This section compares the NPPF policy on these matters with PPS22 (2004) and relevant section of the annex to PPS1 (2007) – paras 19 – 29.
PPS22 itself is rather out of date so the key comparison is with these sections of the PPS1 Supplement.
The following still relevent sections from PPS22 are not carried over, a development that may alarm some.
local development documents should contain policies designed to promote and encourage, rather than restrict, the development of renewable energy resources (para 1(ii))
local planning authorities should not make assumptions about the technical and commercial feasibility of renewable energy projects (e.g. identifying generalised locations for development based on mean wind speeds). Technological change can mean that sites currently excluded as locations for particular types of renewable energy development may in future be suitable. (1 v)
Development proposals should demonstrate any environmental, economic and social benefits as well as how any environmental and social impacts have been minimised
through careful consideration of location, scale, design and other measures. (1 ix)
Planning policies that rule out or place constraints on the development of all, or specific types of, renewable energy technologies should not be included in regional spatial strategies or local development documents without sufficient reasoned justification (para 1(iii))
The wider environmental and economic benefits of all proposals for renewable energy projects, whatever their scale, are material considerations that should be given
significant weight in determining whether proposals should be granted planning permission. Para 1(iv))
Critically the PPS removes all reference to Megawatt targets, even at a local level. It is difficult then to see how the national policy for increasing renewable energy would translate into delivery on the ground. Unlike housing there is no local incentives structure.
The draft also omits key sections as follows:
local planning authorities should not create “buffer zones” around international or nationally designated areas and apply policies to these zones that prevent the development of renewable energy projects. (para 14)
Local landscape and local nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. (para 15)
As most renewable energy resources can only be developed where the resource exists and where economically feasible, local planning authorities should not use a sequential approach in the consideration of renewable energy projects (for example, by giving priority to the re-use of previously developed land for renewable technology developments). (para 16)
As most renewable energy resources can only be developed where the resource exists and where economically feasible, local planning authorities should not use a sequential approach in the consideration of renewable energy projects (for example, by giving priority to the re-use of previously developed land for renewable technology developments). (para 21)
The 1997 report by ETSU for the Department of Trade and Industry should be used to assess and rate noise from wind energy development (although this urgently needs updating) (para 22)
It is the responsibility of developers to address any potential impacts, taking account of Civil Aviation Authority, Ministry of Defence and Department for Transport guidance in relation to radar and aviation, and the legislative requirements on separation distances, before planning applications are submitted. (para 25)
Comparing the key policy tests of the NPPF to the Supplement
|To help increase the use and supply of renewable and low-carbon energy, local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources||In developing their core strategy and supporting local development documents, planningauthorities should provide a framework that promotes and encourages renewable and low carbon energy generation. Policies should be designed to promote and not restrict renewable and low-carbon energy and supporting infrastructure.|
|not presume against energy development outside mapped areas nor require applicants for energy development to demonstrate the overall need for renewable or low-carbon energy or question the energy justification for why a proposal for renewable and low-carbon energy must be sited in a particular location.||planning authorities should:not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location|
|No equivalent section||ensure any local approach to protecting landscape and townscape … does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances|
|identify and map opportunities for renewable and low carbon energy, based on ecological sensitivity and generation potential;have a positive strategy to promote energy from renewable sources and design their policies to maximise renewable and low-carbon energy development; and identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems.||alongside any criteria-based …consider identifying suitable areas for renewable and low-carbon energy sources, and supportinginfrastructure, where this would help secure the development of such sources, but in doing so take care to avoid stifling innovation including by rejecting proposals solely because they are outside areas identified for energy generation|
|No equivalent section||expect a proportion of the energy supply of new development to be secured from decentralised and renewable or low-carbon energy sources|
The two key changes are:
- Only reference to ecological sensitivity and generation potential, no reference at all to landscape sensitivity and landscape issues
- No support for ‘Merton Rule’ type policies. It is unclear if these are now ruled out pending a new national building standards framework. However currently this is something that can only be secured by planning policy and again it ommission seems contrary to will of Parlimament in the the Planning and Energy Act 2008. The rule could be inflexible however, and some trade off between on and off site generation is needed, especially in high density schemes, and allowing CHP schemes special consideration.