS22 and its application by local
authorities, he replied:
PPS22 as an instrument and a policy guidance
document is very sound […] but the weak point in the system
is, in my view, in the education and understanding and the […]
equality of application across the many, many authorities that
have these planning applications to deal with, because at the
moment there is a very definite emerging inequality in how one
scheme is treated in one authority to the other.[217]
Mr McCullough went on express the view that, if inconsistencies
in the application of PPS22 were not rectified, developers would
begin to selectively develop sites in areas where "they think
their chance with planning is greater".[218]
212. The equitable application of PPS22 by local
authorities is crucial to maintaining investor confidence. We
asked Simon Virley, BERR, what guidance the Government will give
local authorities on the implementation of new renewables planning
policy. He responded:
I think the National Policy Statements […]
will be very important here in terms of setting the framework
for local authorities, and then they will be translated into local
and regional strategies, so that clear guidance will be coming
in the form of the National Policy Statements.[219]
This response fails to recognise that it is not the
efficacy of current planning guidance on renewable installations
that is in question, but the equity of its application.
213. We are concerned that a local authority's
reputation in the application of PPS22 may become the deciding
factor in an investor's choice of site location, rather than the
specifics of the site itself. We recommend that 'best practice'
in the application of PPS22 be developed and disseminated as a
priority.
Environmental considerations
214. During the planning process, consideration must
be given to the environmental impact of the development in question.
No energy source is completely harmless to the environment and
for each technology, there is a trade-off between the wider benefits
(e.g. energy security and lower carbon emissions), and their social
and local environmental impacts (potential impacts on populations
of seabirds and aquatic mammals, for example).[220]
Environmental Impact Assessments
215. Environmental Impact Assessment (EIA) is a procedure
that must be followed for certain types of development, such as
the deployment of renewable electricity-generation devices, before
they are granted development consent. Mandated by a European Directive
(85/33/EEC as amended by 97/11/EC), EIA requires developers to
compile an Environmental Statement describing the likely significant
effects of the development on the environment and proposed mitigation
measures. The Statement is circulated to statutory consultation
bodies and made available to the public for comment. Its contents,
together with any comments, must be taken into account by the
competent authority (e.g. local planning authority) before it
may grant consent.
216. The costs associated with the EIA can represent
a significant financial burden to companies attempting to develop
pioneering marine renewables projects. The BWEA told us that:
These are small developments, using technologies
that are new. The latter feature leads to demands for comprehensive
surveying and monitoring to assess what is and is not an issue,
which makes them particularly burdensome on pilot projects of
one or a handful of devices. A proportional approach by statutory
conservation consultees would be welcome to reduce this burden
to the absolute minimum required, and extra help from Government
in carrying out such surveys and monitoring required would also
be very helpful.[221]
The high cost of the EIA for offshore developments
is highlighted by the budget allocation of Marine Current Turbine's
Seagen project. The total budget for this tidal turbine development
was £8million of which £2million was for the EIA.[222]
217. We note that the forthcoming NPS on energy is
expected to contain a list of criteria for offshore wind sites,
and a list of sites that meet those criteria. The Minister assured
us that the EIAs for these sites would be conducted by BERR rather
than being left to developers.[223]
In order to further support the offshore marine industry, and
to prevent the cost of the EIA from deterring developers from
investing in marine renewables projects, the Renewable Energy
Association suggested that the Government also provide developers
with baseline EIAs for potential locations of high wave and tidal
stream energy.[224]
218. We recommend that the Government provide
baseline Environmental Impact Assessments for areas suitable for
all offshore renewables projects, and that it liaise with industry
to ensure these assessments are appropriate to their needs.
204 Ev 71, 105, 121, 129, 133, 139, 157, 168, 175,
180, 242, 244, 257, 279, 300, 322; Qq 11, 80, 88, 209, 210, 212 Back
205
Q 248, Sustainable Development Commission, Lost in transmission:
the role of Ofgem in a changing climate (2007), p66 Back
206
Ev 257 Back
207
HM Treasury, Meeting the Energy Challenge, Cm 7214, May
2007, p 256 Back
208
Defra, Draft Marine Bill, Cm 7351, April 2008, p 38 Back
209
Uncorrected transcript of oral evidence taken before the Business
Enterprise and Regulatory Reform Committee on 31 January 2008,
HC (2007-08) 293-i,Q 129 Back
210
Ev 108, 175, 257; Q 211-213 Back
211
Ev 257; Q 214 Back
212
Ev 335, 373; Q 211 Back
213
Q 210 Back
214
Ev 384 Back
215
Office of Deputy Prime Minister, Planning Policy Statement
22: renewable energy, 2004, p 7 Back
216
Ev 258 Back
217
Q 216 Back
218
Q 211 Back
219
Q 452 Back
220
Ev 120, 187, & Boyle, G. (Ed), Renewable energy, (Oxford
University Press, 2004) Back
221
Ev 369 Back
222
Ev 151 Back
223
Qq 425-426 Back
224
Ev 288 Back
