The revised National Planning Policy Framework (NPPF) was published on 24 July 2018, following a consultation on the proposed revisions earlier this year.   In relation to planning for the low carbon future, the revised NPPF is largely unchanged from the consultation draft, except for the following:
  • The revised NPPF now includes an exemption for wind repowering projects from the planning requirements set by the 2015 Written Ministerial Statement for onshore wind.
  • There is clarification that local authorities can set higher energy efficiency standards for new developments in the government’s response to the consultation.
  • The link to local authorities’ policies needing to be “in line with the provisions and objectives of the Climate Change Act 2008” has been fully reinstated back to what it was in the 2012 NPPF, having been watered down in the consultation draft.
A missed opportunity for promoting the low carbon agenda
Overall, the revised NPPF represents a missed opportunity for the low carbon energy sector, with renewed emphasis on economic growth over sustainable development.  For example, a section in the previous NPPF on building a strong, competitive economy contained a reference to “meeting the twin challenges of global competition and of a low carbon future”.  This section has transformed in the revised NPPF to now have no reference to the environment or low carbon.  In particular, it now states that “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development.”In the dedicated climate change section, requirements for local authorities to take a positive approach to renewables are largely unchanged from the consultation draft and slightly weakened compared with the previous NPPF (which arguably was already fairly weak) – for example, the sentence in the 2012 NPPF stating that “local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources” has been deleted in the revised version.  Overall, there are suggestions that local planning authorities should have positive strategies in place and consider energy in relation to new developments, but there is little to require a more proactive approach.  As a result, only authorities with the capacity and political drive to plan positively for low carbon will do so.  This means that, as ever, renewables developers will need to be aware of local politics in assessing the attractiveness of development locations.

As expected, the current policy restriction on onshore wind that is acting as a de facto ban remains unchanged. However, in a change from the consultation draft, the revised NPPF allows an exception for repowering, meaning that repowers can go ahead without being within an area allocated for wind and without the same requirements for community concerns to have been fully addressed. This is a significant clarification for the wind industry.

Other elements of the smart energy revolution are largely absent from the framework, with only brief reference to the need for new developments to ensure an adequate provision of spaces for charging plug-in and other ultra-low emission vehicles and no direct references to electricity storage or other smart infrastructure.

Meanwhile, the NPPF includes strong support for fracking, requiring mineral planning authorities to “recognise the benefits of onshore oil and gas development, including unconventional hydrocarbons, for the security of energy supplies and supporting the transition to a low-carbon economy; and put in place policies to facilitate their exploration and extraction”.

Local authorities can require higher energy efficiency standards
There is one bright spot – the government’s response to the NPPF consultationprovides much sought after clarity that local authorities can include higher energy efficiency standards for new developments in their local plans, stating:
“In particular, local authorities are not restricted in their ability to require energy efficiency standards above Building Regulations.”

This represents a significant opportunity for local authorities to require developments to meet higher standards, provided viability can be demonstrated both at plan stage and in relation to individual developments.

Planning has a positive role to play in our low carbon future
With the exception of allowing local authorities to set energy efficiency requirements, overall, the revised NPPF continues to demonstrate a lack of vision for the positive role that planning can play in the smart energy revolution.

Westminster should consider looking to colleagues in the Welsh Government for inspiration on this; the Welsh Government’s draft Planning Policy Wales: Edition 10which they consulted on earlier this year proposes ambitious requirements for local authorities to deliver proactive local low carbon policies and local targets, as well as considering issues such as a strategic approach to network infrastructure.

However, although the revised NPPF places lower requirements on local authorities in relation to low carbon issues, it does not remove their ability to choose to take a positive approach.  In particular, the revised NPPF reinstates a strong reference to the Climate Change Act 2008 (which was watered down in the consultation version), requiring local plans to demonstrate how their policies as a whole add up to the climate reduction requirements of this act (80% by 2050).  This is a powerful requirement that can be used by local planners to support low carbon policies and to overcome viability challenges from objectors or planning inspectors. (See Planning for Climate Change – A Guide for Local Authorities, TCPA and RTPI for further discussion of this).

Regen, with partners Pell Frischmann, the Landmark Practice and the University of the West of England, is starting work on a project with the Royal Town Planning Institute to understand and promote the positive role that planning can have in achieving a smart energy future.  If you would like to get involved with the project by offering your views, please contact Hazel Williams. Finally, as part of Regen’s management of the Electricity Storage Network, we will be setting up a planning working group for ESN members.

Please contact Rachel Hayes to discuss membership of the ESN and joining the planning working group.

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