Abolition of Regional Spatial Strategies: a planning vacuum? - Communities and Local Government Committee Contents

Written evidence from Dr Helen Chadwick (ARSS 18)


In addition to any implications for housing delivery the abolition of regional spatial strategies will have profound implications for the delivery of targets on renewable energy and climate change. There are a number of significant factors, many linked with housing delivery.

There is a huge drive for increasing renewable energy delivery:

Renewable energy targets have been hugely ramped up following the recent EU directive on renewables.

Up to 35% of electricity generation from will need to come from renewable electricity technologies, with onshore wind a sizable part of this total.

Currently about 6.6% is delivered.

The policy framework is confused and the abolition of RSS adds to the confusion:

Currently national policy is guided by PPS1 and PPS22 both these documents are under review.

There is new draft National Guidance for the now defunct IPC.

PPS22 calls for Regional targets as part of RSS.

PPS1 calls for local studies to identify carbon savings as part of the development process.

A change in emphasis toward localism will impact dramatically on planning decision making.

Local policy is patchy, with many LDFs have little or no policy relating to renewable energy.

In general, RSS provides the only coherent policy on renewable energy. Policies are evidenced based and have gone through considerable public consultation to reach a consensus.


Renewable energy developments are often difficult and contentious projects. They often need to be sited in the countryside. This often leads to a certain level of antagonism. Most often the decision on acceptance or rejection of any project relies on the careful balancing of the impacts locally against the national need. A commonly aired statement by local group is that they support renewable energy,but do not feel that a local site is the most appropriate.

Any planning decision relies on fairly subjective value judgements, but a solid policy basis nationally and locally can allow much of the decision making to be clearly related to the site. There are no ideal sites for renewable projects, all of them will have significant impacts locally, particularly in relation to visual impact. But technologies can be accommodated in a wide variety of locations and landscapes, if well designed

National policy clearly is supportive of renewable energy and the new EU Renewables directive calls for an enormous increase in the amount of energy from renewables, with a target of 15% of all UK energy coming from renewable sources by 2020. This is an enormous challenge and could require an increase of renewably generated grid connected electricity from around 6% to 34%. No one technology can deliver on this scale and on-shore wind energy, one of the most contentious technologies, will form an important part of the delivery against this targets.

Prior to the general election all of the main national planning policy documents dealling with renewables came under review. PPS22 and Climate change Supplement of PPS1 were due to be amalgamated and a consultation was commenced. New national guidance as part of the new IPC was also put out for consultation. The IPC has now been stood down and the new draft national guidance has no weight. There has not yet been any clarification of the positions re PPS 22 and PPS1.

Local policy in many area is still in formation. Many areas are still operating saved policies from local plans, some of which are over 10 years old. Many local plan policies pre-date any significant interest in renewable installations, which has increased significantly since 2005. Where LDF core strategies have been formulated and adopted, they have been informed by evidence required for PPS1, in relation to carbon-dioxide emissions. On the whole these have been used to inform the policies relating to on building and settlement scale renewable energy, rather than larger grid-connected stand alone installations. Many Local Planning Authorities struggle to meet the staff resource requirement to fully implement such complex study areas.

PPS22 relies heavily on the delivery of sub-national policy via regional renewable targets and policy through RSS. The requirements of PPS1 for evidence for LDFs is not sufficient to meet the requirements for PPS22. This mismatch was the reason behind the review of those documents. Carbon emissions and renewable energy are closely linked with new development and the renewal of urban areas. There is a need for a coherent approach, otherwise expensive and inappropriate low carbon solutions may be chosen. These could damage the emerging markets. As we move into a new low carbon future spatial planning policy has to try to flexible enough to allow a number of different approaches to low carbon development, whilst maintaining and protecting valued and invaluable ameities across our countryside and communities. This will be an immensely challenging process, made more difficult by the lack of clear knowledge of which low carbon technologies will be the leaders in tomorrow's low carbon society.

Regional studies have provided information on resource and accessible capacity as part of the evidence base for RSS targets. Those targets have also gone through specific consultations and been scrutinised in EiP across England. So, whist any process or target can be flawed the RSS policies indicate some level of consensus across an area. Certainly in the East Midlands, it is clear that regional evidence, targets and policy have formed the backbone against which certain appeals have been played out. Clear regional policy has allowed the Planning Inspector to move rapidly to the specific site based material considerations when making decisions.

The new localism agenda brings a different aspect to the decision making process. On- shore wind is very contentious. Some local people would often prefer not to have any on-shore wind in their area. It is not yet clear whether this local view should be given more weight in decision making proceedings. If so, then renewable applications could be seriously affected.


The abolition of RSS has seriously affected the policy clarity around delivery of renewable energy installations. The shortcomings in local and national policy are likely to leave developers and LPAs in some confusion around decision making. The lack of regional policy or targets is likely to take some time to resolve into coherent national or local policy.

Renewable developments are likely to slow as a result. This will have serious implications for our ability to meet the 2020 targets.

Well evidenced, clear and flexible policies are essential to ensure good spatial outcomes in this rapidly evolving policy areas. The lack of such a framework nationally or locally is a major concern.

In some areas RSS is the only policy for delivery of local renewables and it would be helpful if RSS evidence and targets could be upheld in a way that local planning authorities can access as local and national policy is improved. In addition many smaller districts need support to deliver their own evidence base and fully engage stakeholders, particularly English Heritage and English Nature. It is also clear that there is a need for a more coherent approach to local constraints that will clarify and support local delivery of renewable energy.

September 2010

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Prepared 31 March 2011