Memorandum submitted by the Local Government Association (NPS 87)
The LGA Group is made up of six organisations: the Local Government Association (LGA); the Improvement and Development Agency (IDeA); Local Government Employers (LGE); Local Authorities Co-ordinators of Regulatory Services (LACORS); Local Partnerships and the Leadership Centre for Local Government
Our shared ambition is to make an outstanding contribution to the success of local government. Together we work with and on behalf of councils to lobby for changes in policy and legislation, build a strong and positive reputation for local government and support them and their partnerships to continuously improve and be innovative.
We provide services at the national
level which support and are complementary to the regional and local support
provided to councils, as well as the work councils themselves undertake. We
work with authorities across
The 424 authorities who make up the LGA Group
cover every part of
The LGA is supportive of the new planning regime. However local authorities are concerned that the arrangements for resourcing them to undertake their functions at each stage of the new regime are inadequate and we have several suggestions as to how these arrangements could be improved.
· Far more emphasis needs to be placed on Local Development Plans and local land usage.
· There should be guidance on where energy developments might be encouraged or supported.
· The NPSs could give more weight to the cumulative impacts that could result from proposed developments in a single area.
· It is important that community scale renewable generation is promoted.
· The NPS could give more weight to the economic and social impacts which will be important to local people.
1. The Local Government Association is providing oral evidence to the Committee on 3 February 2010.
2. The LGA is supportive of the new planning regime and the need to improve the decision making for nationally significant infrastructure projects. The new arrangements give councils key roles at each stage of the planning process. In particular, the Local Impact Report(s) will be an important source of evidence and insight for the Infrastructure Planning Commission's examination of applications.
3. We recognise the national importance of modernising our energy infrastructure to replace existing power stations as they are de-commissioned and to introduce low carbon energy generation.
4. We are however very concerned about the inadequate arrangements for resourcing councils to discharge their responsibilities at each stage of the new planning regime: pre-application, examination and decision, consent and enforcement. This places new burdens on local government for which they need to be resourced by developers.
5. We have a number of key points to make about the ways in which the national policy statements on energy could be improved.
6. The National Policy Statements need to give more weight to Local Development Plans and local land uses.
7. Development plans are statutory documents prepared in accordance with statutory procedures. They are required to address all types of development and infrastructure to ensure that the vision for an area can be fulfilled and desirable development brought successfully to delivery. This requires close collaboration between the local planning authority and developers (including energy infrastructure providers) to ensure that their intentions are properly reflected. This should include addressing the implications of major infrastructure projects for the wider area including matters such as additional housing need and waste management requirements, both strategically through the Regional Spatial Strategy and locally through the Local Development Framework.
8. The development plan is expected (among other things) to set out the amount of development of different types to be provided for, the planned disposition of the various types of land use, and how they are to be connected to roads and other communications. Where a plan has been developed through a proper process of engagement, including with energy infrastructure providers, it will be a key factor in decisions on other types of development proposals, and should also be a significant consideration in relation to nationally significant energy infrastructure projects.
9. It will be important for the Infrastructure Planning Commission in considering a proposal for energy infrastructure, to ask whether the proposal would cause harm to the delivery of other objectives for the area addressed in the development plan. Examples of possible harm might be that the proposal would reduce the amount of land available for other important types of development, or physically prevent or inhibit such development, or change the market situation locally (including the effect of environmental conditions) to the detriment of the commercial viability of other desirable development. Conversely, the proposal might assist the achievement of other objectives for the area, which should work in its favour.
10. There should be guidance on where energy developments might be encouraged or supported - these decisions are left entirely to developers except in the case of the nuclear NPS where the government has decided on specific sites, following consultation. We see a need for a more strategic approach that considers proximity to the transmission network, economic development and integration with other major infrastructure.
11. To illustrate this point, a possible consequence of leaving decisions to developers could be a proliferation of proposals for new energy generating capacity on the coast (in addition to the ten nuclear sites), to take advantage of readily available cooling water and the entry points for fossil fuel. The discussion of the potential nuclear sites demonstrates the potential harm to the landscape and important ecological interests that could be caused by such developments. Moreover, there would be significant cumulative impacts if a number of different installations came forward in the same general area. These could include the need for new transmission lines affecting sensitive landscapes and wider impacts upon nature conservation, tourism, the fishing industry and other matters of considerable public interest. Whilst this example is speculative, it does illustrate one outcome which could arise in the absence of strategic guidance on location in the NPSs.
12. The NPSs could give more weight to the cumulative impacts that could result from proposed developments in a single area. To illustrate this point new generating stations, particularly if they are clustered in a particular location, may need new transmission infrastructure - a new transmission line to connect to the station could be one of the most significant impacts, with local concerns about the route of the grid lines. This ought to be considered at the time of the application for the generating station.
13. Whilst the energy NPSs relate to large scale energy generation, it is equally important that community scale renewable generation is promoted. We welcome the coverage of combined heat and power in the statements. But there are further ways in which renewable generation can be encouraged - for example, through the use of renewable energy sources in other major infrastructure developments, in particular airports and ports.
14. Although the NPS covers environmental impacts, it could give more weight to the economic and social impacts which will be important to local people.
15. Finally, the LGA is meeting with councils impacted by proposed new nuclear build on the 22nd January at which we will discuss the nuclear NPS. We would be happy to send the committee a supplementary note after that meeting or cover our key points on that national policy statement in our oral evidence.