Memorandum submitted by RenewableUK
1. RenewableUK is the leading trade association
for wind wave and tidal energy. It represents over 660 corporate
members, and is made up of those companies who will deliver the
bulk of the renewable electricity over the next decade. Planning
has been a continual problem for wind energy in particular with
over 9GW currently stuck in the planning system. For this to be
resolved, the National Policy Statements are key to ensuring delivery.
Whilst RenewableUK welcomes the Government having reissued the
statements, we are concerned that some key areas do not seem to
have been addressed, with some of these detailed here.
2. THE IMPORTANCE
OF NATIONAL
POLICY STATEMENTS
IN DELIVERING
RENEWABLE ENERGY
Over the next decade 22GW of existing generating
capacity will need to be replaced, while at the same time the
UK Government has adopted ambitious renewable energy and carbon
emission reduction targets. To meet these challenges requires
a necessary and sustained multi-billion pound investment programme
to deliver a range of renewable energy technologies across all
areas of the UK, both on- and offshore. The principles of the
Planning Act 2008 and the development of National Policy Statements
on nationally significant infrastructure projects recognize this
need for renewable energy and the urgency of delivery. RenewableUK
welcomes and has long supported the principles contained within
the Planning Act 2008 and the introduction of NPSs.
3. THE BALANCE
OF THE
NEED CASE
The need for renewable energy generation is clear
and delivery against UK and EU targets is legally binding. While
the need case for renewable energy within NPS EN-1 is strong,
we are concerned that the strength of this need does not properly
reflect the high level of capacity (around 30GW) expected to come
forward from wind energy development between now and 2020. While
it is not the role of the NPSs to pick or compare technologies,
the industry is concerned that there is parity between zero carbon
and renewable energy technologies. For instance, section 3.3.4
of the NPS states that: "nuclear power will help reduce the
UK's dependence of fossil fuels" but does not do so for renewables
with other examples through the needs case.
4. RELATIONSHIP
WITH EXISTING
PLANNING REGIME
It is essential that the objectives of the Act are
not compromised by the planning reforms currently proposed by
the Government. Without clear direction within NPSs as to the
weight to be accorded to them at the local level, there is a real
risk that route and branch reform of the Town and Country Planning
system in England could significantly delay the determination
and deployment of smaller scale—though nonetheless essential—renewable
energy infrastructure below 50MW. This direction would provide
much needed assistance to local authorities in the preparation
of their new local and neighbourhood plans.
The relationship between the Major Infrastructure
Planning Unit and the Marine Management Organisation will be important
in ensuring that the need for marine renewable energy infrastructure
is properly balanced against other concerns.
5. POINTS OF
DETAIL
Throughout the draft NPSs and the renewable energy
NPS in particular, there remain a number of points of detail that
need to be addressed and have not been changed from the original
draft. These points, as detailed in our February 2010 response,
contain detailed policy guidance that has the potential to unravel
the development process, if poorly worded, poorly understood,
or incorrect. We therefore ask that these points of detail be
revisited, taking into account the industry's concerns as previously
identified. For instance, in EN3 there are a number of references
to burying cables to a sufficient depth (greater than 1.5m below
the sea bed) which is extremely prescriptive and would be extremely
difficult and costly to achieve on hard substrate. Restrictions
like this could hinder the development of offshore wind.
December 2010
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