Letter of submission from RPA, following
the Review of Planning Policy Guidance Note 22
I enclose the RPA's response to the invitation
to send in a written submission following the PPG22 workshop held
I hope you find it useful. If the RPA can be
of any further assistance, please do not hesitate to contact me.
Chief Executive, Renewable Power Association.
Representations to the Department of Transport,
Local Government and the Regions on the review of Planning Policy
Guidance Note 22: Renewable Energy.
The Renewable Power Association (RPA) is a newly
established trade association representing producers of renewable
energy. Its membership includes renewable electricity generators,
fuel suppliers and providers of heat, along with their equipment
and service providers.
The RPA has member companies involved in wind
energy, solar, biogas, energy-from-waste, landfill gas, biomass,
wave, tidal, marine current and sewage gas industries, together
with respected names from the legal, accounting and energy trading
The RPA works on the large number of generic
issues that affect renewable energy producers, irrespective of
the technology involved. These include the New Electricity Trading
Arrangements, the Renewables Obligation, renewables integration
issues, embedded generation, NFFO/SRO contract issues, emissions
savings, planning, the Climate Change Levy, etc.
1. The RPA participated at the invitation
of DTLR in a seminar concerning the review of PPG 22 on 16 January
2. At the conclusion of the seminar participants,
who represented industry, government agencies and departments,
research organisations, local government and non governmental
organisations were invited to submit written representations to
DTLR on their views about review of PPG 22.
3. The RPA, although a new organisation
founded in 2001, has through its member companies considerable
experience of the development of renewable energy in the UK. Like
all other organisations in the field it sees the current 10 per
cent renewable generation by 2010 target as extremely challenging.
The rate of deployment will need to increase over seven fold compared
to rates seen since 1990. Delivery of the current level of capacity
has been slow, disjointed and for the most part difficult. 2010
is not far away in project development timescales and it is important
that PPG22 is revised as rapidly as possible, to give a positive
tool for the development of renewables. The Scottish equivalent
of PPG22, the NPPG6, has been effective and the RPA would encourage
DTLR to produce a similarly positive document.
4. The main influences in the deployment
of RE so far in the UK have been the, mainly financial, support
mechanisms and the planning system. Progress to date in deployment
may be summarised as there being considerable and real support
for RE at a national level but that individual projects have had
considerable difficulty in gaining planning permission at the
local level. Indeed the policy drivers for national support have
strengthened considerably as a result of stronger European legislation
(the EU Renewables Directive); international efforts to curb climate
change and pressures from the Royal Commission on Environmental
Pollution and recently the Cabinet Office PIU Energy Review.
5. The national drivers for RE include the
legally binding contribution the UK has to achieve in meeting
its Kyoto and EU RE Directive obligations and for delivering annual
RE targets to electricity supply from 2003. The latter is one
of the most important measures that will be necessary to meet
the international targets. As such the revised PPG must be focused
to deliver these requirements.
6. Planning has been seen as an obstacle
to deployment of RE, rather than as a positive force for encouraging
deployment. This belies the true purpose of the planning system"to
regulate the use of land in the public interest"as
such regulation has effectively held up deployment of RE developments,
denying the public interest which is to see a much higher level
of deployment than that which has to date been achieved. This
problem is acknowledged in the DTLR Planning Green Paper and requires
7. Furthermore the current system in practice
is adversarial and must be changed to reflect the benefits that
renewables bring at local, national and international levels.
Several decisions have stated or implied a global benefit can
only be achieved by a local negative impact but in the majority
of cases this is not the case. A partnership approach advocated
in the Green Paper is essential to deliver RE projects at the
build rate required and the PPG should say this. The existing
system, which has led often to public inquiries, is unsatisfactory
as it unnecessarily polarises viewpoints, is expensive, time consuming
and the only winner is the legal profession.
8. That this state of affairs has come about
reflects an inability in the planning system to react proactively
to the considerable demands placed upon it in by the RE industry.
It also reflects some specific problems with the NFFO systemit
was made site specific but with limited consideration of whether
the sites proposed were capable of gaining planning permission.
9. The result has been a level of failure
of planning applications for RE projects which is high when compared
to other development sectors (eg retail, housing). In response
Government and the industry have resorted to solutions such as
off shore wind power which largely bypasses the planning system.
The RPA's view is that such measures are indicative of an underlying
problem which, until it is addressed properly, will continue to
dog the successful achievement of the RE targets.
10. The RPA believes that review of PPG22
is absolutely necessary to create a better planning framework
for the delivery of RE projects over the coming years. However,
this alone is not sufficient to address the very real problems
faced by industry and local planning authorities in considering
RE projects. The Government has recently issued its Green Paper
on review of the planning system, entitled "A Fundamental
Change". Reforms to many other areas of planning policy,
interrelated to RE development through the system of PPGs is necessary
to create the conditions for the large scale deployment of RE
which the Government, the RE industry, the environmental movement
and others wish to see.
11. That PPG22 has, in its current form,
faults is understood widely. It is perhaps longer than it needs
to be, recites general planning procedures unnecessarily, is insufficiently
well cross referenced to other PPGs and to Circulars, and contains
information about RE technologies which is out of date and in
some cases inaccurate. This is not the fault of the PPG but is
indicative of general faults in the system of Planning Policy
Guidance which is perhaps unwieldy, overly long, and insufficiently
reactive to changes in development industry.
12. The RPA believes that the RE industry
has to be dealt with differently to other types of development
which the Government wishes to support. The main difference between
RE and, say housing, is that the renewables industry lacks the
financial resources required to support long standing and detailed
involvement in the planning process. In comparison, the house
building industry actually supports regional planning studies
through its trade body, the House Builders Federation. As a result
every local plan or UDP is subject to representations by the house
building industry relating to sites and housing targets.
13. Without significant changes in the system
for support and control of renewable energy in the planning system,
the RPA fears that planning will continue to act as a barrier
to RE deployment. Aside from the damage to the RE industry and
the government's targets on renewable energy, this will undermine
the reputation of the planning system as a force for delivering
the government's sustainable development agenda.
14. Thought needs to be given to the mechanisms
by which the regional targets for RE, which have recently been
identified through the Regional Renewable Energy Studies, can
be delivered. The idea of translating these regional targets through
to district targets in the same way as is done with housing figures
is probably unrealistic. A high degree of flexibility is needed
to allow for the differences between technologies and the scope
for technological innovation.
15. In consideration of Regional targets,
consideration should be given to how these should relate to other
regional objectives such as landscape protection or agricultural
diversification. The RPA believes that there should be some parity
between the Regional objectives of protecting landscapes and other
environments and of providing for the generation of renewable
energy. Particularly where landscape or other policies of local
importance are protected, PPG22 should give guidance on how the
regional objective of delivering RE should be reconciled with
16. Members of the RPA believe that PPG22
in its current guise is;
provides little real guidance.
17. Therefore a fundamental reform of PPG22
is required. This would appear generally within the spirit of
the Government's Green Paper on reforming the planning system.
The new PPG22 should be:
shorter and more precise;
written on the basis of current and
predicted future technology but not over-descriptive about technology;
provide guidance both to Local Planning
Authorities and developers about best way to promote
renewable energy through the planning system;
capable of being updated annually
or bi-annually without the need for fundamental review.
18. The purpose of the PPG is as much to
assist local planning authorities as it is to assist the industryso
to a certain extent it should contain basic information on RE.
19. Experience from planning inquiries shows
how little use PPG22 has been either to LPAs or developers in
resolving planning issues associated with RE projects.
20. In reviewing PPG22, DTLR should see
it in the context of national energy policy, specifically the
physical developments needed to deliver energy policy. Commonality
of approach between procedures and policy guidance for developments
promoted through Planning, Electricity, Transport and Works and
Private Acts would help. E.g. Offshore wind is seen currently
as a "great white hope", largely because of the belief
that it can be promoted under T + W Acts procedures. But;
(i) LPAs retain a significant role as consultees
on T + W Act type procedures;
(ii) Projects usually require development
on coast, which require planning permission.
21. National energy policy has been stated
and is clear on the requirement for a major scale-up of renewables.
This must not continue to be a matter of debate by decision makers
in the planning arena. There should be better weighting of the
environmental benefits of renewable energy in planning decisions
in comparison with the alternative ie generation from fossil fuel
or nuclear sources. The fact that larger power plants are considered
by the Secretary of State with the Local Planning Authority merely
a statutory consultee has tended to make things more difficult
for renewable projects by comparison.
22. The emphasis of current PPG22 tends
to be on electricity generation and grid connected projects. Whilst
these will remain important, Kyoto objectives may also be achieved
by small-scale non-grid connected projects and by CHP and heat
only projects. PPG22 should address smaller scale as well as larger
23. Members of the RPA have many ideas about
how to facilitate delivery of RE objectives through planning and
development control systems:
(i) Requirement for percentage number of
new houses on a development to have solar panels or passive solar
design. Like requirement for percentage social housing. Possibly
to be delivered through "community development tax"
approach suggested in reform of planning obligations as part of
Planning Green Paper.
(ii) Developments above a certain size must
have eg a wind turbine on site or pay for one elsewhere in the
region. Has been tried in LB Merton.
(iii) Commercial developments above a certain
size to be permitted only if planning obligation entered into
to procure percentage of power used from renewable sources.
(iv) Enhance understanding of sustainable
energy use in consideration of urban regeneration and new urban
forms. E.g. considerable effort and policy on achieving green
transportation in regeneration areas but little thought so far
to, for example, district heating, which may be powered by biofuels
(v) Proactive policy stance in development
plans and related documents. Some authorities (eg Bradford) considerably
ahead of others in creating RE friendly policy environment and
in making links to other areas of policy.
24. Relationship with other PPGs. PPG7 Countryside
and PPG20 Coast for example are particularly relevant but connection
of RE to these is not clear.
25. Specifically regarding PPG 7: Countryside
and Rural Economy, role of RE as form of agricultural diversification
requires detailed consideration. Also there should be a review
of whether some forms of RE development may be appropriate in
Green Belts. E.g. wind farms, small-scale hydro, small scale solar.
26. Within development plans, RE policies
should be clearer and more succinct, PPG22 should encourage this.
Tendency for pro RE policies to be outnumbered by policies acting
against RE. Desire for parity of status of all environment and
27. Only proactive/ positively worded part
of current PPG22 concerns areas of search". These have not
ended up being used or being usefulneed to consider why.
Previous tendency to view RE a bit like minerals but increased
realisation that unlike minerals RE does not have precisely defined
areas of arisinga different approach needed.
28. General failure of development plans
to have site-specific policies on RE, unless worded negatively.
Need to consider whymargins on RE projects not sufficient
for developers to fund long lasting local plan involvement perhaps.
Alternative approach needed.
29. Energy Local Planspreviously
discussed sectoral local plans akin to Minerals and Waste Local
Plans. Increased move towards this type of planning if District
wide Local Plans and UDPs to be replaced by Local Development
30. In other utility industry development
sectors there has been advice in the form of planning circulars
about the appropriate ways for developers and planning authorities
to react to development projects. For example, DoE Circular 17/91
on Water Industry Investment advised LPAs to accept that wastewater
treatment infrastructure would necessarily be located close to
outfalls. No such advice currently exists for RE development although
certain parallels can be seemhydro power can only occur
at rivers, wave power at the coast and wind power in exposed locations.
In revising PPG22, the RPA therefore believes that DTLR should
consider providing similar input either in guidance or as a separate
31. The RPA would also welcome a review
of the General Permitted Development Order to include minor forms
of RE development. It accepts that this is not directly an issue
for the revision of PPG22 but considers it to be relevant.
32. Finallycurrent PPG22 has not
been a complete disaster. For example the general quality of development
plans is considerably better now than five years ago in terms
of their coverage of RE. Also deployment of RE has had limited
success and general awareness of RE within planning profession
is better. So we are building on success, perhaps changing up
a gear rather than kick starting a recalcitrant motor.