The revised draft National Policy Statements on energy - Energy and Climate Change Contents

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.


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.


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.


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.


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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