21 May 2019
In light of the ongoing climate crisis, we need to ensure councils are doing all they can to promote and plan for renewable energy – even under the constraints of national policy.
This paper provides a snapshot of the extent to which suitable areas for onshore wind are being identified in local plans.
Findings are based on evidence taken from 20 local plans: 10 emerging and 10 adopted.
The paper concludes that only a small number of plans identify areas suitable for onshore wind, hampering deployment of this key renewable energy resource.
The paper assumes some basic knowledge of the planning system.
In 2015, the Secretary of State Secretary for Housing, Communities and Local Government radically amended national planning policy for onshore wind by issuing a Written Ministerial Statement, HCWS421 . This states that local planning authorities should only grant planning permission for wind energy development if:
- The development site is in an area identified as suitable for wind energy development in a Local or Neighbourhood Plan.
- Following consultation, it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing.
The statement adds:
“In applying these new considerations, suitable areas for wind energy development will need to have been allocated clearly in a Local or Neighbourhood Plan. Maps showing the wind resource as favourable to wind turbines, or similar, will not be sufficient”.
There has been growing concern among environmental groups, including Friends of the Earth, the Centre for Sustainable Energy2 (CSE) and 10:10 that this policy is making it difficult for new onshore wind energy schemes to come forward in England.
As a result we decided to look at how local planning authorities are responding, focusing on their approach to identifying and allocating suitable areas for wind energy development in local plans3 .
Basis of research and rationale
There is currently a lack of evidence demonstrating that local plans are reflecting the requirements and considerations of the 2015 Written Ministerial Statement (WMS).
A survey carried out by CSE just over a year after the WMS was published indicated a lack of progress.
With new applications for wind turbines unlikely to be given planning permission outside of an identified area for onshore wind, and given the crucial role of wind energy as a key renewable resource, we investigated what progress was being made three years on.
As new turbines now need to be proposed in areas suitable for wind, to what extent are new and adopted local or neighbourhood plans identifying such areas or allocating sites in their plans? Where they are not, are other forms of climate change mitigation or adaptation and renewable energy policies in place?
Both national planning policy and the legislative4 context reaffirm the need for town planning to help bring about “radical reductions in greenhouse gas emissions”5 in line with the Climate Change Act (an 80% reduction in carbon emissions by 2050).
Renewable energy generation forms a key means to achieve these reductions.
Friends of the Earth appreciates that there are other ways to deliver such “radical reductions” in addition to wind energy and that the capacity for wind energy will vary from place to place.
Nonetheless onshore wind has a potentially significant role to play in offering clean renewable energy and in supporting a transition away from fossil fuels, and wind energy is recognised as being one of the cheapest forms of energy currently available6 .
Given the current policy position, an indication of what proportion of local plans adopted and in preparation might be identifying suitable areas for onshore wind is a good indicator of whether future onshore wind provision is more or less likely to be restricted at a local level.
Our research focused on local plan policy making7 to see if suitable areas for onshore wind are being identified.
To meet the WMS requirement8 , we assumed such areas would need to be referenced in a strategic diagram, proposals map or development plan document and link to a local or neighbourhood plan policy.
Policies or guidance in Supplementary Planning Documents or renewable energy (evidence-base) studies suggesting “favourable areas for wind” were not considered, since these documents do not form part of the local plan or neighbourhood plan.
In all, we looked at a sample of 20 local plans: 10 adopted (plans which have been agreed and form the basis for deciding planning proposals), and 10 draft plans (pre-adoption).
We felt that looking at both adopted and draft plans would give an overview of progress made in implementing the new policy.
Looking at draft plans – especially those in the earlier stages of preparation – also leaves open the possibility of engaging with the consultation process. This might entail objecting when a plan does not provide onshore wind or renewable energy allocations without proper justification or, conversely, supporting an approach which positively plans for renewable energy.
Our sample of 20 plans was stratified – we tried to reflect a variety of circumstances, geographical size and location, rural/urban make-up, and differing extents of statutory and non-statutory policy constraint.
As a desktop project, we utilised qualitative research methods, analysing plan policies. Telephone conversations with some authorities were needed to clarify our understanding of proposed or adopted policy wording.
From this we ascertained whether each plan was or was not identifying suitable areas for wind energy.
For the purposes of our analysis, we reached a view on whether a plan reflected the requirements of the WMS9 .
Wider local authority context
In addition to noting whether allocations had been made or suitable areas identified (and detailing the relevant renewable energy policy), we also noted some other key local authority information, to better contextualise the results.
For example, smaller urban plan areas with nearby restrictive statutory designations might well be constrained from bringing forward allocations compared to larger rural districts with fewer designations.
Where possible we tried to reflect the variety of different circumstances and noted key constraints, geographical makeup and the size of each authority.
Details included statutory landscape designations (eg, Areas of Outstanding Natural Beauty and National Parks), key biodiversity constraints (eg, European sites), as well as green belt restrictions (where applicable) for each plan area. The size (in square miles) of an authority area was also recorded.
Of the 20 local plans examined by Friends of the Earth:
- Five authorities (a quarter)10 had identified suitable areas for wind development within either advanced draft or adopted local plans.
- 12 authorities11 (over half) did not identify suitable areas for wind development, stating either that they are not identifying such areas or will leave it for prospective Neighbourhood Plans to identify local areas/sites12 .
- Three authorities13 intended to identify suitable areas in forthcoming allocations documents, although their progression could take from 1-3 years to be adopted.
NB 6 authorities identified areas of potential wind development in their evidence-base documents (eg, Renewable Energy Study or similar14 ). However, since these areas were not identified in their respective local plan we considered these plans fell short of the WMS requirement.
We would caution that the following observations are based on a small sample size and representative conclusions need further extensive research.
However, to the extent that our findings corroborate other research, such as by CSE, they shed light on the approach some planning authorities are taking.
Other important key cross-cutting factors warrant consideration, but were not investigated. These include the extent of all restrictive planning designations, the political make-up of each council, the presence of RAF bases (eg, Air Defence and Precision Approach Radar), National Air Traffic Services radar and the extent of existing wind turbine coverage in an area.
Geographic size of the local authority area
It appears that the size of a local authority area does not dictate whether wind energy sites or areas will be allocated.
Some of the largest authorities failed to allocate any sites or identify areas for onshore wind. These include Cornwall (1376 square miles), Craven (454 sq mi) and Stratford-upon-Avon (377 sq mi). Compare to smaller plan areas which do identify suitable areas, such as Melton (185 sq mi), Chesterfield (66 sq mi), Rochdale (64 sq mi), as well as Blackpool (13 sq mi).
While this suggests that smaller-sized local authorities are more likely to identify suitable areas for wind, research with a larger sample is needed to show whether this is a factor.
Statutory Planning Constraint
1. Landscape designations
We considered whether key statutory landscape (AONB and National Park), ecology (SPA, SAC, Ramsar) and non-statutory (eg, green belt) designations might reduce opportunities for identifying suitable areas for wind15 and there did seem to be some correlation.
Of the 12 local plans in our sample that did not identify suitable areas or propose allocations, seven were within or adjacent to AONBs.
This could be a key factor in limiting the ability of these authorities to meaningfully identify areas for wind, although a larger sample is needed to draw firm conclusions.
In our sample of 20 local plans, the presence of statutory ecological designations appears to be less important in preventing turbine allocations coming forward.
At least two plans considering identifying areas suitable for wind (Carlisle and Blackpool16 ) also have Special Protection Areas (SPA) or Special Areas of Conservation (SAC) either within or adjacent to their plan areas.
As each SAC is protected for different reasons, namely geological or habitat, there may well be justified reasons why some authorities were prepared to identify areas suitable for wind despite the presence of these European designations, while others weren’t.
3. Green belt
Some local authority areas had substantial green belt designations within their plan areas, which could restrict their ability to identify suitable areas for onshore wind (especially as the benefits of renewable energy from wind do not always outweigh harms to the openness of the green belt and other harms).
It’s therefore likely this has played a part in explaining why planning authorities with substantial green belt constraint have not identified suitable sites or brought forward wind allocations.
4. Urban or rural
Those plans that contained principally smaller urban areas (eg, Cambridge and York) usually did not allocate areas for wind. With minimum distance restrictions to houses and settlements (eg, noise, visual and landscape impact), it makes sense that neither of these urban areas had identified suitable areas.
These plans can however still deliver the National Planning Policy Framework’s (NPPF) call for “radical reductions to greenhouse gas emissions” in other ways, and we note both authorities have proposed other policy means to achieve climate change mitigation and adaptation.
In addition, while it may be harder for urban areas to identify areas for wind power compared with their rural counterparts, there may be urban authorities and communities who are proposing allocations or failing that, turbines in conjunction with a specific development proposal.
However, our sample did not identify examples of the former in urban authorities and consideration of site allocations policies for other types of built development (for example, mixed use) did not form part of our study.
5. Provision for other types of renewable energy
As well as considering whether plans in our sample identified areas suitable for onshore wind, we also asked whether local plans encouraged other types of renewable energy.
As mentioned above, councils can meet legislative and policy requirements for renewable energy generation in different ways.
For example, the European Union Renewable Energy Directive (which requires the UK to generate 15% of its energy from renewable sources by 2020) does not specify the type of renewables such energy generation should come from.
In this context, it would be too simplistic to suggest those local authorities not identifying suitable areas for onshore wind are failing the Directive or the UK planning duty to ensure planning policies deliver on climate change mitigation and adaptation.
This is especially relevant for authorities that are heavily restricted by their urban make-up or some examples of the planning constraints provided above.
As long as suitable and strong climate change policies are included, we assume it is very likely that the plan-making authority would still be in compliance with relevant EU Directives and national regulations and policy requirements.
At the time of writing, new wind energy schemes can only come forward as part of a “suitable area for wind energy development” within a local or neighbourhood plan, according to the 2015 WMS on wind.
Our results provide a snapshot of progress made by a small selection of planning authorities to identify suitable areas, from a review of emerging and adopted local plans.
Of the 20 authorities we looked at, only a quarter of plans either included or proposed to identify suitable areas for wind energy.
A further three planning authorities were seeking to identify suitable areas in forthcoming Site Allocations Development Plan Documents (which form part of the local plan).
However, timeframes for bringing these documents forward are likely to be medium to long term. More worryingly, over 60% of plans we looked at were not planning to identify suitable areas for onshore wind, with some authorities relying on the optional Neighbourhood Plan process to progress such allocations.
There appears to be no consistent rationale to explain whether suitable areas have or have not been identified.
Those authorities identifying suitable areas differed in size, the presence and extent of planning constraints (including European sites) and geographical make-up (et al).
Some smaller authority areas with both European and other statutory constraints did identify or were proposing to identify suitable areas for wind in forthcoming plans.
Yet some of the larger authority areas lacking significant landscape or biodiversity constraint also failed to identify areas suitable for wind energy development.
As expected, more intensified urban areas were unable to identify areas for turbines, principally due to limited land being available for such development. These councils usually promoted other types of renewable energy or had other climate change mitigation policies in place.
We found considerable variation in local plan approach for renewable energy generation.
While all plans usually contained policies that contribute to climate change mitigation and adaptation objectives (as required by statute17 ), actual policy content varied significantly as to how these objectives would be delivered.
Some local plans omitted any reference to stand-alone renewable energy generation, although as mentioned above, may still be compliant in other policy areas.
While the size of our sample is limited, our findings give cause for concern. Only local plans (or neighbourhood plans) that identify suitable areas for onshore wind can enable the future delivery of onshore wind applications18 . However, very few local plans we looked at appear to have identified or to be considering identifying such areas.
Under existing national planning policy it is difficult to see how new onshore wind proposals can come forward in the absence of suitable areas identified in plans.
At the same time, there is no requirement for local planning authorities or groups preparing neighbourhood plans to identify areas suitable for wind.
But unless they do so, it will be difficult or impossible for schemes to receive approval from the local planning authority.
If our findings are indicative of a broader trend affecting local plans (and neighbourhood plans) as a whole – and they may well be, given research carried out by others such as CSE – we envisage very few onshore wind turbines coming forward for the foreseeable future or until such time as the government sees fit to amend the NPPF to provide a robust planning framework for wind.
Given the current restrictive national and local plan policy landscape now in play, Friends of the Earth make the following recommendations, which we consider to be necessary to facilitate delivery of onshore wind:
1. Reform the planning system so that it provides a clear, positive planning framework for onshore wind power.
2. Delete footnote 49 (to paragraph 154 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 backing19 .
3. Require or incentivise planning authorities to carry out a comprehensive assessment of the scope for all renewable technologies in their area, including onshore wind, and to plan accordingly.
4. Encourage greater local plan interventions to remind authorities of the need to comply with EU Directives on Renewable Energy, as well as national legislation for plan-making.
5. Reinstate a more competitive Feed-in-Tariff subsidy for onshore wind to take-up.
6. Guidance and support should be given to local communities to enable them to influence the direction and content of local plans and neighbourhood plans including the ability to accommodate wind and other forms of renewable energy.
7. Greater dissemination and collation of good-practice case studies and knowledge, for example the RTPI/TCPA guide20 .
Until the government revises national policy to provide a planning system that is positive and supportive of onshore wind, Friends of the Earth and other stakeholders should continue to encourage local authorities and communities preparing local or neighbourhood plans to identify and bring forward suitable wind allocations.
Further research to see if our results are borne out in a bigger sample of plans would also be worthwhile. This would enable exploration of barriers and opportunities, best practice, and policy changes and levers necessary to provide a favourable planning framework for onshore wind.
- 3Since our research was carried out a new National Planning Policy Framework has been published. This broadly sets out the same policy approach as the WMS.
- 4Sc19 (1A) duty of Planning and Compulsory Purchase Act (2004), as inserted by the Planning Act 2008.
- 5National Planning Policy Framework: both the original 2012 and revised 2018 (Para 148 – 2018) and 2019 versions call for “radical reductions in greenhouse gas emissions”. Footnote 48 adds that LPA mitigation and adaption policies should be “in line with the objectives and provisions of the Climate Change Act 2008”.
- 6Drop in wind energy costs adds pressure for government rethink, Guardian 23.07.17.
- 7Plans that have either been adopted or are near to being adopted since 2015.
- 8“In applying these new considerations, suitable areas for wind energy development will need to have been allocated clearly in a Local or Neighbourhood Plan” – Para 6 – HCWS42
- 9The WMS requirement forms part of a revised NPPF published July 2018.
- 10Rochdale, Lancaster, Chesterfield, Ashford and Harborough.
- 11Cornwall, West Somerset, Bromsgrove, Stratford-upon-Avon, Derbyshire Dales, Telford and Wrekin, Cambridge, City of York, Craven, Havant, Guilford, and Ashford.
- 12The formation of Neighbourhood Plans isn’t compulsory and so this will not guarantee turbine allocations coming forward at a sub-district level.
- 13Sunderland, Carlisle and Blackpool.
- 14City of York, Stratford-upon-Avon, Carlisle, Chesterfield, Melton, and Harborough.
- 15NB We did not check the presence of significant heritage (such as Grade I and II* listed buildings or Scheduled Monuments), MOD or NATS radar constraint (data unavailable) or other localised factors that might also have a bearing on the ability to identify such areas, such as road network widths, the presence of bats or breeding birds, local landscape sensitivity and capacity etc.
- 16Blackpool has a very small plan area (13 square miles).
- 17Sc19 (1A) duty of Planning and Compulsory Purchase Act (2004) as inserted by the Planning Act 2008.
- 18With the exception of repowering of existing turbines, which can come forward outside of allocations. See NPPF3 para 154(b) – footnote 49.
- 19Revocation of Written Ministerial Statement HCWS42 would also be needed should this footnote be removed