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The Nuclear Free Local Authorities have responded to a government consultation about onshore wind by welcoming the proposed lifting of the blanket ban on any new projects in England and by calling for onshore wind to be treated ‘equally’ to other energy projects for planning.
Levelling Up Minister Michael Gove MP has asked Whitehall mandarins to consult over extensive plans to change the National Planning Policy Framework, the national guidelines applicable to planning applications in England.
Under Section 8, there is a welcome proposal to lift the blanket ban on new windfarms first imposed by former Prime Minister David Cameron, with the unwanted rider that new ‘clean’ wind power projects meet certain onerous conditions prior to approval which are not applicable to onshore ‘dirty’ fossil fuel or nuclear developments.
English NFLA Chair, Councillor David Blackburn, who sits on his own Council’s Planning Committee in Leeds, cannot understand the logic:
“Surveys show that eight in ten British people support the development of new onshore wind projects in England, about double the number who support civil nuclear power, and most would be happy to live next door to a wind turbine, unlike a nuclear power plant.
“Many Conservative MPs representing rural constituencies, including Prime Minister Rishi Sunak MP, have opposed lifting the ban stating they fear the ‘blight’ of the countryside, but the government has been forced to do so kicking-and-screaming in the face of a backbench rebellion over the issue.
“Now ministers are attempting to caveat this by making new ‘clean’ wind projects meet vague and onerous conditions to receive planning permission, such as demonstrating they have ‘community support’ and provide ‘community benefits’, when a ‘dirty’ coal mine, fracking site or even a nuclear power plant do not.
“The NFLA has been supportive of the campaign by Possible to lift the ban and wants to see onshore wind receive at least ‘equal’, if not favourable, treatment under planning laws to these unwanted and unpopular polluting energy sources.”
The Department for Levelling Up, Housing and Communities consultation can be found at
https://www.gov.uk/government/consultations/levelling-up-and-regeneration-bill-reforms-to-national-planning-policy
The consultation is open for public comments until 23:45 / 11:45pm on 2 March 2023.
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For more information, please contact Richard Outram, NFLA Secretary by email to richard.outram@manchester.gov.uk or by mobile phone on 07583 097793
Notes to Editors
The campaign by ‘Possible’ to lift the ban can be found at: https://www.wearepossible.org/
The letter submitted to the Department for Levelling Up, Housing and by Cllr Blackburn dated 7 February reads:
Planning Policy Consultation Team
Planning Directorate – Planning Policy Division
Department for Levelling Up, Housing and Communities
Floor 3, Fry Building
2 Marsham Street
London
SW1P 4DF
Response by the Nuclear Free Local Authorities English Forum to the consultation on the Levelling-up and Regeneration Bill reforms to national planning policy.
Dear Colleagues,
I am contacting you as Chair on behalf of the UK/Ireland Nuclear Free Local Authorities English Forum to submit our comments to Chapter 8 – relating to Onshore Wind – of the consultation on the Levelling-up and Regeneration Bill reforms to national planning policy as they impact England alone.
We are living at a time of an acute energy crisis, with many British households being unable to afford fuel bills bloated by the obscene rise in gas prices, and on the brink of irreversible climate change, caused by prolonged overreliance upon fossil fuels which has had a retrograde impact on our planet and the people, fauna and flora which inhabit it. It is abundantly clear that our citizens will need to be able to access domestically generated, affordable, and reliable energy, free of Russian gas or uranium, and without the deleterious environmental impact associated with the consumption of fossil fuels.
Ending our reliance on dirty fossil fuel energy and instead moving towards a truly green energy mix based on generation through the employment of a range of renewable technologies – solar, wind, hydro, tidal, geothermal, biomass, and green hydrogen – coupled with increasing our capacity in a range of innovative storage solutions must represent the most logical way forward to provide Britain with green and affordable energy, and national energy independence. Within that mix there will be a significant part to play for onshore wind, one of the cheapest, most practical and most publicly popular of renewable energy technologies.
That onshore wind is incredibly popular across the UK can be attested to from surveys, where eight in ten people surveyed indicated support for it [1] with strong support in every constituency,[2] in marked contrast to the appetite displayed by these respondents for that faux-green technology, civil nuclear, which only enjoyed half the level of support.
Onshore wind has the virtue of having a minimal carbon footprint, that associated with the manufacture, delivery, erection on site, and ongoing maintenance of the turbine, associated machinery and grid connection, but independent studies have shown that turbines generate enough energy to ‘repay’ the embodied energy within 3 – 6 months.[3] And unlike fossil fuel generation a turbine does not contribute to climate change by directly releasing carbon dioxide into the atmosphere. Consequently, whilst the average Carbon Dioxide emissions from all UK power stations, including coal, gas, nuclear and renewables, are 537 kgCO2/MWh2 that for wind-generated electricity alone over the lifespan of a turbine varies between 4.6 and 10.2 kgCO2/MWh3.[4]
The NFLA therefore totally supports the government in its intention to remove the current blanket block on new onshore wind projects in England to increase green energy generation through the expedient measure of updating the National Planning Policy Framework, but with the caveat that there should be no onerous restrictions applied to onshore wind with the removal of the blanket ban. For the government’s proposals are more restrictive than those which apply to the development of new onshore fossil fuel generators, and in some cases even nuclear fission (for example, in requiring a wind turbine to be sited with ‘support’ from a community when no such precondition is placed upon the development of a nuclear power station). This despite onshore wind having none of the environment impacts of these dirty technologies (atmospheric, watercourse and ground contamination; the potential for serious accidents; the accumulation of radioactive waste and the need for expensive post-operational decommissioning work).
Put simply these restrictions will still make it hard for new commercial businesses or not-for-profit community-led cooperatives to enter the onshore wind market, and perversely such entrants would find it easier to open a new coal mine than erect a wind turbine. The level of popularity for onshore wind suggests that most people and communities are unconcerned by their minimal aesthetic or environmental impact, but somewhat more enthusiastic for their capacity to generate clean power and for the windfall benefits that can accrue for the communities in which they are embedded, so why is there any need for wind to be subject to a separate and more onerous planning regime?
The NFLAs would therefore like to see instead new onshore wind treated in the same way as any other type of local planning application. This means removing, rather than amending, the existing Footnote 54, and ensuring that the new planning regulations are fit-for-purpose by supporting the development of new onshore wind generating capacity and helping supportive communities to build it!
Responding to the relevant questions in the consultation, the NFLAs wish to make the following statements:
Q.41: Do you agree with the changes proposed to Paragraph 155 of the existing National Planning Policy Framework (NPPF)?
The NFLAs strongly wish to see the NPPF encouraging ‘repowering’, that is to say the replacement of obsolete wind turbines at the end of their operational life with more modern turbines on the same site footprint, and believes that this should be the default position with local authorities, developers and community energy groups empowered to ensure that this happens. Repowering is clearly necessary, cost-effective and beneficial. While we agree that it is useful for local plans to address repowering and that local authorities should be encouraged to do this, this local plan process might not be done more often than every five years, and local authorities may not have the time, resources or expertise to include repowering in their plans. Inclusion in a local plan therefore should not be a requirement without which repowering cannot go ahead. In addition, it is not clear what the requirement to address impacts “satisfactorily” will mean in practice, or how developers or community energy groups will demonstrate that they have met this.
Q.42: Do you agree with the changes proposed to Paragraph 158 of the existing National Planning Policy Framework?
The addition of the suggestion to approve in paragraph c) is a positive step. It is not clear what “acceptable” impacts would be in practice, or how it would be demonstrated that this bar has been cleared.
Q.43: Do you agree with the changes proposed to footnote 54 of the existing National Planning Policy Framework?
It is positive that the proposed footnotes 62 and 63 (slightly) lower the almost impassable bar for new onshore wind projects which were in the previous footnote 54. However, the redrafting still sets a higher bar for new onshore wind than for other types of energy development; still fails to provide clarity on how this bar can be cleared, and how communities or developers can show that it has been cleared; and still poses too great a barrier to the new wind power we urgently need. We are therefore concerned that this new wording would still thwart the growth of clean community energy that is needed across the UK and would still block new wind projects that have local support or prevent applications from coming forwards.
Do you have any views on specific wording for new footnote 62?
Our view is that onshore wind does not need a separate planning regime that places greater barriers on it than other types of project; to that end, we believe that this footnote should be removed rather than amended. If the footnotes remain, clarity is badly needed about what is meant by “appropriately addressed” and “satisfactorily addressed” and the level of community support which is required, and how this can be demonstrated in practice.
Please publicly record us as a respondent and notify us of the outcome of the consultation, by email to NFLA Secretary Richard Outram at richard.outram@manchester.gov.uk Thank you.
Yours sincerely,
Councillor David Blackburn,
Chair of the English Forum,
On behalf of the UK/Ireland NFLA Steering Committee
3. 1 http://proceedings.ewea.org/offshore2009/allfiles2/167_EOW2009presentation.pdf
4. DECC 2014 Government Conversion Factors for Company reporting July 2014
