Written evidence from SSE (ARSS 25)
SSE (Scottish and Southern Energy) is grateful to
have this opportunity to submit evidence to the Committee's inquiry
into the abolition of regional spatial strategies, and in particular
the potential impact of this on achieving the renewable energy
targets that have been set out in UK planning policy. As the UK's
largest generator of renewable electricity, SSE is keen to ensure
that reforms to the planning system do not become an impediment
to the Government's ambitions of tackling climate change and ensuring
secure energy supplies.
KEY POINTS
The submission focuses specifically on the potential
impact of the abolition of regional spatial strategies on generating
renewable energy. The key points include:
1. A need for local spatial plans (drawn up in
conformity with national policy) to recognise the importance and
urgency for bringing forward renewable energy projects in order
to tackle climate change and secure energy supplies.
2. Continued support for incentivising local
communities to accept appropriate forms of renewable energy including
business rates to be retained by Local Authorities for onshore
wind projects.
3. SSE and indeed the vast majority of other
developers already provide generous and effective community funds,
so there appears to be little need for mandatory requirements.
4. SSE awaits the opportunity to comment on intended
arrangements to be put in place to ensure appropriate cooperation
between local planning authorities on matters formerly covered
by regional spatial strategies—cooperation will need to
take into account the need for encouraging renewable energy.
5. A need for clarity over the potential role
of Local Enterprise Partnerships in planning process.
A need for local spatial plans (drawn up in conformity
with national policy) to recognise the importance and urgency
for bringing forward renewable energy projects in order to tackle
climate change and secure energy supplies
It is recognised that one of the key policies of
Regional Strategies was to "tackle challenges posed by climate
change".[13]
Despite the revocation of the Regional Strategies, it is essential
that this key aim continues to play a prominent role in the formation
and implementation of local spatial plans (that are to be drawn
up in conformity with national policy). To support this process,
it is important that National Policy Statements are designated
as soon as is possible with a strong statement on national need.
This takes into account the requirements of the UK Renewable Energy
Strategy and Low Carbon Transition Plan 2009 and also policies
specific to planning and climate change that are contained within
a supplement to PPS1. Local spatial plans should only be considered
to be sound if they adequately address the need for appropriate
renewable energy solutions in their respective areas. There is
an opportunity for a formalised process by which key aspects of
the National Policy Statements are transposed into the local spatial
plans.
Continued support for incentivising local communities
to accept appropriate forms of renewable energy including business
rates to be retained by local authorities for onshore wind projects
The Rt Hon Eric Pickles MP's statement on Revoking
Regional Strategies states that "imposed central targets
will be replaced with powerful incentives so that people see the
benefits of building."[14]
SSE has supported the process of incentivising local communities
to accept appropriate forms of renewable energy and continues
to do so, but it is important that if targets are to be removed,
appropriate forms of incentivising local communities are considered.
In particular, SSE supports business rates to be retained by Local
Authorities.
Our preferred mechanism would be for local authorities
who already collect the liabilities and make the planning decisions
to manage the funds on behalf of the community. This would be
the simplest mechanism and would avoid any bureaucratic and regulatory
issues with the definition of community with local authorities
being best placed to decide appropriate use of the funds. Providing
business rates to local authorities would allow them to see some
of the economic benefits of onshore wind development, ensuring
their incentives are well-aligned in planning activities.
SSE and indeed the vast majority of other developers
already provide generous and effective community funds, so there
appears to be little need for mandatory requirements
SSE believes strongly that community funds should
not be mandatory. Non-statutory guidelines would be much more
constructive alternative to mandatory legislation for ensuring
best practice across the Industry. Community funds should not
be mandated due to:
(1) Needless bureaucracy—Mandatory
funds have a significant bureaucratic issue of regulation. There
would be a requirement for a regulatory body, which would also
have to be decided, monitoring all renewable energy projects from
the start of planning continuing through to its decommissioning
sometime in the future. This additional cost of regulation, would
inevitably be passed onto consumers, and would be unwelcome at
a time when there is already pressure on bills.
(2) Loss of community engagement—Any
attempt to mandate a minimum level of benefit to a community would
no longer be seen as an incentive to communities, as the actions
of the developer would no longer be viewed as a genuine demonstration
of good will. This may have the opposite effect on community support,
with communities potentially seeing the renewable project as a
burden. If best practice guideline were brought in, which SSE
met or exceeded this would be seen as a genuine effort of community
engagement.
(3) Lack of innovation—Renewable
energy developers would lose the incentive to innovate in how
it engages communities in attempts to provide benefits to communities.
Any additional funds would have a negative public perception due
to the compensatory image of the mandatory funds. Indeed, in many
cases developers could chose not to engage beyond the mandatory
level which could, potentially, reduce the overall value to the
community.
SSE awaits the opportunity to comment on intended
arrangements to be put in place to ensure appropriate cooperation
between local planning authorities on matters formerly covered
by regional spatial strategies—cooperation will need to
take into account the need for encouraging renewable energy
The Rt Hon Eric Pickles MP's statement on Revoking
Regional Strategies states that "the abolition of Regional
Strategies will require legislation in the "Localism Bill"
which [the Government will be] introducing this session."[15]
It will be important for this Bill to include measures to ensure
cooperation between local planning authorities on matters relating
to renewable energy and for all local planning authorities address
the need for appropriate renewable energy solutions in their respective
areas. Furthermore, there should be a clear and unambiguous process
for decision-making particular for when proposed renewable energy
projects straddle or are close in proximity to local planning
authority borders.
SSE will await the opportunity to comment on intended
arrangements to be put in place to ensure this cooperation, which
is likely to be included as part of the Localism Bill.
A need for clarity over the potential role of
Local Enterprise Partnerships in planning process
The invitation to submit evidence to the Inquiry
into the abolition of Regional Spatial Strategies refers to a
suggestion being made that Local Enterprise Partnerships (a potential
replacement for the abolished Regional Development Agencies) may
fulfil a planning function. It will be important for this potential
planning function to be clarified and justified in the context
of the current decision-making process before SSE can comment
further.
IN SUMMARY
SSE understands why there has been so much attention
focused on reforming decision-making powers to deliver necessary
infrastructure. While recognising the Government's desire to put
decision-making powers back into the hands of local councils,
it is important to ensure that reforms to the planning system
do not become an impediment to the Government's ambitions of tackling
climate change and ensuring secure energy supplies. SSE therefore
supports a clear and unambiguous planning process, with local
spatial plans giving due consideration to the need for renewable
energy (in conforming with national policy).
September 2010
13 "Policy Statement on Regional Strategies",
Department for Communities and Local Government and Department
for Business, Innovation and Skills (February 2010), Section 2.2. Back
14
"Communities and Local Government-Revoking Regional Strategies"-Statement
by Eric Pickles,
http://www.communities.gov.uk/statements/newsroom/regionalstrategies
(Published 6 July 2010). Back
15
"Communities and Local Government-Revoking Regional Strategies"-Statement
by Eric Pickles,
http://www.communities.gov.uk/statements/newsroom/regionalstrategies
(Published 6 July 2010). Back
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