Communities and Local Government CommitteeWritten evidence from RenewableUK

1. Introduction

1.1 RenewableUK supports the principle of a National Planning Policy Framework (NPPF) for England. RenewableUK also welcomes the positive provisions which provide some support for renewable energy included in the draft NPPF, however in our view these need to be strengthened.

1.2 It is important to find the right balance in the NPPF in order to ensure that the provision of clear and necessary direction on national policy priorities and appropriate planning procedures are not lost in the pursuit of a single, streamlined document. The NPPF should provide both policy and procedural direction to local authorities on a range of planning matters, from the development of local plans and policies through to the determination of individual applications. RenewableUK consider the Scottish Planning System to be a good model to follow in successfully achieving this balance between national objectives and local interests and recommend that the experiences of Scotland and Wales be given detailed consideration.

Context: The Role of Renewables

1.3 Energy is a vital planning matter and it is crucial that the UK develop a new, sustainable energy infrastructure in order to reduce carbon emissions from the energy sector; maintain security of energy supplies and minimise cost volatility for the consumer. Given the large number of power stations which will close and require replacement over the next 15 years, it is essential that we take this opportunity to rebuild our energy infrastructure—at a local as well as national scale - using renewable and low carbon technologies wherever possible.

1.4 We believe that the UK’s renewable energy targets will be best met through a diverse mix of development where well designed projects, that are in general conformity with requirements stated in the NPPF, National Policy Statements (NPSs) for Energy, Local Development Frameworks (LDFs) and where appropriate the Marine Policy Statement (MPS) should be accepted. Failure to deliver the renewable energy investment needed could leave the UK exposed to infraction proceedings from the European Commission and therefore all areas of England will need to significantly increase their levels of renewable energy generation.

1.5 RenewableUK wishes to emphasise the important role that renewable energy technologies play in contributing to the sustainable development of communities, in reducing the country’s carbon emissions and in mitigating the impacts of climate change. Renewable electricity is planned to contribute at least 30% of the UK’s final electricity consumption by 2020 to enable the UK to deliver its statutory target of achieving 15% of all energy consumption from renewable energy sources, including heat and transport, by 2020. This will require positive planning and therefore strong support within the NPPF.

1.6 Currently renewable energy is provided for under climate change considerations in the NPPF, however climate change mitigation is just one of the benefits of renewable energy. Renewable energy generation also contributes to economic development; the building of a skills base; manufacturing; and a less fossil fuel dependant society and economy. It is thus fully in line with sustainable development principles. It is a cross-cutting theme to all sections of the NPPF.

2. Summary of Key Areas of Concern:

(a)Vision of the NPPF.

(b)Sustainable development.

(c)Planning for renewables.

(d)Duty to co-operate.

(e)Overarching vision of the natural environment policies.

(f)Local authority resourcing.

(g)Relationship with other policy and additional guidance needed.

3. Responses to the Committee’s Questions

3.1 Question 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?

3.1.1 Despite its pro-development theme, the NPPF does not, in RenewableUK’s view, give sufficient guidance to local authorities and developers. Our main concerns are on the following areas:

(a)Structure of the NPPF.

(b)Planning for Renewable Energy.

(c)Duty to cooperate.

(d)Natural environment policies.

(e)Local authority resourcing.

(f)Relationship of NPPF with Neighbourhood Plans.

(a) Structure of the NPPF

3.1.2 Renewable UK has the following concerns in terms of the current structure of the NPPF:

There is no coherent “story” or direction provided in the NPPF for local authorities and communities in developing their local plans.

There are cross-cutting themes, such as Energy, which have not been given due consideration in the document.

A lack of policy certainty will result in a lack of investor confidence across all development sectors. Renewable energy investment will be diverted outside the U K.

3.1.3 In RenewableUK’s view, it is unclear how the distinction has been made between different sections of the NPPF, such as Planning for People, Planning for Prosperity and Planning for Places. An issue such as Energy is overarching and underlies all three themes. In our view, all subsections within “Planning for Prosperity” are also planning for people and places. Green Belt has been located under “Planning for people” but in our view would it fit much better under “Planning for places” together with the “Natural environment”.

3.1.4 On this basis local authorities and communities would not be able to make a balanced decision as to what policies to include in their local plans, and developers are likely to face great uncertainty in terms of what to expect from planning policy. This could lead to relocating their investments elsewhere.

3.1.5 Should the current structure be maintained in the final version of the NPPF, it is requested that RenewableUK’s suggested provisions for energy and associated infrastructure (including transmission infrastructure) be located under “Planning for prosperity” as well as the climate change section and other relevant sections.

(b) Planning for Renewable Energy

3.1.6 In terms of guidance for investors and developers, some of the provisions in the NPPF, in particular the spatial approach to the development of wind energy, which is introduced within the climate change section, has the potential to deter investment confidence. RenwewableUK has the following concerns on the spatial approach:


A lack of policy certainty.

A lack of detail on spatial policy for renewables.

3.1.7 Currently the NPPF refers to “suitable areas” and “opportunity areas” for renewables. RenewableUK strongly opposes such wording as it is vague and open to interpretation. It therefore recommends that the NPPF instead refer to the well known and understood term “Broad Areas of Search”.

3.1.8 The Companion Guide to PPS22 contains valuable information on the planning process for renewable energy. It includes information on Broad Areas of Development for example, which should not be lost. The Guide states that the boundaries of broad areas of search should not be identified on maps, but rather that criteria-based policies should be used to identify named areas which should be expressed as indicative symbols (if they need to be mapped) rather than as areas with defined boundaries.

3.1.9 Commercial uncertainty is a significant issue which could result from a lack of policy direction in the NPPF and in Local and Neighbourhood Plans. Developers are currently putting resources into developing projects in a way that is consistent with criteria in PPS22 and LDFs. However, unless provisions are strengthened in the NPPF, it would not be clear to developers whether their proposals are in conformity with the proposed policy on renewable energy in the NPPF, thus putting investment in great risk. If there is a lack of investment and delivery of renewables, this will compromise the UK’s security of energy supply and carbon reduction obligations.

3.1.10 There is currently a link to the Energy NPSs in a footnote on page 43 of the document. We consider this to be insufficient. In particular, there could be an opportunity to have a link in an energy chapter as suggested above, as well as in a new paragraph after Paragraph 152, and a bullet point under Paragraph 153.

3.1.11 If spatial planning is to go ahead as currently drafted in the NPPF, RenewableUK recommends the following:

There will need to be a clear methodology for the planning process, to be developed with input from the industry.

There will need to be a clear evidence base, such as studies carried out to underpin the approach ultimately taken.

The duty to co-operate provisions need to be strengthened both in the NPPF and Localism Bill.

It must be made clear that local authorities cannot introduce further delay by trying to refine the overall evidence base for the spatial approach. Landscape and visual studies, for example, can take months or even years to complete.

It must be made clear that there should be no presumption against energy development outside the Broad Areas of Search, provided the criteria are met.

PPS22 advice should be applied to each determination as it applies now.

(c) Duty to cooperate

3.1.12 RenewableUK sees the lack of strong direction or requirements for the duty to co-operate as a significant barrier for the deployment of renewable energy. The energy resource the renewables industry is reliant on (such as wind) is a cross-boundary resource and therefore if local authorities are going to be allocating “Broad Areas of Search” it is essential that cross-boundary cooperation takes place effectively and productively. This is addressed in more detail under Question 5 below, which addresses the duty to co-operate specifically.

(d) Natural Environment Policies

Green Belt

3.1.13 RenewableUK recognises the important role Green Belts can play and the presumption against inappropriate development in the Green Belt as set out in the draft NPPF. However, we have concerns that the NPPF as currently drafted would introduce restrictions on development which go beyond the requirements in existing national planning policy. These additional restrictions could undermine the provision of necessary energy infrastructure.

3.1.14 In particular, Paragraph 146—states that “When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development”. The renewables industry has serious concerns about this new policy statement which is not in the existing PPG2. We therefore wish ask that this statement be withdrawn.

3.1.15 At a practical level, a presumption against development of renewable energy projects in the Green Belt could have significant negative implications for the achievement of carbon emissions reduction targets and the security of electricity supply. Most of the major urban areas in the country are surrounded by Green Belt, which could be the perfect location for appropriate renewables infrastructure, such as wind turbines, which does not detract from the purposes of the green belt. This would allow energy generation to be close to demand and away from more environmentally sensitive areas. At the same time Green Belt land would be able to make a valuable contribution to renewable energy generation, where there are appropriate conditions for it.

Health of the Natural Environment

3.1.16 Paragraph 164 contains the actions needed to achieve the objective of a healthy natural environment. Renewable energy has a key role to play in achieving and maintaining this objective by contributing to a less resource-intensive society and economy. RenewableUK therefore considers that this merits the inclusion of two additional bullet points under Paragraph 164, to cover the promotion of a less resource-intensive society and economy; and the deployment of renewable energy.

Development in the Landscape

3.1.17 Paragraph 167 includes objectives in relation to protected valued landscapes, and bullet point four more specifically relates to major developments in designated areas. A new item is suggested to be included to cover the need for national and wider considerations (such as climate change and carbon emissions reductions) to be considered in exceptional circumstances where development is in the public interest.


3.1.18 Paragraph 169 outlines the principles that need to be applied in order to conserve and enhance biodiversity. Bullet point two relates to development proposals where the primary objective is to conserve or enhance biodiversity. A balance needs to be struck between protecting biodiversity locally, protecting biodiversity on a wider scale, and the process of achieving a less resource-intensive society. The achievement of such a society would in itself provide for the protection of biodiversity on all levels. RenewableUK therefore requests that the bullet point be amended to include a weighing up against national considerations, such as the security of energy supply and carbon reduction obligations.

Preventing Unacceptable Risk

3.1.19 Paragraph 173 relates to preventing unacceptable risks from pollution and land instability. Bullet point 3 seeks that local authorities identify and protect “areas of tranquility”. There is no rationale for this as change in the urban and rural landscape is a constant process. Such provisions should not be misinterpreted as barriers to the development of renewable energy. The functions provided by this bullet point are already catered for in the provision of National Parks, hence it is requested to be deleted. Additionally, noise is not a determinative issue for wind energy development and should not be dealt with under the NPPF.

3.1.20 On the basis of the comments above, it is recommended that:

The NPPF should not impose additional and unduly restrictive barriers to the deployment of renewable energy in Local Green Areas and Green Belt.

Renewable energy be included on the list of development which is not inappropriate in the Green Belt.

There should be careful coordination between the NPPF and the Natural Environment White Paper, without introducing additional barriers to the deployment of renewable energy.

(e) Local Authority Resourcing

3.1.21 Given that local authority budgets are being cut by one third, there is significant uncertainty in terms of their staff levels and knowledge base. RenewableUK is particularly concerned about how local authorities would be able to take on a number of new tasks, including the reworking of their local plan structure. RenewableUK would be happy to discuss with Government how local authorities could be resourced for the delivery of renewable energy objectives.

(f) Relationship of NPPF with Local and Neighbourhood plans

3.1.22 RenewableUK’s view is that the NPPF should make it clear that Local and Neighbourhood Plans should not preclude renewable energy developments in general or in large parts of their plan. Currently, due to the limitations of some plans, renewable energy developments do not always receive political support at local level, despite the urgent national need for addressing security of energy supply and climate change objectives.

3.2 Question 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?

3.2.1 The NPPF refers to sustainable development as defined in the Brundtland Report—Our Common Future. RenewableUK agrees that sustainable development is about the interaction of the environment, society and the economy. However, one key point of true sustainability, which is not well articulated in the NPPF, is that both the economy and society operate within the limits of the environment. The deployment of renewable energy ensures that this can be continued into the future.

3.2.2 Strong sustainability, with renewable energy, should be the overarching concept of the NPPF, and this should be stated very clearly. Only then would the statement in paragraph 11 that “there is not necessarily contradiction between increased levels of development and protecting and enhancing the environment” be put into true context. Sustainable development is only possible if development respects the limits of the environment as a finite resource.

3.2.3 As currently drafted, the NPPF can be misinterpreted to read that any growth should be encouraged—as stated in paragraph 13 for example. The NPPF needs to clearly state that truly sustainable (in an environmental as well as an economic sense of the word) growth is to be encouraged, as opposed to any growth. This, according to the Brundtland report means less resource-intensive growth. There are a number of other references to encouraging growth throughout the NPPF, such as in Paragraphs 10, 14 and 17, which need to be clarified in the same way.

3.3 Question 3: Are the “core planning principles” clearly and appropriately expressed?

3.3.1 RenewableUK supports the introduction of “core planning principles”, however we believe that some changes are required in order to make them clearer and more appropriate, as follows:

Bullet point 1 states that planning should be genuinely plan led. This principle is supported, however policy ticking should not be encouraged and decision—making should be a balancing exercise. Due to the limitations of some plans, they do not always contain positive policy provisions for renewable energy at the local level. Thus the NPPF should give as much support as possible to this type of development.

Bullet point 2 states that development should be supported and proactively driven—the type of development needs to be defined, ie “high-quality, less resource-intensive development this country needs”. The bullet point also refers to the key sustainable development principles set out in this framework— these are not clearly stated. If this is a reference to the roles of planning in Paragraph 10, this should be clarified.

Bullet point 7 refers to reuse of existing (eg existing buildings) and renewable resources (eg renewable energy)—this point is supported by RenewableUK with a request for an addition—the development of renewable energy and associated infrastructure should be referred to as well.

3.4 Question 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?

NPPF Relationship with the Natural Environment White Paper

3.4.1 RenewableUK has significant concerns about the integration of the Natural Environment White Paper (NEWP) and NPPF policy provisions. In particular, the significant role that the planning system is expected to play in bringing forward NEWP proposals is clear and the importance of getting these proposals right at the outset should not be underestimated. In order for these proposals to work most effectively, it is vital that Defra and DCLG work in close cooperation with one another, and with the renewables industry, in open and early dialogue to ensure that these initiatives do not thwart the delivery of wider sustainable development objectives and the long term prosperity of the country.

3.4.2 Proposals for further restrictions on development within the landscape should not unnecessarily hinder the development of much needed green energy infrastructure, and the contribution it can make to carbon reduction obligations. Such measures would be contrary to existing planning policy and the spirit of the 2009 Renewable Energy Directive. Wind energy, and other forms of renewable energy bring significant environmental benefits and should not be subject to further barriers to deployment in areas which would otherwise be suitable for development.

3.4.3 It is vital that proposals contained within the White Paper, and their implementation through the NPPF, do not frustrate the development of other pillars of national policy such as economic growth and sustainable development, including the deployment of much needed clean energy infrastructure. The benefits of renewable energy development in preserving and enhancing ecosystems, through carbon reduction and agricultural diversification should be recognised. Additionally, the NPPF should not impose additional and unduly restrictive barriers to the deployment of renewable energy in Local Green Areas.

NPPF Relationship with other Policy

3.4.4 RenewableUK welcomes the consolidation of existing policy statements and guidance into a single, streamlined document such as the NPPF. However, we believe that its links with the Energy NPSs in particular need to be strengthened.

3.4.5 Given the underpinning technical work, consultations and recent Parliamentary scrutiny/approval of the Energy NPSs, RenewableUK strongly believes that the NPPF should confirm them as a material consideration under the TCPA regime, as well as the primary policy document for the nationally significant infrastructure project (NSIP) regime.

3.4.6 It is requested that a new bullet point be included under Paragraph 153, instead of Footnote 8 on page 43 of the NPPF, which refers to the Energy NPS, Broad Areas of Search and development size. It is RenewableUK’s view that this would be a clearer and more logical layout of the guidance.

Additional/Compiled Guidance Need

3.4.7 RenewableUK has a concern that some important existing guidance may be lost in the process of policy consolidation. In particular, we wish to see that key aspects of existing guidance contained in PPS22, including on the sequential approach for renewables, be retained. Developments under “Other locational considerations”, paragraph 16 of PPS22 explicitly states that renewable energy projects should not be subject to a sequential approach as they can only be developed where the resource exists and where economically feasible. This position should be retained in the NPPF.

3.4.8 The Companion Guide to PPS22 contains valuable information on the planning process for renewable energy. It includes information on Broad Areas of Development for example, which should not be lost. The Guide states that the boundaries of broad areas of search should not be identified on maps, but rather that criteria-based policies should be used to identify named areas which should be expressed as indicative symbols (if they need to be mapped) rather than as areas with defined boundaries.

3.4.9 RenewableUK would also suggest that additional guidance be prepared on Broad Areas of Search for renewable energy projects, if the spatial approach as proposed, is to be retained in the NPPF. If required, RenewableUK would be happy to assist the Government in putting together such guidance.

3.4.10 In terms of the NPPF’s relationship with Local and Neighbourhood Plans, we believe that it is essential that the NPPF spell out that Neighbourhood Plans should align with and support the delivery of the strategic aims of the NPPF and Local Plans.

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

3.5.1 Given that the NPPF is not enshrined within the Localism Bill, and therefore it is Government policy rather than part of statute, the renewables industry has consistently called for Government to strengthen the “Duty to Co-operate” provisions of the Localism Bill to place an obligation on local authorities to positively plan for renewables infrastructure, particularly across boundaries. This is vital, since housing and commercial developments in one local authority area could have a major impact on another local authority area, due to the resulting increased energy requirements. Positively planning for this, with early engagement with the energy (and renewable energy) industry, will guard against a piecemeal approach, which is more costly and often has a bigger impact on the environment and surrounding community. This would enable a more strategic approach to energy provision.

3.5.2 RenewableUK welcomes the NPPF provisions to enable local planning authorities to jointly plan for development and infrastructure across boundaries, however we consider them to be very weak provisions which need to be strengthened. We have the following concerns:

A lack of cross-boundary planning will result in ad-hoc approach to much needed strategic infrastructure development, which will have a knock-on effect on all other forms of growth.

Without active assessment of, and planning for, renewable energy (and other) infrastructure, local authorities could be faced with shortfalls in network capacity and/or electricity supplies and the delivery of the UK’s energy needs as well as climate change targets as a whole could be jeopardised.

3.5.3 The NPPF places much emphasis on the need for additional housing and other development, yet it is essential that local authorities talk to energy companies to understand likely increases in demand arising from housing/other growth. Without active assessment of, and planning for, renewable energy (and other) infrastructure, local authorities could be faced with shortfalls in network capacity.

3.5.4 RenewableUK therefore recommends that:

provisions in the NPPF be strengthened to include a specific duty to jointly plan for strategic infrastructure and renewable energy and associated infrastructure in particular, across local boundaries.

The Duty to co-operate provisions in the Localism Bill need to be strengthened.

3.6 Question 6: Are the policies contained in the NPPF sufficiently evidence-based?

3.6.1 Renewable energy is not extensively covered within the NPPF, however in the case that the provisions that are in there, including spatial provisions are retained, these should be supported by:

Widely referencing the Energy NPSs which, given the level of underpinning technical work, public consultation and Parliamentary scrutiny/approval, provide strong evidence for both the urgent national need for all forms of renewable and low-carbon energy development and provide considerable useful detail/evidence.

Clear wording and explicit references are needed in the NPPF to ensure that natural environment policies, such as Green Belt and Local Green Areas are sufficiently evidence based and do not become additional barriers to the development or renewable energy.

3.6.2 In terms of spatial planning, developers already carefully consider the environmental suitability of locations when deciding where to build energy developments. The NPPF encourages local authorities to apply a spatial approach to renewable energy. Should this be implemented, it is vital that any spatial planning should be consistent and rigorous, and take into account the full range of other issues, including:

Natural resource availability/physiological factors (such as wind speed, proximity to water sources, geological suitability etc.)

Physical constraints (access to the grid system, road access, existing infrastructure/other impacts that may constrain a development, such as proximity to aircraft/bridlepaths etc).

Planning and environment constraints (health and safety, environment, air/water quality).

Public consultation and industry engagement.

3.7 Question 7: A brief general assessment of the fitness for purpose of the draft Framework as a whole

3.7.1 In summary, in RenewableUK’s view the NPPF as currently drafted is not fit for purpose for the following reasons:

It lacks policy direction and detail for local authorities, communities and developers.

It fails to properly integrate sustainable development principles.

There is an under-representation of Energy issues in the document.

Lack of integration with other environmental policy.

September 2011

Prepared 20th December 2011