Consultation response in full

Question 38 - Do you agree that in incorporating the Written Ministerial Statement on wind energy development into paragraph 98 of the National Planning Policy Framework, no transition period should be included?

The inclusion of a transition period has little bearing on the effects of the policy change and we have no strong views on this either way. We would however like to make some additional observations about the stated intention versus the actual effects of the WMS in general, alongside some recommendations for bringing outcomes of this policy closer in line with its objectives. We strongly welcome the intention to provide clarity on the local community ‘backing’ condition, which is discussed in more detail below.

Onshore wind in England post-WMS

The WMS was billed as “giving local people the final say over wind farms”, and the former Secretary of State for Energy and Climate Change made clear “that where local communities want more onshore wind, that should be supported.” But in practice the two new planning conditions for onshore wind introduced in the WMS, taken together, comprise a de facto moratorium on any new onshore wind generation in England - whether or not the local community wants it.

The Public Renewable Energy Planning Database shows that only six viable planning applications for wind projects in England have been submitted since the WMS was introduced, one of which has already been rejected. The remaining five applications comprise 22 turbines with a combined capacity of 42MW. None are community led schemes.

The WMS has had a damaging impact on four important stakeholder groups beyond the utility scale wind energy developers that were ostensibly the target of the new rules.

Farmers

Farmers have been amongst the key beneficiaries of small and medium scale wind energy developments in England and Wales, with renewable energy generation representing a vital source of revenue diversification. Around 500MW of medium sized wind is in private hands, providing around £125m annually to farming businesses (NFU) - as well as cutting farming business costs. Post-Brexit, farmers will need reliable sources of income and protection from energy price volatility more than ever.

Industrial energy consumers

Onshore wind is currently the renewable energy generating technology that is most able to compete with conventional high carbon energy sources in an open market without public subsidy. This is particularly true for PPA-based private wire development models, where behind-the-meter wind generation can allow industrial energy consumers to self-supply much of the power they need. Co-locating small and medium scale wind generation with power demand centres can help to minimise energy costs for UK business and industry - a key goal of the draft Industrial Strategy.

Community energy groups

No community wind projects have submitted planning applications since the WMS was introduced, while one 7MW scheme in West Yorkshire withdrew its planning application. Recent survey work by Centre for Sustainable Energy (CSE) shows that a majority of planning officers in England believe the WMS makes it harder for communities to bring forward wind projects. Communities have in practice lost agency as a consequence of a policy change that was supposed to give them more choice, not less.

Onshore wind supply chain companies

The onshore wind sector provides skilled, sustainable jobs distributed across the UK with hundreds of companies involved in the supply chain beyond manufacturers. Onshore wind expenditure has a high domestic content at 69% (Policy Exchange) and supports over 12,000 jobs (RenewableUK). Freezing the UK onshore wind market will entail losing existing jobs and lowering investment in skills and training in future positions. Smaller and medium scale manufacturers, of which several are UK companies, in particular stand to benefit from changes that enable communities, businesses and farmers to bring through smaller scale developments.

Practical problems with implementing the WMS

Designation in Local and Neighborhood Plans

Because Local Plans do not oblige local authorities to identify areas as suitable for renewable energy development, many local authorities are choosing not to carry out this work. Based on their 2016 survey results, CSE estimates that onshore wind will not now be able to be developed at any scale in around two thirds of English local planning authorities for the foreseeable future. Furthermore where local authorities do wish to plan for renewable energy, there are additional costs associated with non-token assessment of wind resource and designation of sites. In the context of shrinking local authority budgets this is likely to lead to wind designation being de-prioritised.

‘Fully addressing’ identified impacts and establishing local community ‘backing’

Nowhere else in the NPPF do the phrases ‘fully addressed’ or ‘therefore has their backing’ appear - the conditions are unique for onshore wind. Without specific guidance or criteria it is extremely unclear what additional conditions - if any - beyond the normal planning determination process this places on onshore wind applications. CSE’s November 2016 survey of planning officers found that only 14% felt that the existing guidance on this test is clear enough to support predictable planning decisions. Asked if they were themselves confident that they understood how this condition could be met by planning applicants, only 26% replied that they were. The stated confidence of the 26% group is further undermined by the fact that comments expressed by officers gave a wide range of different interpretations of what ‘fully addressed’ means in practice.

Summary

We share the view that local communities interests were not being adequately served under the pre-WMS regulatory regime for onshore wind, and we supported the removal of wind farms of over 50MW from the Nationally Significant Infrastructure Projects (NSIP) regime as part of the Government’s approach to giving communities more of a say on local wind projects. The top-down imposition of large scale industrial developments on skeptical rural communities who derived little or no benefit from hosting this important infrastructure was a mistake that has indeed had a corrosive effect on the social licence of the UK wind industry, at least at a localised level amongst certain demographics. Nevertheless we believe the conditions imposed via the WMS is the wrong political solution. It places unjustifiably onerous demands on a cheap and valuable technology that consistently enjoys support of conservative and non-conservative voters alike and offers local and national benefits. In doing so it fails to ‘give local people the final say on wind farms’ - as the need for designation means potential applications are often blocked before they can reach planning deliberation - and in fact undermines the agency of ‘communities that want more onshore wind’.

Recommendations

1. Identification of suitable areas for renewable energy in Local and Neighbourhood Plans

Government should establish a framework to support the development of Local Plans which actually meet the requirements of the NPPF on renewable energy and reflect the implications for spatial and local planning that national climate targets confer on localities. There must be identified resource for local authorities to carry out this work - in particular where they choose to identify sites suitable for wind development which entails extra costs to be completed to an appropriate standard.

2. Community backing

We welcome the intention to clarify the criterion for local community backing. However, the planning system already contains provisions for establishing local support for proposed developments. Ideally therefore the additional requirement that ‘planning impacts identified by affected local communities [are] fully addressed and therefore the proposal has their backing.’ should be removed altogether to remove confusion. Failing that it should be replaced or complemented with a set of substantive criteria that are consistent across all local authorities so that prospective developers can understand what threshold they are required to meet. We propose that the NPPG’s suggestion that local authorities develop planning policies that give material weight to community leadership, ownership or meaningful involvement in renewable energy schemes could also constitute an appropriate criterion for satisfying this test.

3. Exemption for community-scale wind projects

The Feed-in-tariff regime treats renewable energy developments under 5MW capacity as community-scale. We believe that this is an appropriate definition to adopt for an explicit exemption from the WMS conditions for consent for wind energy application.

Farmers and businesses seeking to self-supply alongside community energy groups would all be free to progress small to medium scale wind energy developments without prejudice under the standard planning system, while utility scale wind farms would remain subject to the additional constraints introduced by the WMS. This would ensure that England is able to continue to benefit from its wind resource, creating a pipeline of community scale projects that will contribute to British energy security and decarbonisation goals, as well as throwing a vital lifeline to domestic wind industry supply chain companies.

If you'd like to add your name to our response, sign here.

 

 

The full petition text

To Philip Hammond (Chancellor of the Exchequer) and Greg Clark (Secretary of State for Business, Energy & Industrial Strategy):

Ensure that the cheapest forms of clean energy - onshore wind and solar PV - are not frozen out of the UK energy system, by reinstating a competitive financial support auction for future projects.


Dear Mr Hammond,

Enabling the UK’s cheapest low carbon energy technologies to compete

In 2016, a record breaking 25% of our electricity mix came from renewables, according to the government's own figures. We welcome the government's moves to further this record thanks to their investment in less established technologies such as offshore wind, as well as their commitment to demand side response and battery technologies in the December capacity market auction.

We’re now awaiting the announcement on the future of the Levy Control Framework after 2020, which we understand will be announced in the Spring Budget.

As the principal control mechanism to ensure value for money for energy bills payers as we accelerate the UK’s decarbonisation, this announcement will have significant consequences for future investment decisions and costs borne by consumers.

As such, we believe it is imperative that a stable future deployment pathway is established for the two cheapest sources of low carbon energy - onshore wind and solar PV - so as to ensure we achieve maximum decarbonisation while protecting consumers from higher bills.

Onshore wind is low cost

According to the National Audit Office, onshore wind is the UK’s cheapest form of new build capacity. Even less bullish estimates, such as the BEIS autumn 2016 cost assessment, expect onshore wind to undercut new CCGT between 2018 and 2020. Onshore wind is the cheapest new low carbon power source we can build.

Excluding it from financial de-risking policies, and therefore blocking most projects’ route to market, will increase the cost of decarbonisation to the bill payer. It will also undermine the government’s manifesto pledge to achieve the lowest cost decarbonisation.

The cost of excluding onshore wind is significant for the billpayer

The Citizens Advice Bureau, in collaboration with NERA Economic Consulting, modelled the impacts on the overall cost to decarbonisation of excluding onshore wind from CfD auctions in 2015. They found that for each CfD auction round run without onshore wind, an additional £500m would be added to consumer bills over the 15 year contract period. With multiple auctions likely to be run to bring forward sufficient low-carbon power investment to meet emissions reduction targets, this additional cost could easily become a multi-billion pound proposition.

Policy Exchange similarly identify that replacing 1GW of onshore wind deployment with the equivalent amount of generation from offshore wind would add £75-90m per year.

With ambitious emissions reductions targets written into domestic law the UK has to invest in rapidly decarbonising the power sector. Onshore wind provides the most cost effective way to do this. The figures quoted here highlight the danger of escalating costs of alternative options if a route to market is not provided.

Solar PV cannot fill the gap

It is particularly troubling for the effective use of public resources that, due to the state aid rules surrounding the CfD mechanism, scale solar PV is also unable to bid for the same financial security that less mature renewables, fossil and nuclear generators have access to (via either CfDs or the capacity market).

As the UK’s second cheapest - and rapidly cheapening - low carbon power source solar PV might have been able to lessen the cost impact of excluding onshore wind from CfD rounds. However, by failing to run any Pot 1 CfD auctions, this mitigation is precluded, so the full additional cost implications will be realised.

This is compounded by the sudden reduction in FiT rates in 2015, which have led to an 83% reduction in average quarterly deployment of PV under the FiT in Q1-Q3 in 2016 compared to the same period in 2015 - according to the Solar Trade Association.

Freezing out the UK’s cheapest low carbon power sources

The decision not to run future Pot 1 CfD auctions means freezing the UK’s two cheapest low carbon power sources out of new energy investment and deployment.

This will have several negative consequences.

First, as discussed, it will increase the cost of the UK’s decarbonisation.

Second it will endanger crucial supply chains, skills and investment. 70% of spend on onshore wind over a turbine’s lifetime is in the UK. Thousands of jobs are supported - with the potential for strong growth. Skills needed to build on the huge success of renewables deployment in the UK over the last decade are at risk of being lost as pipelines dry up and jobs are lost - Endurance Wind UK’s closure is just one example. Investment is also being stymied: the unexpected early closure of the Renewables Obligation led more than half of major onshore wind lenders to say they would not lend in future. This trend will continue if the financial de-risking permitted for other technologies is not reinstated for wind. More broadly, the Office for National Statistics found that the UK’s clean energy sector shrank by 8.7% between 2014-15, in part due to policy changes affecting onshore wind and solar PV.

Third, it endangers public consent for the necessary transition to a low carbon economy. While public support for renewables remains very high (over 70% for onshore wind and over 80% for solar PV), concerns over the cost of energy have the potential to derail necessarily ambitious decarbonisation plans if ‘green taxes’ are identified as causal factors. Notwithstanding the undeniable long term cost and environmental benefits of investing in renewables, it would be prudent to honour the Government’s manifesto commitment to lowest cost transition in order to ensure public consent for action on climate change remains strong.

Fourth - and most importantly - for all of the reasons above it risks endangering the UK’s ability to meet its global climate change obligations. Since the Paris Agreement in 2015 a new global consensus has emerged over the need to work together to prevent catastrophic climate change. In order to achieve this all countries need to up their ambition - the UK will struggle to do so by ignoring some of the best tools available to build the transition. Domestically the Committee on Climate Change identified the lack of support for onshore wind as a policy gap in its June 2016 progress report to Parliament on meeting the UK’s own carbon budgets.

Reinstating support for onshore wind and solar PV

In light of all these considerations we the undersigned call on the Government to ensure that the cheapest forms of low carbon power - onshore wind and solar PV - are not frozen out of the UK energy system, by reinstating a competitive financial support auction for future projects. Future Pot 1 CfD auctions can be amended, with a tapering cap on the administrative strike price, to ensure further cost reductions over time. By holding the strike price for onshore wind level with the cost of a new CCGT plant the Government can honour its manifesto commitment not to provide new subsidy to onshore wind.

Both onshore wind and solar PV deserve the ability to compete on a level playing field with other generation technologies. As things stand the Government is picking winners before the game's even been played.

We would welcome a meeting to discuss this further and look forward to hearing back from you at your earliest convenience.

It's crunch time for community energy in Cornwall

It's crunch time for community energy in Cornwall

When the government chose to freeze out cheap and clean onshore wind power from the future of the UK’s energy system, it launched a two pronged attack.

One was the removal of the financial support it deserves in order to compete fairly with other energy sources, like fossil fuel generators, which still receive public subsidy. We’ve done a lot of talking about that since we launched Blown Away in October.

But we’ve talked less about the other one: new planning barriers.

Write to the Mail on Sunday

We know newspapers listen to their mailbags, so now is the time to let the Mail know people like it when they write positive news stories about onshore wind. Send the Mail on Sunday and email (and copy in the Daily Mail too) telling them you'd like to see more articles like the one from last week

Make sure you mention that backyard wind turbines are only a small part of the story. Everyone benefits from lower bills if we build the cheapest form of new energy - onshore wind. 

You can also mention other reasons you support onshore wind. 

Send your letter to the Mail on Sunday: letters@mailonsunday.co.uk

Make sure you copy in the Daily Mail: letters@dailymail.co.uk

 

The Blown Away quiz sources

The Blown Away quiz makes a number of assumptions, but seeks to provide an indicative sense of the scale of support being offered to fossil fuel generators, compared to the total absence of support for onshore wind power at scale.

Our estimations were derived from the following sources:

7GW of onshore wind capacity using £550m is based on Cornwall Energy estimates (scaled), endorsed by RenewableUK.

2,800 turbines is derived by dividing 7GW by average turbine size of 2.5MW, assumption used by RSPB in their 2050 Energy Vision report.

18.4tWh annual energy delivered also scaled from RSPB 2050 Energy Vision report.

6% of UK annual electricity demand derived by scaling from a New Scientist article which states Hinkley C would provide 24tWh annually, equating 7% of annual UK electricity demand.

£550m spent on diesel and coal power refers to £549m worth on capacity market contracts allocated to diesel (£176m) and coal (£373m) fired electricity generators in the 2014 and 2015 capacity market auctions.

Two further capacity market auctions will run in December 2016 and January 2017, and are expected to allocate around £1bn. For more information click here.

Thanks for standing up for onshore wind and solar

There's one more thing you can do - will you share the message with your friends so more of us can stand up for renewables?

 
 
 

Tell your local council you love wind

Wind power is most certainly a local issue. Councils have a big role to play with planning permission and there's often plenty of debate within local communities.

So make sure your council knows how important wind power is to you. Tell them why you like it and why you'd like to see it built in your area. We've written a template letter but feel free to personalise it and add in your own reasons. 

If you live in a rural area, this is particularly important - more space for a turbine than in a city! 

If you get a reply, don't forget to let us know: email hello@1010uk.org.

Write to your MP

Recent policy changes brought in by the current government have really hung wind out to dry. They've cut subsidies and tied planning permission up in knots. 

But MPs really do care about what they get through the post from their constituents. A mailbag of supportive letters could give them that little bit more motivation to stand up for onshore wind in parliament.

So let your MP know why you love wind - we've written a letter template with a few reasons, but do add in your own! 

If you get a reply, don't forget to let us know: email hello@1010uk.org.

Thanks for signing our petition!

You've signed our petition asking the government to ensure dirty fossil fuels aren't subsidised more than clean onshore wind. Thank you!

We'll be sure to send you updates about how the campaign is going and info about other ways you can support onshore wind. 

There's a few more things you can do: please get your friends to sign too!

 
 
 

And why not write to a newspaper and tell them how much your love wind. Or poke your MP or local council and make sure they know too. 

Thank you!

Thanks so much for poking the people in power about wind. It's super important we tell them how much we love wind, so the 73% of people who support it have their voices heard. And hopefully that'll mean more turbines and more clean, cheap wind power in the UK. 

If you get a reply, please let us know. Email us on hello@1010uk.org.

 

Guide: how to write to a newspaper

One way you can show your support for onshore wind is by writing to the press, nationally or locally. As our media analysis shows, national press often focuses on the perceived negatives of wind power rather than the benefits - so we need to rebalance the debate. And local papers are important for highlighting the potential onshore wind holds for communities around the country.

If you've never done it before, here's a quick guide to how to write to a newspaper.

If your letter gets published or you get a decent reply, please let us know! Email us on hello@1010uk.org or Tweet us @1010

 

Local paper

1. Identify the paper

If you want to write to your local paper go for the one that gets delivered to you for free. If you don't get one, have a look at this site that lists the local papers in different UK regions and find the one nearest you. 

2. Write your letter

Write them an email (or letter) letting them know you love wind and why. To help you, below are three key points we think are worth mentioning:

1. Public support for wind is sky high!

Latest polling from 10:10 and ComRes shows support for onshore wind is huge! 73% of the UK public support onshore wind.  In rural areas support is still over two thirds. What’s more, polling carried out by Co-op Energy found 52% of the public would support a wind turbine within two miles of their home.

2. Wind powers ahead in the energy price race

Wind is the cheapest form of low carbon technology, bar none. When taking into account carbon costs (i.e the cost of climate change and all its impacts) wind is the cheapest of all energy generation, including fossil fuels - according to Bloomberg New Energy Finance. By 2020 it is likely to be cheaper than new gas power stations on any measure. Add this to the fact that the UK is Europe’s windiest nation and the argument for clean onshore wind power really starts to add up.

3. Locally owned wind is good for communities

It has the potential to provide investment for local communities around the country. A wind farm recently given the go ahead in the Scottish highlands is expected to bring £9 million to the community through jobs, local investment and cost savings. This could be replicated across the country, bringing a welcome boost to many local economies. Unfortunately though, only 10 community energy schemes were registered in 2016, down from 76 in 2015. Communities are keen to make community energy work though. Research completed by Cooperative Energy this year states that 78% of the public think Government should do more to help local community groups generate their own energy, with profits staying in the area.

3. Send it off

The letters page of your chosen paper will have an email address or postal address you can use. You're looking for something like: letters@[the name of the paper].co.uk.

If you can't find it, head to their website. There should be a Contact Us page (usually in the footer of the site) where the email address for the letters page will be listed. If there's no letters address, the editor is your best bet. 

 

National paper

1. Identify the paper

Pick a paper to write to - perhaps one you read regularly or particularly like. 

2. Write your letter

Remember our media analysis showed that the written press are out of touch with the UK public on onshore wind. By writing to them we can bring them up to speed, and help rebalance the debate. Here’s three key things you could mention.

1. The UK press is out of touch with the public on onshore wind

New research by Sandra Bernick at Imperial College London and climate charity 10:10 has revealed that the UK’s print press is out of touch with the UK public on attitudes to onshore wind.

The research found that between 2011-2016 there were two and a half times as many negative editorial and comment pieces penned as positive ones. It also found that for every one positive argument used for onshore wind, there were four negative used against.

This is despite new polling carried out by 10:10 and ComRes showing public support for onshore wind farms is 73% - twice the level of support for fracking. The negative way the press report wind could explain why the same poll found that average perceived public support for onshore wind was 42%, almost half its actual level.

2. Onshore wind powers ahead in the energy price race - but government is blocking the way

Wind is the cheapest form of low carbon technology, bar none.  When taking into account carbon costs (i.e the cost of climate change and all it’s impacts) wind is the cheapest of all energy generation, including fossil fuels - according to Bloomberg New Energy Finance. By 2020 it is likely to be cheaper than new gas power stations on any measure. Add this to the fact that the UK is Europe’s windiest nation and the argument for clean onshore wind power really starts to add up.

However, the government has removed financial support for onshore wind, despite continuing to hand hundreds of millions to coal, gas and diesel generators through the ‘capacity market’. It’s not fair that onshore wind is hung out to dry while dirty fossil fuels remain supported.

3. Wind power is a great British success story

The proportion of UK electricity provided by onshore wind has trebled since 2010 to 6% in 2015. Add offshore wind into the mix and wind power provides at least 11% . In 2016 Scotland reached a new milestone - over 24 hours it met 100% of its electricity demand from wind. Clean wind power has most certainly moved from the margins into the mainstream of the UK’s energy system - and it is something we should be proud of, economically and environmentally. The UK ranks 6th in the world wind rankings and £400m was invested in onshore wind alone in 2015, building on the UK's status as the second largest market globally for wind in 2014. Just when we were really starting to get going, government has pulled the plug. When you consider all the benefits, this just doesn’t make sense.

3. Send it off

The letters page of your chosen paper will have an email address or postal address you can use. You're looking for something like: letters@[the name of the paper].co.uk.

If you can't find it, head to their website. There should be a Contact Us page (usually in the footer of the site) where the email address for the letters page will be listed. If there's no letters address, the editor is your best bet.