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?
For live wind energy applications that entered the planning system before the written ministerial statement came into effect on 18th June 2015 we believe transitional arrangements should remain in place to allow determination under the arrangements that applied at that time.
We would also like to make some additional observations about the stated intention versus the actual effects of the written ministerial statement (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 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, industrial or large energy consumers, community energy groups and UK-based supply chain companies.
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.
Farming businesses are being denied the ability to diversify income and reduce business energy costs.
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 gross income of around £125m annually to farming businesses (NFU estimate) - 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. However, the most recent NFU Farmer Confidence Survey (autumn 2016) shows that while many forms of on-farm renewable energy continues to grow, the proportion of farmers deploying wind power has remained flat.
Industrial energy consumers
Industrial and large energy consumers are less able to reduce energy costs, reduce exposure to volatility and decarbonise.
Onshore wind is currently the renewable energy generating technology 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. If this was supported by increased energy management and efficiency savings and complemented by energy storage technologies, some industrial sites could become completely energy self-sufficient including EV and HV (Hydrogen Vehicle) charging stations.
Community energy groups
Community energy groups in England are prevented from developing wind energy projects that can bring local benefits.
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. Where one side of a community supports a scheme and another group opposes it, how should planning officers determine whether the application has the support of the community or not? This remains unclear, and stymies community groups with limited resources being able to bring forward projects that can bring local benefits. In practice, communities have lost agency as a consequence of a policy change whose stated aims included giving them more choice, not less.
For example, Bristol Energy Network - a co-signatory to this response - is working with one of its community members, Ambition Lawrence Weston, to develop a community-led wind turbine. While this has the support of the community, and would provide an opportunity for a significant community benefit fund to tackle fuel poverty and social inequalities, the new planning regulations have made it extremely difficult to develop the project.
Onshore wind supply chain companies
The onshore wind supply chain, particularly at the small and medium end of the market, supports British businesses and jobs - and is now under severe threat.
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). Continuing to freeze 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 Neighbourhood Plans
Local authorities lack the resources or capacity to appropriately plan for wind energy.
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’
Local planning authorities do not understand the community ‘backing’ requirement, meaning the risk of submitting an application is deemed too high.
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. Investing resources in a wind energy application in this context becomes intolerably risky, especially for community-led projects.
Meaningful local participation and engagement in planning decisions regarding wind energy is essential - but the result of the WMS has been to create extreme uncertainty, and hurt communities, businesses and farmers it was not designed to undermine. Changes to paragraph 98 must reflect these learnings and ensure a reasonable balance.
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 sceptical 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 are the wrong political solution. These place 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, the WMS 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’. Furthermore, British farmers and businesses are being denied valuable opportunities to reduce energy costs and exposure to price volatility while contributing to national decarbonisation.
1. Provide adequate resource and framework for the 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. Mapping the national wind resource more accurately and publicly to Local Authority levels could help to direct future wind developments more effectively. Additionally, for areas where a local plan has not yet been adopted government could consider allowing applications to be submitted for wind energy development on a criteria basis until site allocation is completed by the LPA.
2. Remove or clarify the community ‘backing’ criterion
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 require planning impacts identified to be material to the application in question, and 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. Provide exemption from rules introduced in the WMS for community-scale wind projects
The Feed-in-tariff regime treats renewable energy developments under 5MW capacity as community-scale - and the vast majority of onshore wind Fit projects are within the 1.5MW threshold. We believe that either of these capacity thresholds would be an appropriate definition to adopt for an explicit exemption from the WMS conditions for consent for wind energy applications. 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 subject to any future changes. 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.
Leo Murray, director of strategy, 10:10
Richard Hatton, country manager at Enercon GmbH-UK
Jonathan Scurlock, chief adviser, renewable energy and climate change at National Farmers' Union
David Tudgey, project development officer at Bristol Energy Network
Dale Vince, founder of Ecotricity
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