Response to consultation on revised national Planning Policy Framework (NPPF)

The NPPF is an important piece of government policy. It shapes the way development decisions are made – for example on where houses can be built and what sustainable transport arrangements should be made. The current proposals (May 2018) to revise the NPPF include support for Fracking and restrictions on on-shore wind.

Our brief submission to the consultation addressed these two issues:

Onshore wind power developments

The draft text in paragraph 153 and footnote (40) are wrong to make provisions specifically for onshore wind, which have the effect of making it more difficult for developers to get planning permission. This is contrary to the aspiration set out in Para 147 which says (paraphrased) –  that the planning system should help to achieve radical reductions in greenhouse gas emissions.

While para 153 requires that local authorities should approve an application for renewable and low carbon development if its impacts can be made acceptable, footnote 40 penalises developments where more than one wind turbine is proposed. There is no justification for this approach, which will only serve to hinder progress towards the objective set out in para 147.

In contrast, elsewhere in the NPPF, provisions are made to allow large-scale infrastructure developments, like roads, to be permitted on the grounds of compelling public interest, even where significant harm will result to landscape, heritage and biodiversity.

 For instance in para 173 regarding SSSIs, development is generally to be avoided but: “The only exception is where the benefits of the development clearly outweigh both its likely impact (…)”;

and then regarding ancient woodland and trees, “Where development would involve the loss of individual aged or veteran trees that lie outside ancient woodland, it should be refused unless the need for, and benefits of, development in that location would clearly outweigh the loss;

 and again, “development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland) should be refused, unless there are wholly exceptional reasons [49]”

 “49 For example, infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills), where the public benefit would clearly outweigh the loss or deterioration of habitat.”

Given the importance of climate change, we consider the NPPF should take a similar approach to onshore wind turbines as it does to other infrastructure development like roads – that is to allow the public benefit to be weighed against the landscape and other impacts on a case by case basis, rather than there to be a presumption that multiple wind-turbine developments are to be screened out of consideration.

Our view is that avoiding the worst effects of climate change is of such importance that developments that add to genuinely low carbon energy supplies, like onshore wind, should be treated in the same way as other infrastructure projects of national significance.

 Oil, gas and coal exploration and extraction

In the draft para 204, the text states that developing on-shore oil and gas reserves supports the transition to a low carbon economy. In our view, this is far from the truth. Prospecting for, extracting, and in particular, burning oil and gas contributes significantly to atmospheric concentrations of green house gases. This is incompatible with the UK’s statutory obligations under the Climate Change Act, and its moral responsibility to take urgent and effective action to minimise the likely negative effects of global warming / climate change for UK citizens today and in the future.

It is also in direct conflict with the objective set out in para 147 – that the planning system should help to achieve radical reductions in greenhouse gas emissions.

We therefore ask that support for all developments that extend Britain’s use of fossil fuels, including on-shore oil and gas extraction, be removed from the new NPPF