A lack of “suitable areas” for onshore wind in local plans

Despite a recent overhaul of national planning policy in 2021, new applications for onshore wind1 still can’t receive planning permission unless they have the “backing” of the local community and are identified in an area "suitable for wind energy" in an adopted local or neighbourhood plan.

This report builds on our initial research in 20192 into how well councils are planning for onshore wind, though within the recognised constraints of national planning policy. It reaffirms the national policy imbalance between carbon intensive vs renewable energy production and concludes that in the 3 years since our original report, and with the UK inching closer to the 2050 net zero target, even fewer adopted local plans identify areas suitable for onshore wind. 

We acknowledge the long-term financial and resource constraints potentially hindering some planning authorities. However, with the country facing multiple climate, ecological and energy challenges, it’s more important than ever that onshore wind generation isn’t hamstrung by a lack of uptake by councils identifying "suitable areas". 

The paper assumes some basic knowledge of the planning system. If you’d like to access the original 2019 report, please contact [email protected]. Alternatively, a summary is provided below.  

Policy restraints on onshore wind

Despite the well-documented imbalance in national policy against onshore wind compared to oil and gas developments,3  and the ongoing energy crisis, the National Planning Policy Framework (NPPF) retains a "de facto ban" for new onshore wind schemes. The current policy wording originated from a 2015 Written Ministerial Statement (WMS) based on a Conservative Manifesto pledge to "change the law so that local people have the final say on wind farm applications." 

The current version of the NPPF states that when determining applications for renewable and low-carbon development, councils should:   

"...approve the application if its impacts are (or can be made) acceptable. Once suitable areas for renewable and low carbon energy have been identified in plans, local planning authorities should expect subsequent applications for commercial scale projects outside these areas to demonstrate that the proposed location meets the criteria used in identifying suitable areas."

Footnote 54 then states:  

"Except for applications for the repowering of existing wind turbines, a proposed wind energy development involving one or more turbines should not be considered acceptable unless it is in an area identified as suitable for wind energy development in the development plan; and, following consultation, it can be demonstrated that the planning impacts identified by the affected local community have been fully addressed and the proposal has their backing." 

It's clear that the above NPPF context is very restrictive, with planning applications for onshore wind having to overcome a range of negative caveats. While we can’t influence whether future applications receive backing local communities, we can try and influence the update of suitable areas in adopted plans, which is one half of the battle won.  

2019 findings

Before we undertook our original research in 2019, available data from that time made it clear that onshore wind approval and installation rates had dramatically fallen since the government’s original 2015 WMS. For instance, only 16 new turbines were granted planning permission between 2016 and 2020 across England, representing a 96% decrease compared to the 435 turbines permitted for construction on 108 different sites between 2011 and 2015. 

Our research agenda arose from joint concern shared with Possible (previously 10:10) and the Centre for Sustainable Energy over the rates at which suitable areas for wind might be being identified in newly adopted local or neighbourhood plans, and whether low uptake might create further trouble for future delivery.    

Our initial 2019 findings supported that concern, with only 25% of councils (from the 20 randomly identified) having included "suitable areas" in their adopted or emerging plan – as required for renewables developers to part-pass the above NPPF policy test. Though based on a limited sample, the figure suggested onshore wind delivery could be further constrained across large geographical areas of England (where the NPPF policy applies).  

More recently, in the wake of the ongoing energy crisis, there was an understandably high expectation that onshore wind might feature more prominently within the government’s British Energy and Security Strategy. Unfortunately, no national planning policy U-turn was offered, and the restrictive NPPF remains. The one notable exception regarding onshore projects links to the repowering of existing wind farm sites, which can take place without footnote 54 restrictions (although this originated from a 2020 review of the NPPF).     

The ongoing energy crisis means the government must seek alternative and radical ways to reduce UK electricity costs, which is why – despite there being no policy U-turn – we believe the subject of onshore wind and "suitable areas" in local plans is worth revisiting.  

New evidence

Since our initial findings that only 25% of local plans were identifying "suitable areas" for onshore wind projects, more academic research has been undertaken, most notably by Dr R. Windemer of University of West England.4  While Dr Windemer’s full paper has not yet been published (scheduled for late 2022), her preliminary results are available and have helpfully been informed by a much larger sample of councils (ie, 165 compared to our sample of 20).  

This new academic evidence supports our previous findings but also proves the identification of "suitable areas" for onshore wind has worsened since 2019.  

2022 UWE initial research findings: detail

Based at the Centre for Sustainable Planning and Environments (University of the West of England), Dr Windemer’s key findings highlights an even bleaker picture compared with 2019: 

"…140 (or 85%) [of councils] do not have areas identified as suitable for wind energy development in their local plan. A review of remaining local authority policy documents revealed that overall 89% of all local planning authorities in England do not have areas identified as suitable for wind energy development in their local plan or in an adopted neighbourhood plan."

This is a worrying trend. 89% of all local planning authorities (aka councils), when combined, represents an extensive geographic area where essentially no new applications for onshore wind can be approved as they would not accord with the restrictions of retained NPPF policy identified above.5

While the UWE findings do suggest that 65 council respondents are now currently updating their wind policies or are intending to do so, the report summary suggests that the same councils have outlined considerable challenges in doing so.   

For those authorities not planning to update their wind policies (ie, not planning to identify suitable areas for onshore wind), some of the key reasons include "resource constraints, landscape or green belt designations, issues surrounding community support or a lack of potential for wind energy." We should add that there’s very limited government guidance as to how these "suitable areas" should be identified.  

Friends of the Earth’s Planning Team appreciates that resource and national guideline constraints remain an issue for councils, especially for plan making. We also recognise that some plan areas will be more geographically constrained (re statutory, landscape or green belt designations), but whether these reasons justify the low 11% take-up rate of "suitable areas" for wind is questionable.   

Implications

The further decline in the number of councils failing to identify "suitable areas" for onshore wind in adopted local plans is important for several reasons.   

Despite multiple local government declarations of climate emergency across England, many of those same authorities are likely to represent the 89% of councils that have failed to identify "suitable areas" for wind energy in their adopted local plan. This fact should be made common knowledge, so the public can question their local authorities and hold them to account.  

In addition, both national planning policy and planning law reaffirm the need for town planning to contribute to both climate change mitigation and adaptation. In law this requirement focuses more on local plan making,6  while the NPPF requires more generally that the planning system "shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure" (para 152).  

It would be a huge shame (and represent a real missed opportunity) if a large proportion of those councils that have pledged to tackle the climate crisis are also, perhaps unknowingly, "failing to plan for or "support" renewable energy infrastructure" as is expected in order to contribute to radical reductions in greenhouse gas emissions. At the same time, we acknowledge that other ways also exist for councils to contribute to radical reductions in greenhouse gas emissions, especially where wind energy capacity is either restricted (either geographically, by planning, national or retained European designations) or where local council political control may require alternatives to onshore wind to ensure compatibility with retained Conservative Manifesto commitments.7

Lastly, despite our continuing efforts, national planning policy (as quoted above) still fails to align itself with amended requirements of the Climate Change Act 2008, namely a 100% net zero reduction in carbon emissions by 2050. It’s clear that renewable energy, including onshore wind generation, is a key means to helping achieve these reductions, with influential organisations like the Climate Change Committee advising the government of its effectiveness to help meet us meet net zero. 

Our view is that despite government inaction at the national policy level, local councils should still be doing all they can to help delivery onshore wind (and other renewables) for future generations. A good example of council action is Stroud Council which, despite being covered in 50% of the Cotswolds AONB, is also accommodating "suitable areas" via draft policy Delivery Policy ES2 Renewable or low-carbon energy generation.

Onshore wind has a potentially significant role to play in delivering cheap, clean, renewable energy while also supporting a transition away from fossil fuels. We can’t rely on NPPF constraints being lifted (including the need for wind applications to demonstrate planning impacts have been fully addressed and have local community backing), so it’s crucial that local authorities take the lead and the proportion of adopted local plans identifying "suitable areas" dramatically increases from the underwhelming 11%. 

Conclusions

Friends of the Earth’s original 2019 research provided a worrying snapshot of the lack of identification of "suitable areas" for onshore wind developing, suggesting only 25% of local plans identifying such areas. The University of the West of England’s more recent findings demonstrate the actual figure is much lower: with only 11% of local plans identifying suitable areas in adopted plans (or alternatively 89% of councils failing to do so). 

Evidence shows low uptake by councils in identifying "suitable areas" under the current NPPF’s restrictive policies and its subsequent requirement for new applications to have been identified in such an area in an adopted local or neighbourhood plan. It’s therefore unlikely that onshore wind generation will occur at the scale required across England, as the CCC has suggested it could be.

Despite the obvious cost-of-living impacts resulting from the ongoing energy crisis, it’s clear that the government continues to constrain one of the cheapest forms of renewable energy. 

While we note more positively that the repowering of existing sites was excluded from NPPF footnote 54 constraints in its last review,8  it’s unlikely there’ll be much improvement on the 11% of adopted local plans that have included them – although the Stroud example at least shows some councils are trying to do so. 

Without more radical action being taken to address the current policy constraints facing onshore wind, its potential to help bring down energy bills and assist the UK in delivering its binding net zero carbon commitments will continue to be unnecessarily restrained.   

Recommendations

Given that council action to try and get around national policy constraints to wind has worsened, Friends of the Earth offers the following recommendations which we consider necessary to enable the future delivery of onshore wind into the UK’s energy mix.   

1. Lobbying for positive reform of the planning system, provisionally in the context of the Levelling Up and Regeneration Bill (LURB), but also other legislation and/ or policy changes so that an amendment can provide a clear and positive national policy framework for onshore wind delivery. 

This would entail deletion of footnote 54 (to paragraph 158 b) of the NPPF, which stipulates that a proposal involving one or more turbines should not be considered acceptable unless "in an area identified as suitable for wind in the development plan and any planning impacts identified by the local community have been fully addressed and the proposal has their backing."9

2. Greater scrutiny by the Planning Inspectorate (PINS) at local plan examinations to ensure local planning authorities are complying as effectively as possible in identifying suitable areas, which are policy stipulations for onshore wind applicants. More onshore wind delivery will better ensure we’re on target to meet binding climate legislation for local plan making (Sc19 Planning and Compulsory Purchase Act, re Climate Change Act 2008) and the government’s binding 2050 net zero target.   

3. Reinstating a lighter touch "Feed-in-Tariff" subsidy for onshore wind that only community groups can access, especially given the ongoing energy crisis. The additional incentivisation of local community wind projects to harvest what is a free and abundant energy resource could prove effective in bringing down escalating energy bills, and in the short term, as well increase the proportion of schemes having local community backing – the other stringent NPPF onshore wind policy test. Failing this, onshore wind is still one of the cheapest forms of energy generation and could still help provide cheaper energy direct to potential host communities.  

4. Until a national policy reversal, greater government guidance and support should be given to local communities to enable them to better influence the direction of travel and content of local and neighbourhood plans, especially linked to accommodating "suitable areas" for wind and other forms of renewable energy.  

5. Greater dissemination and collation of good-practice case studies and best practice on how local authorities have been successful in identifying "suitable areas" in their local plans and how local communities have been able to "back" new applications for onshore wind.  

Until the government introduces a fairer, more balanced, positive, and supportive national policy position for new onshore wind schemes, Friends of the Earth will continue to encourage local planning authorities and communities to identify and bring forward "suitable areas" for wind allocations, where possible.  

• 1With the exception of repowering existing turbines which have come to the end of their lifetime.
• 22019 research into 20 local plans (10 emerging and 10 adopted) showed that only 25% of councils had identified "suitable areas" for onshore wind.
• 3Where para 211 of the NPPF gives “great weight to the benefits of mineral extraction and the economy”, including oil and gas extraction, no such weight exists for renewable energy developments. 
• 4"The impact of the 2015 onshore wind policy change for local planning authorities in England" (2022)
• 5Notwithstanding the other key caveat of the NPPF para 158 that such schemes also need to demonstrate that all local resident concerns have been overcome and that such schemes have the community’s backing. 
• 6Sc19 (1A) duty of Planning and Compulsory Purchase Act (2004), as inserted by the Planning Act 2008 states, “Development plan documents must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority’s area contribute to the mitigation of, and adaptation to, climate change.”
• 7Current WMS and NPPF onshore wind restrictions originated from a 2015 Conservative Manifesto Pledge which is arguably likely to retain support in Conservative majority local plan making authorities.
• 8Paragraph 54 now states: "Except for applications for the repowering of existing wind turbines, a proposed wind energy development involving one or more turbines should not be considered acceptable unless it is in an area identified as suitable for wind energy development in the development plan; and, following consultation, it can be demonstrated that the planning impacts identified by the affected local community have been fully addressed and the proposal has their backing.”
• 9We assume that revocation of Written Ministerial Statement HCWS42 would also be needed should this footnote be removed, as the WMS will still stand.