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

Written evidence from Ecotricity (ARSS 77)


Targets set for renewable energy development are an important tool in ensuring the delivery of generating capacity. The removal of these targets from the development plan will weaken the ability of the industry to deliver this capacity.

We do not believe that the fiscal proposals suggested by the Coalition will persuade to accept new development in their environment. In any event the significant elements of the fiscal measures proposed appear to be rebranding of measures that were already in place under the previous administration.

We do not think that the measures proposed by the Coalition are adequate to address the policy vacuum that has been created. Without further detail it is difficult to distinguish how the concepts being considered will fill this vacuum. There remains a requirement for a policy framework above the local level which has not been described.

The disbanding of the Leader Boards will ultimately lead to local authorities having to collect and manage their own data at their own expense.


1.    This submission provides evidence to the Communities and Local Coalition Committee Inquiry into the abolition of Regional Spatial Strategies. It is provided on behalf of Ecotricity. Ecotricity is a Stroud based renewable energy company which has 51 wind turbines generating 193MW electricity. We have a growing portfolio of sites in construction, consented and in the planning system.

2.    To inform the Inquiry, the Committee has posed the development industry a number of questions which, whilst weighted towards the housing sector have similar application across all sectors.


The implications of the abolition of regional renewable energy targets for levels of renewable energy development

3.    In response to the decision of the Secretary of State for Communities and Local Government to revoke and ultimately abolish Regional Spatial Strategies most reaction has focussed on the implications for the housing market and the delivery of housing required to meet local demand. However, the Strategies contained targets for a wide range of development types and this submission concentrates on the implications for the delivery of renewable energy in the form of onshore wind.

4.    The requirement to prepare RSS's came out of the Planning and Compulsory Purchase Act 2004 and when adopted they became a formal part of the Development Plan. Section 36(6) of the Act requires that determinations on planning applications must be made in accordance with the development plan unless material considerations indicate otherwise.

5.    As the RSS formed part of the Development Plan this created a strong and statutory relationship between national targets and local authority decision making. The removal of the RSS's removes that relationship between national targets and local decision making. In our opinion the result will be a reduction in the weight that local decision makers will give to the delivery of national targets. The outcome will be that decisions will focus entirely on local impacts and these will no longer be balanced against national targets.

6.    Prior to the revocation of the Regional Spatial Strategies the situation was that Government set national targets which were translated at regional level by the Regional Assembly. Local planning authorities then determined individual planning applications against criteria based policies where these had been adopted to deliver projects towards regional targets.

7.    This approach acknowledges that, because of a range of constraints, no single region could deliver all of the renewable energy required to meet the established targets and the regional approach allowed for a disaggregation of supply across England. The targets were based on a robust assessment of the capacity of each region to deliver renewable generation capacity with input to this process from the renewable energy industry and local communities.

8.    In recent years an important element of environmental and energy policy-making has been the establishment of targets for the achievement of given outcomes by a specified date. Targets do not, of course, determine which means might be used to deliver them, but they do give a clear indication of ends. In this context the end is the achievement of a global objective through the delivery of projects at a local level. In this respect the achievement of renewable energy targets cannot be compared to the delivery of residential or employment land allocation.

9.    Given the global imperative to reduce emissions and as a consequence climate change the case for continuing to set targets is strong. They provide an obvious means of focusing both policy makers' and market participants' attention on areas where new policy measures may be required or existing ones adjusted. For example the Open Source Green Paper identifies that the planning process is an obstacle to the delivery of renewable energy projects and needs to be speeded up.

10.  The UK targets for renewable energy generation first appeared in 2000, and were contained in New and Renewable Energy.[118] This strategy document set a target of 10% of energy from renewable sources by 2010. It also established the strong relationship between a positive, strategic approach to planning for renewable energy, including targets for renewable energy provision, from the regional level downwards to facilitate its development while continuing to protect the countryside.

11.  The Government therefore proposed that regional renewable energy assessments should set the framework for a more strategic land use planning approach at regional level, itself providing the framework for local authorities' development plans and decisions on individual energy projects. It is important to note that at no time did Regional Assemblies have the power to determine planning applications.

12.  This commitment to target setting and delivery towards these targets had already been established in Government policy in the form of guidance within Planning Policy Statement 22-Renewable Energy ("PPS22-2004") in respect of regional targets. This states that:

"Targets should be set for achievement by 2010 and by 2020. Progress towards achieving these targets should be monitored by regional planning bodies. Targets should be reviewed on a regular basis…"[119]

13.  In 2007, the EU Heads of State agreed to legally binding targets for the reduction in greenhouse gas emissions and a corresponding increase in the proportion of energy derived from renewable sources. Reducing greenhouse gases and increasing renewable energy according to the targets agreed by the Heads of State and Government will make the EU much less dependent on imports of oil and gas. This reduces the exposure of the EU economy to rising and volatile energy prices, inflation, geopolitical risks and risks related to inadequate supply chains that are not keeping up with global demand growth.

14.  The UK Renewable Energy Strategy 2009[120] establishes a target of renewable energy of 15% by 2020, almost a seven-fold increase in the share of renewables in scarcely more than a decade. This target relates to a legally binding EU obligation entered into by the UK Coalition under the 20-20-20 Directive.

15.  2010 is a significant milestone on the route toward this target. The interim target for renewable energy set for 2010 is 10%. Data prepared by Renewables UK illustrates how there will be a significant shortfall of 45% in the delivery of renewable energy against the interim 2010 targets.

16.  With the removal of the RSS targets and the policy vacuum which this has created, local planning authorities will be at best treading water waiting for the transitional guidance to emerge, and at worst abandoning work prepared to date with a view to re-evaluating housing targets. In either scenario renewable energy proposals will fall foul of this hiatus as local planning authorities will be focussing their energy on other priorities.

17.  PPG3 Housing advises that evidence of current and future levels of need for housing should be based on local and sub-regional evidence of need and demand. In contrast, until the national target of 10% by 2010, or 20% by 2020 are achieved, there is a need for every renewable energy project. In the absence of regional targets and measurement of progress against those targets the difficulty will be in persuading local planning authorities that there remains a need for individual projects presented to them.

18.  In revoking the RSS, the Coalition has made clear the duty of local planning authorities to continue to bring forward plans such as Core Strategies which contain growth for their area. Although local planning authorities now have the freedom to create their own growth targets local planning authorities must base this on robust evidence.

19.  As it stands local authorities will still have to maintain a five year supply of housing land for their district and this is confirmed in the revised PPG3. They will have to establish this without reference to a regional target which will mean undertaking research into local need and demand. If the localism proposals are pursued for all development sectors then the burden on local planning authorities in terms of justifying allocations would multiply accordingly.

20.  We have serious doubts about the ability of local planning authorities to identify the capacity of their particular area to accommodate a particular form of development across the whole range development types in terms of resources and/or expertise.

21.  In his letter of the 29 June 2010 to all local authorities the Secretary of State for Communities and Local Coalition introduces the concept of Local Enterprise Partnerships. These sub-national amalgams will take time to evolve and we are concerned that in the meantime the decision making process will suffer.

22.  Our submission, in response to the specific question, is that the abolition of the RSS's will result in a significant slowing in the delivery of renewable energy capacity.


The likely effectiveness of the Coalition's plan to incentivise local communities to accept new development, and the nature and level of the incentives which will need to be put in place to ensure an adequate level of renewable energy development

23.  It is clear from the Conservatives Green Paper on planning that the revocation of the Regional Spatial Strategies is driven by a belief that householders and local communities resist development proposals because they are brought forward as a result of targets formulated in Whitehall or Regional Assemblies. This is clearly a flawed belief as development proposals attracted opposition long before the introduction of RSS's in 2004.

24.  The Green Paper also suggests that to date, local communities have not had the ability to influence their environment proactively but have just had to react to proposals as they are brought forward by developers. This is also clearly not the case as, since 2000 there has been the facility for towns, villages and parishes to develop plans which would identify where the community would prefer development to be located and what local character should be retained. These plans would then feed into the formulation of Local Development Frameworks. In an urban context these have taken the form of Sustainable Community Strategies. The availability of these tools has not led to communities universally engaging in the process to influence their environment or prevented them opposing development which they find objectionable.

25.  To remedy this situation the Coalition is proposing purely fiscal measures. The Green Paper on planning sets out the Coalition's intention to allow communities that choose to host wind farms to keep the business rates they generate for six years. They also announced an intention to examine how community ownership of wind turbines can be introduced, as on the Continent, and how discounted electricity can be available to communities in the vicinity of wind farms.

26.  In relation to housing, the Coalition incentive proposed to match the council tax raised from each new property by 100%. This, in the submission of the Coalition, would reassure local residents that by allowing new housing the cost of any new services required to support those properties would be adequately funded. This misses the obvious argument which will be adopted by local residents which will be that if we do not have the housing in the first place the existing services would be adequate.

27.  It is understood that the money to finance this incentive will be sourced from the Housing and Planning Delivery Grant. The principles of HPDG were described as being to:

Strengthen the incentive for local authorities to respond to local housing pressures by returning the benefits of growth to communities; and

Incentivise efficient and effective planning procedures

28.  The grant allowed local authorities to employ additional resources within planning departments to improve the through flow of planning applications and the quality of decision making. The Coalition's proposal as outlined in the Green Paper is to reintroduce this grant under a different name.

29.  The ring fencing of business rates from renewable energy development for deployment in local communities seems sensible but in our opinion this will not reverse opposition to development proposals.

30.  In response to the specific question it is our submission that the incentives proposed by the Coalition will not assist in persuading local communities to accept new development.


The arrangements which should 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, &c);

The adequacy of proposals already put forward by the Government, including a proposed duty to co-operate and the suggestion that Local Enterprise Partnerships may fulfil a planning function;

31.  As a development company we have concerns about the way in which the reformation of spatial planning has been handled on a number of counts. Given the content of the Conservatives manifesto, the Green Papers on planning (Open Source) and Local Government (Open Source) it was evident that a fundamental change was being signalled. However, what has surprised the development industry is the absence of transitional arrangements in the short term and paucity of detail of what will replace the existing structures in the longer term.

32.  There are clearly issues which require consideration at a spatial level beyond the boundaries of a single local authority. These issues include housing, transport, the economy and the environment and need to be addressed at a scale higher than local. In 2007, Keith Mitchell, the Conservative chairman of the South East England Regional Assembly, said "The assembly gives elected local councillors the power to make decisions on housing, transport, the economy and the environment that are too big for a single local authority to make. Without the assembly these decisions would be made by quangos or remote civil servants."

33.  In August 2010, the RTPI and 29 other national bodies involved in spatial planning at various levels wrote to the Secretary of State to express concerns about the withdrawal of the RSS's and the absence of any specific framework to replace them. The legal challenge to the withdrawal of the RSS's submitted by CALA homes and endorsed by the HBF suggests that the development industry is not prepared to roll over and let the change happen without a fight.

34.  The RSS's which had been adopted had been the subject of consultation with the development industry and local communities during their evolution. For example the North East Strategy was subject to four rounds of public consultation. They were not therefore conceived in isolation of community input and then foisted upon them.

35.  We understand that the Government has invited submissions from groupings who would like to form Local Enterprise Partnerships and not surprisingly we understand that many of these are from collections which correspond closely to the former regional boundaries. The Secretary of State suggests that these bids are from people "finally freed from the shackles of regionalism". We would suggest that the submissions are more likely to be from people staring into a policy vacuum and reacting out of necessity to fill that vacuum.

36.  We support the concept of a National Planning Statement but do not feel that any objectives or target set out in an NPS can be or will be achieved by local communities acting alone. A further level of planning is needed between the national and the local, which sets priorities for investment and solutions to problems which can only be addressed beyond town or borough boundaries. This sub-national level is required to ensure that investment in major infrastructure best serves both the needs of local communities and the wider area.

37.  An intermediary level is necessary to ensure an integrated approach to the protection and enhancement of the environment and to prevent loss of biodiversity and where any decisions taken locally have a wider than local impact. This level of planning is important to ensure that climate change is addressed at a level where intervention can be most effective. Importantly, this level of planning can assist in making the delivery of infrastructure more cost effective.

38.  The Green Paper suggests that regional spatial guidance has been withdrawn in Germany and Switzerland, but that is clearly not the case as this, tier (the Lander and the Canton) continues to be an important element of the planning process in both countries.

39.  In response to the specific question we would submit that RSS's were delivering a spatial framework for the delivery of infrastructure, development and investment. They had been the subject of consultation with the development industry and local communities and were an important element of the development plan. We agree with the Secretary of State's assertion that people relate to their environment on different levels from street through neighbourhood through to country but that region forms an important part of that relationship. Prior to the introduction of the RSS's the regional identity of for example the North East, North West or Midlands was deep rooted. We feel that any new arrangements should continue to reflect these historic alliances.

40.  In our opinion the proposals put forward by Government are inadequate and without further illumination it is difficult to distinguish how the nebulous concept of the LEP can properly deliver the planning function that was previously provided by the regional plans.

How the data and research collated by the now-abolished Regional Local Authority Leaders' Boards should be made available to local authorities, and what arrangements should be put in place to ensure effective updating of that research and collection of further research on matters crossing local authority boundaries

41.  With the disbanding of the Leaders Boards there is a further vacuum in terms of research and monitoring. The Government will no doubt argue that in the absence of regional targets the monitoring of delivery against targets is less critical. Nevertheless, over time the existing data will become redundant and it will be the responsibility of each authority to carry out the research and monitor across each development type at its own cost.

September 2010

118   DTi New and Renewable Energy: Prospects for the 21st Century. Back

119   CLG Planning Policy Guidance Note 22-Renewable Energy Para 3.  Back

120   DECC The UK Renewable Energy Strategy 2009. Back

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Prepared 31 March 2011