Environment, Food and Rural Affairs CommitteeWritten evidence submitted by RenewableUK

RenewableUK is the trade and professional body for the UK wind and marine renewables industries. Formed in 1978, and with over 670 corporate members, RenewableUK is the leading renewable energy trade association in the UK. Wind has been the world’s fastest growing renewable energy source for the last seven years, and this trend is expected to continue with falling costs of wind energy and the urgent international need to tackle CO2 emissions to prevent climate change.

1. Introduction and Summary

1.1 RenewableUK welcomes the EFRA Committee’s Inquiry into the Natural Environment White Paper (NEWP). While we welcome the principles and objectives of NEWP, and the use of biodiversity offsets, we highlight the need for proper coordination of strategic Government objectives across departments. The NEWP must not frustrate economic recovery and carbon reduction initiatives, and any resulting action or policy must not act as an additional barrier to the deployment renewable energy, which facilitates environmental protection and sustainability—now and in the future.

1.2 There is also a need for a procedural framework supporting NIAs, LNPs, and LGSs to be subject to pubic consultation and wide engagement process—not simply developed by the departments or those specifically nominated by them. The creation, management, and upkeep of NIAs and LGSs should be done in an inclusive way and open to all stakeholders, including those from the business community. The planning status of LGSs and the different parts of NIAs also needs to be clarified.

2. Context—The Role of Renewables

2.1 Renewable energy plays a very important role in contributing to sustainable development, in reducing the country’s carbon emissions, reducing reliance on environmentally damaging fossil fuels and in mitigating the impacts of climate change, all of which will also help achieve the aims of the NEWP. It helps protect the environment for future generations, makes the economy more environmentally sustainable and improve the quality of life and well-being of communities.

2.3 RenewableUK believes that the UK’s renewable energy targets will be best met through a diverse mix of sources. 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. This will require positive planning and therefore a strong policy support.

3. Responses to the Committee’s Questions

3.1 Question 1: What actions are required across Government Departments, from local government and by civil society to deliver the White Paper’s proposals to grow a green economy and reconnect people with nature?

3.1.1 It is vital that any Government strategy for the conservation of biodiversity and the environmental adaptation to climate change is conducted in harmony with the Government’s objectives for the decarbonisation of the UK’s energy network and the wider role of sustainable development in mitigating as well as adapting to future climate change. The proposals set out in the White Paper must correspond with and not frustrate the deployment of the clean and green energy infrastructure that the country needs in order to achieve substantial reductions in green-house gas emissions, stabilise energy costs and sustain economic prosperity while securing the long term future of the country’s ecological diversity.

Nature Improvement Areas

3.1.2 RenewableUK has concerns with the function of NIAs, the method in which they may be identified, and their planning status—at the local and strategic level. These should be clarified by Government with more policy detail. Without clear focus on a limited number of key priorities for restoration within each NIA, there is a real risk that this initiative may lose focus and become dissipated.

3.1.3 RenewableUK recommends that proposed timescales be published for the election of an assessment panel and engage in stakeholder discussion workshops to inform the development of the criteria against which competitive bids are to be assessed. To ensure that the identification and subsequent location of NIAs are both widely understood and supported, it will be important to bring together a wide range of stakeholders in their development and in securing their continued success.

3.1.4 It is understood that 12 NIAs, covering at least 10,000 ha are to be established by 2015. However, the proposed configuration of land within NIAs, with core areas, corridors and stepping stones, is not yet clear. RenewableUK seeks further clarification as to the way in which the Department has envisaged these areas to work together, and the extent to which these areas are likely to map onto existing areas of environmental conservation.

3.1.5 The NEWP states that local authorities, communities and businesses will be able to use local planning to support NIAs through identification in local plans where they choose. However, there is no clarity as to the relationship between NIAs and the planning system, including, for example, whether NIAs may be identified as part of the plan-making process, at what stage NIAs may be included within local plans, and the status to be accorded to NIAs within the planning system. More detail is needed in policy, and we remain concerned that any uncertainty as to the role and status of NIAs, or their component parts, within the planning system will thwart investment in sustainable infrastructure and frustrate the economic recovery.

Local Nature Partnerships

3.1.6 RenewableUK welcomes the establishment of Local Nature Partnerships. However, in order for relationships between LNPs and LEPs to flourish, there will be a need for mutual cooperation and coordination of objectives. Without a clear priorities and objectives, there is a real risk that siloed thinking may result in conflicting initiatives, confrontational relationships and confused results. In order for economic investment to prosper it will be necessary for the objectives and relationships between these groups to be easily understood and informed by the business community as well as by local residents and interest groups. It is also important that their duties and make up are clearly laid out, to ensure that they are acting transparently and representatively.

New Local Green Spaces Designation

3.1.7 RenewableUK understands that the Local Green Spaces Designation (LGS), as identified within the NPPF is designed to give local people an opportunity to protect green spaces that have significant importance to their local communities. While we appreciate the need to prevent overdevelopment of areas we suggest that the aims behind this proposal may be better met through existing initiatives.

3.1.8 The purpose of such a designation was initially envisaged as being analogous to Sites of Special Scientific Interest (SSSIs); designed to protect and conserve species, habitats and geological features that meet specific criteria, based on their scientific importance. In contrast, the proposed criteria for the selection (and therefore function) of LGSs, as set out within the draft NPPF appear to protect sites that are “demonstrably special to a local community” for any, or all of the following reasons: beauty; historic importance; recreational value; tranquillity; richness of its wildlife.

3.1.9 It is clear that the above summary of proposed criteria for designation differ significantly from that of SSSIs. The proposed function of the LGS appears to act rather as a “catch-all” for a range of amenity, ecological, landscape and historic factors. In RenewableUK’s view the various intended objectives of the LGS would be better met through existing area-based classifications, eg Sites of Special Scientific Interest; Sites of Importance for Nature Conservation; Areas of Outstanding Natural Beauty; National Parks; Village Greens; Green Belt; Special Areas of Conservation; Special Protection Areas; National Nature Reserves; and Local Nature Reserves.

3.1.10 RenewableUK believes that the creation of a new designation will add confusion for all parties, both creating additional workload within LAs, who will be confirming these new designations; and raising extensive concerns amongst the developer community across all sectors, at a time when the Government is seeking to shore-up business confidence and stimulate an economic recovery. We recommend that the Government re-consider whether there is a need for this designation.

3.1.11 RenewableUK also has concerns that the creation of new areas identified as LGS, as currently defined, will further prevent the development of renewable energy infrastructure in otherwise acceptable locations. We therefore fundamentally object to draft proposals for local policies for managing development within LGSs to be consistent with those established under Green Belt legislation. Instead, we urge clear guidance on what development is appropriate within LGSs and exactly what their status is.

3.1.12 Following the publication of the draft NPPF, we understand that consultation on this designation is currently taking place within the wider consultation on the NPPF and not through separate publication. With such a potentially new important designation, RenewableUK feels that there should be an independent consultation, prior to consideration over its inclusion within national planning policy. RenewableUK also seeks further clarification as to the intended scale of LGS areas, as we believe the current wording contained within the draft NPPF to be overly simplistic and open to wide interpretation and possibly abuse.

3.2 Question 2: Will the institutional framework outlined for delivering the proposals (in particular Nature Improvement Areas and Local Nature Partnerships) be effective? Does the proposed Natural Capital Committee have sufficient powers?

3.2.1 In RenewableUK’s view, the proposed framework for delivering NIAs and LNPs will not be effective because, as discussed above, more detail is needed on how the institutional framework would be set up and operate; the framework cannot function efficiently without the involvement of local businesses and communities from the outset. The channels for doing this are not clearly defined in policy at present; and there is a need for a clear policy direction of mutual cooperation and coordination of priorities and objectives at the institutional level which is currently not in place.

3.3 Question 3: What further research and/or evidence is required to develop practical programmes sufficiently detailed to deliver the White Paper’s ambition to fully embed the value of nature into policy delivery?

National Ecosystems Assessment

3.3.1 RenewableUK supports the principle objective of the National Ecosystems Assessment (NEA) research, but asks that the development of further research proposals be conducted in an open and consultative way with a range of industry and environmental stakeholders, in order to learn most effectively from existing good practice and build on known successes. The role of renewable energy in preserving and enhancing ecosystems should be recognised.

Research programme on soil degradation

3.3.2 The NEWP states that Defra intends to conduct further research on how to best manage lowland peatlands in a way that supports efforts to tackle climate change. While RenewableUK welcomes the principle objectives of such research, we ask that any work be conducted in a coordinated way across all parts of Great Britain bringing together Natural England, Scottish Natural Heritage and the Countryside Council for Wales, in order to resolve existing differences in approach and policy inconsistencies in the treatment of proposed development in such areas. We also recommend that any proposals for new research should first consider the valuable insights already gained from peat research, such as that conducted by Scottish National Heritage.

3.3.3 With regard to the development of wind energy on peatland, we recommend that any emerging policy reflect existing evidence that good practice in locating, designing and managing windfarms can lead to them being successfully accommodated within some areas of peatland, with minimal adverse environmental effect. Additionally, in some situations good practice can also deliver long-term peatland benefits including restoration of previously damaged habitats.

3.3.4 Therefore any policy developed as a result of Defra’s research should take into account not only the amount of carbon that is released into the atmosphere where windfarms are constructed in peatlands, but also the benefits of clean energy production, the offsetting of fossil fuels use and any restoration measures that are proposed on site. RenewableUK is eager to be involved in the formulation of any policy emerging from soil and ecosystem services research. The results of such research should also be peer-reviewed and robust.

3.4 Question 4: What evidence is there from other countries that the approaches proposed in the White Paper can be successfully applied in practice?

3.4.1 RenewableUK is not aware of any at the present time but remains keen to engage with DEFRA and statutory agencies further on this.

3.5 Question 5: What resources will be needed to fully deliver the White Paper’s ambitions and how can these best be provided? How might the value of “services” provided by ecosystems to beneficiaries be translated into spending that will enhance the natural environment?

3.5.1 In the present economic climate, where LPAs and statutory agencies need to be better resourced, the NEWP initiatives will result in additional demands and responsibilities in a time of financial constraint.

3.6 Question 6: Does the White Paper set out an accurate assessment of the barriers to public engagement with the natural environment and make the most effective proposals for re-engagement?

3.6.1 It is RenewableUK’s view that LNPs have positive potential in this regard, however we question the creation of LGS as an effective means of increasing public engagement on environmental issues.

4. Conclusions

4.1 For the economy to prosper, it is necessary that the Government’s objectives on the Green Economy, the environment, planning and other national objectives work together through a cohesive and coherent vision, rather than in fragmented and divergent ways. In order to maintain business confidence and secure necessary inward investment in the UK, Government must work collaboratively across Departments to remove policy contradiction and minimise policy uncertainty.

4.2 It is vital that all initiatives take into account the contribution that renewable energy infrastructure deployment makes to the reduction of fossil fuel use and meeting the UK’s climate change targets. Any future action and policy resulting from the NEWP should not therefore result in additional barriers to renewable energy development.

26 September 2011

Prepared 16th July 2012