Written evidence from E.ON (ARSS 49)
SUMMARY
1. The regional spatial strategies performed
a valuable role in helping to realise national energy and climate
change targets at a regional level. The strategies helped ensure
that renewable and low carbon energy were a key part of development
plans at a more local level. The UK has very challenging targets
in the energy sector and we are concerned that, without some form
of regional coordination, these targets will be more difficult
or more costly to deliver.
2. We fully supported the concept of regional
targets to drive national objectives and as such we would like
an alternative structure to be put in place that delivers this
need. The National Planning Framework should replace the role
of regional spatial strategies, providing clear guidance on the
importance of renewable and low carbon energy deployment. We believe
that local authorities would benefit from an approach which takes
a holistic view and provides consistency and cross border integration,
ensuring borders are not a barrier to meeting large scale development
needs.
3. We would also like a framework that encourages
local authorities to facilitate delivery of broader targets. We
support the use of incentive schemes, such as that proposed by
the government which allows the community to retain the business
rates associated with a new development for a certain number of
years, provided such incentives do not limit the economic viability
of the project. Any incentive structure should ensure funds are
directed towards those most affected within the community.
4. It is essential that local people should
be able to have a say, though consultation and community engagement,
at a local level on how to achieve national policy and that it
is important that development decisions aim to deliver a positive
outcome for communities. Plans should be in place to address how
the area will contribute to the transition to a low carbon economy.
A robust evidence base should be used to inform how each plan
will support the delivery of national policy. This could fall
within the remit of the National Planning Framework.
QUESTIONS
Q. What are the implications of the abolition
of regional house building targets for levels of housing development?
5. The recession together with constraints
on lending by banks has had a much more significant impact on
the reduction in levels of housing development, than the abolition
of regional house building targets. However, regional targets
supported the drive to a low carbon economy as it provided house
builders and companies in the business of delivering utility infrastructure
and services with a degree of certainty around what would need
to be built, where and when. In addition, regional spatial strategies
provided the platform on which joined up utility infrastructure
solutions could be developed. It allowed energy companies to partner
with developers (such as house builders) and the community to
deliver sustainable energy infrastructure that may serve multiple
urban developments, in turn making use of sustainable local sources
of energy such as wind, biomass and municipal waste. We are now
concerned that what has been lost through the abolition of regional
house building targets is the ability for infrastructure suppliers
to plan for and deploy joined up "sustainable"infrastructure.
6. We believe that, through new development,
new opportunities are created to rejuvenate the existing infrastructure
that serves the community around a particular development. For
example, meeting the low carbon energy requirements of a large
development of around 3,000 Code level three homes could be most
cost efficiently met through a district heating scheme built over
a number of phases. The deployment of this new energy infrastructure
could potentially be extended to meet the energy needs of the
adjacent built environment across a local boundary. Therefore,
the delivery of new homes, coupled with holistic energy planning
could lead to the lowering of the overall community's carbon footprint.
In the absence of regional spatial planning another approach that
allows for a holistic approach to be undertaken is crucial. The
abolition of housing targets has removed the certainty that investors
had and could result in missed opportunities.
Q. What is the likely effectiveness of the
Government's plan to incentivise local communities to accept new
housing development, and the nature and level of the incentives
which will need to be put in place to ensure an adequate long-term
supply of housing?
7. It is important that communities are
able to have a say in development proposals and local people are
fully consulted upon for major new housing developments. However
local planning authorities must assess developments not just in
terms of local impact but also national need in reaching their
final decision.
Q. Should arrangements be put in place to
ensure appropriate cooperation between local planning authorities
on matters formerly covered by regional spatial strategies (eg
waste, minerals, flooding, the natural environment, renewable
energy)
8. Yes. We believe that there should be
a duty on local planning authorities to co-operate with neighbouring
authorities to identify optimum locations for developments that
meet national policy objectives. The National Planning Framework
could facilitate this.
9. We are also concerned that the abolition
of regional spatial strategies has also meant that significant
work conducted previously by RDAs in establishing regional requirements
for sustainable development may not take place; this needs to
be addressed as part of the National Planning Framework.
10. In order to ensure that local authorities
are able to make a contribution to the UK's energy and climate
change related goals it is important that sustainable energy solutions
are encouraged at the right scale. Therefore, where sustainable
energy infrastructure can be deployed at a scale which supports
the needs of multiple urban developments the planning framework
should incentivise this outcome in the interests of all stakeholders.
September 2010
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