Communities and Local Government CommitteeWritten evidence from the Renewable Energy Association

The Renewable Energy Association (REA) represents a wide variety of organisations, including generators, project developers, fuel and power suppliers, investors, equipment producers and service providers. Members range in size from major multinationals to sole traders. There are over 650 corporate members of the REA, making it the largest renewable energy trade association in the UK. The REA’s main objective is to secure the best legislative and regulatory framework for expanding renewable energy production in the UK. The Association undertakes policy development and provides input to government departments, agencies, regulators and NGOs.

1. Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

The REA welcomes the draft NPPF’s clear statements of support for sustainable development. However we fear that the lack of detailed guidance on how to translate this aspiration practically into development plans and planning decisions could result in uncertainty and ultimately delay, rather than accelerate, the deployment of many renewable energy projects.

2. Is the definition of “sustainable development” contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

We regret the fact that the draft NPPF fails to make use of the excellent work performed by the Sustainable Development Commission and others over recent years producing carefully considered definitions of “sustainable development”. The draft NPPF’s definition is quite general and unlikely to provide authorities with the clear guidance they require when drafting development plans and making planning decisions.

3. Are the “core planning principles” clearly and appropriately expressed?

The REA welcomes the NPPF’s mention that development plan policies should “encourage, rather than restrict, the ... development of renewable energy”. However we believe that energy is such an important element of the economy that it deserves its own clear bullet point. In particular the UK’s legally binding target to reduce greenhouse gas emissions 80% by 2050 (and 50% by 2027) should underpin the whole of the NPPF and therefore be a key “core planning principle”.

4. Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?

The information released to date by DCLG is not explicit concerning the fate of guidance contained in the Planning Policy Statements, but our assumption is that the NPPF is intended to supersede it. We are concerned about the loss of some of the very helpful guidance for renewable energy contained in PPS 1 (Delivering Sustainable Development) and PPS 22 (Renewable Energy). We are also concerned that the change of emphasis from criteria based policies in PPS 22 to opportunity mapping in the NPPF will prove a retrograde step for renewable energy, based on the fact that opportunity mapping has very limited relevance for most renewable energy technologies. In addition it is highly unlikely that planning departments will be able to devote the resources, nor will they have the internal expertise, to undertake a meaningful opportunity mapping assessment. We would like to see a much more explicit link between the NPPF and the National Planning Statements for energy and a clear statement that the NPSs will be a material consideration for the smaller scale projects dealt with by local authorities (which provide the majority of renewable energy deployment).

5. Does the NPPF, together with the “duty to cooperate”, provide a sufficient basis for larger-than-local strategic planning?

The REA is concerned that deployment of renewable energy requires a more strategic and larger scale approach than can be provided by many planning authorities. We therefore regret the disappearance of Regional Spatial Strategies and we are not convinced that the “duty to cooperate” will provide a sufficient impetus to produce the required level of cooperation between neighbouring authorities, especially as many of these will be short of staff qualified to undertake this task.

6. Are the policies contained in the NPPF sufficiently evidence-based?

It is unclear to what extent the policies in the draft NPPF are evidence based. The REA welcomes some clear statements of support for the deployment of renewable energy but would like to see these as part of a much stronger, better defined sustainable development agenda. Given the UK’s legal target to achieve 80% greenhouse gas emission reductions by 2050, we would expect this to underpin the entire development plan process on the basis of clear evidence. Unless this target is enshrined in the heart of the nation’s planning processes, it is difficult to see how it will be achieved—the publication of the NPPF provides a unique opportunity to do so. The deployment of renewable energy will play a key role in meeting the target and must be an integral part of this process. However renewables face an even more challenging shorter-term legal target to contribute 15% of the UK’s energy consumption in 2020 (from our current 3%), requiring an urgent and concerted approach by all concerned.

September 2011

Prepared 20th December 2011