Written evidence from Dr Helen Chadwick
(ARSS 18)
INTRODUCTION
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.
IMPLICATIONS FOR
DELIVERY OF
NEW RENEWABLE
ENERGY DEVELOPMENT
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.
CONCLUSIONS
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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