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


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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