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 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.
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’.
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.
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