The NNSOC and the Northumberland branch of CPRE comments on Northumberland Local
Plan
Core Strategy Pre-Submission Draft October 2015 (“the October 15 Draft”)
The Northumberland Environmental Policy Group of the Northumberland & Newcastle Society and
the Northumberland Branch of CPRE are principally concerned with Policies 65 and 66 of the
October 15 Draft.
We continue to support the criteria-based approach taken by these policies but consider that the
renewable energy section of the Full Draft Plan is unsound because it fails to properly recognise
the impact of the 18th June WMS which represents an important change in government policy as
explained in the amendments to the NPPG, in turn applied by the Planning Inspectorate and the
Secretary of State in subsequent appeal decisions.
In short, government policy now distinguishes “on-shore wind” from other “renewables” and for the
Plan to be “sound” that distinction must be fully recognised (the provision of a separate policy
(Policy 66) dealing with “on-shore wind” pre-dates the WMS and does not, by itself, make the
required distinction or enforce the new prerequisites now evident in and required by government
policy).
As para 1.2 of the October 15 Draft explains: “For this stage responses must be based around the
'Tests of Soundness' that require the Core Strategy to be 'Positively Prepared', 'Justified',
'Effective' and consistent with national policy” (emphasis added).
For instance, para 11.72 of the October 2015 Draft should, we suggest, state (our suggested
amendments are in bold but we have also re-ordered the paragraph and, for consistency, imported
words regarding the WMS from later in the October 15 Draft):
“Reflecting current national planning policy as amended by the Ministerial Statement issued by
the Secretary of State for Communities and Local Government on 18 June 2015, the
approach to renewable and low carbon energy in Northumberland is to provide a positive policy
framework recognizing that it can make a valuable contribution to slowing down climate change,
meeting energy needs and improving energy security but that a distinction is to be drawn
between wind energy developments and other sources of renewable energy.
The above mentioned Ministerial Statement and the subsequent updates to the National
Planning Policy Guidance state that local planning authorities should only grant planning
permission for wind energy developments if:
The development site is in an area identified as suitable for wind energy development in a
local or neighbourhood plan; andfollowing consultation, it can be demonstrated that the
planning impacts identified by affected local communities have been fully addressed and
therefore has their backing.
Criteria-based policies, to be read subject to those prerequisites, are proposed which set out
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that renewable and low carbon energy proposals will be supported if:
(1) in the case of proposals for wind energy development: (a) the development site is in an
area identified as suitable for wind energy development in a local or neighbourhood plan;
(b) following consultation, it can be demonstrated that the planning impacts identified by
affected local communities have been fully addressed and therefore has their backing; and
(c) the applicants are able to demonstrate that the effects on the environment and local
communities are otherwise acceptable; and
(2) in the case of proposals for other renewable and low carbon energy, the applicants are
able to demonstrate that the effects on the environment and local communities are
otherwise acceptable.
The NPPF (which is to be read in conjunction with later guidance – in this case the NPPG
as amended following the Ministerial Statement) advises Local Planning Authorities to
consider identifying suitable areas for renewable and low carbon energy sources, and
supporting infrastructure where this would help secure development of such resources.”
We believe that it is better, when quoting the NPPF, to do so accurately and that it is also clear
that:
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There is no legal obligation to “identify suitable areas” (as the Council accepts);
Any decision to identify such areas should be subject to public consultation;
If the decision is made to undertake such an exercise, areas which already accommodate
substantial wind energy development at or near earlier indications of capacity should be left
out of the exercise (to include them would waste resources);
The methodology of any such process should also be subject to public consultation.
Para 11.73 of the October 15 Draft is also incorrect because, as the Council has expressly
confirmed, no decision has been made on whether to so identify such areas and no brief has been
prepared for that exercise. The position should therefore be made clear and the wording amended
along the following lines:
“However, in light of the Ministerial Statement and the amendments to the National Planning
Practice Guidance, the public will be consulted on whether and if so to what extent and how the
identification of suitable areas should be undertaken. If such areas are identified their treatment,
taking account of the criteria otherwise to be applied, would be explained in a specific
Development Plan Document”.
Para 11.77 also requires amendment to make clear that the feedback referred to preceded the
18th June WMS.
Dealing with Policy 65, we suggest the following amended introductory paragraphs preceding the
criteria (amendments to the main text are in bold):
“Policy 65
Renewable and low carbon energy development
In plan-making and assessing development proposals, the strategy for the development of
renewable energy and low carbon energy development is to support and encourage proposals in
appropriate locations in order to contribute to energy generation and a reduction in emissions of
greenhouse gases, recognizing that a distinction is to be drawn between wind energy
developments, where government policy sets two initial pre-requisites (that the
development site is in an area identified as suitable for wind energy development in a local
or neighbourhood plan; and that, following consultation, it can be demonstrated that the
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planning impacts identified by affected local communities have been fully addressed and
therefore has their backing), and other sources of renewable energy.
Subject to the first prerequisite, support will be given to renewable and low carbon energy
developments where there is clear evidence that proposals are community-led and supported
such that the second prerequisite is met.
Subject to both those prerequisites, through the development management process,
applications will be supported where it has been demonstrated that the environmental, social and
economic benefits of the proposal clearly outweigh any adverse effects, individually or
cumulatively, on local communities and the environment. In considering applications, appropriate
weight will be given to the following: .......”
Our point is that there is no point in Policy 65 (which applies to all renewable energy proposals)
“encouraging or supporting” a proposal that fails to meet prerequisites applied to it by government
policy. To do so would be inconsistent with government policy and, accordingly, unsound.
Para 11.90 of the October 15 Draft is also in need of amendment. We suggest the following
(again, amendments are in bold):
11.90 Whether a proposal has the backing of the affected local community is a planning
judgement for the local planning authority. It is considered that the application of the criteria in the
policy will assist in enabling this judgement to be made noting that the planning impacts
identified by affected local communities must be fully addressed, the test not being one of
mere acceptability. As referred to above consideration will be given to whether and if so to
what extent and how areas suitable for wind energy should be identified and if it is
considered to be appropriate to take this approach a Development Plan Document will be
prepared to identify such areas.
Further on the issue of detailed guidance which may be expressed in a Supplementary Planning
Document (SPD), we note that the scope and criteria for this document remain undefined and it is
unclear how, if undertaken, this work will be scoped and commissioned and how far it will be
subject to proper public consultation.
Para 11.83 of the October 15 Draft states:
“The Council has undertaken a study to understand the landscape and visual effects of the current
operational wind farms in Northumberland. The conclusions of this study work recognise the
importance of considering the effects on long and medium range views from and to iconic
landscapes and heritage assets and the outlooks for heritage assets. This is recognised in the
policy. The study also made recommendations for additional guidance on the planning application
process which will be addressed in the SPD that is to be prepared.
The Society congratulates NCC on procuring what we believe is an important piece of research
which explicitly supports criticisms of visualisations which we, and others, have made to the
authority over a number of years and confirms the factual basis of the concerns which informed
the debate that took place in the House of Lords in the summer of 2014.
However, we are concerned that the full implications of this report are not adequately reflected in
the October 15 Draft. In particular the conclusions that:
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The potential for harmful adverse cumulative landscape and visual and character effects is
however increasing, and in more sensitive locations, significant. Landscape capacity may be
close to its thresholds in parts of the county.
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Adverse effects upon important views and vistas from some of Northumberland’s most
distinctive and important landscape and heritage features have been identified. In particular,
inland vistas from the Northumberland Coast Area of Outstanding Natural Beauty (AONB), and
particularly from some of its outstanding heritage assets (in particular the coastal Castles) have
been eroded as has its wider landscape context and sense of remoteness [Executive
summary, p. 9].
The findings support the view that Northumberland has no significant further capacity for major
onshore wind developments without causing major damage to iconic landscapes and heritage
sites.
Likewise, we believe that para 11.84 of the October 15 Draft deserves comment. It states:
“Another area of concern identified during the consultation process has been the potential impact
of wind farm development on the tourism economy in Northumberland.
Northumberland’s landscape, natural and historic environment and tranquillity are a key draw for
visitors. Inappropriate wind turbine developments have the potential to adversely affect these
assets and could therefore impact on the tourism economy, if people are dissuaded from visiting/
returning. In light of the concerns expressed, the Council commissioned two pieces of work (156)
to help understand the effects of onshore wind farms on tourism to inform the policy in the Core
Strategy.”
The Society and CPRE remain concerned that the Tourism Study is deeply flawed, particularly in
its reliance on desk-based research referencing a handful of outdated studies of small turbines
which bear little relation to large modern turbines or even the subsequent cumulative development
in the areas cited in these historic studies.
The methodology of the desk-top study is questionable, as was noted in a detailed critique of the
study submitted to NCC by the Society.
Returning to the Ministerial Statement of 18th June and by reference also to that from DECC, we
repeat the Society’s concern that their full implications are not adequately reflected in the October
15 Draft.
The then Secretary of State at DECC, Mr Ed Davey MP, acknowledged in 2014 that it was already
clear that the UK would more than meet the 2020 target for onshore wind capacity.
The NPPF states, “that all communities have a responsibility to help increase the use and supply
of renewable and low carbon energy”. However, in the light of revised government policy, realised
renewable capacity in Northumberland and the recognised adverse effects already caused to
Northumberland’s sensitive landscapes and heritage sites, we consider that further onshore wind
development in Northumberland should not be being encouraged and that, in order for the policies
to meet the test of soundness, they must accord with government policy both by distinguishing
between wind energy and other renewable sources and by ensuring that the criteria based
approach of both policies 65 and 66 are subject, in the case of wind energy proposals, to the
prerequisites set by the WMS.
Further, we note that the Council has recently published the report it commissioned from Entec 1.
(We suggest that its findings on the suitability and identification of areas within Northumberland for
wind energy development be treated with great caution because it predates: (1) the revision of
national policy guidance on which it relies (notably the introduction of the NPPG and more
1
Renewable, Low Carbon Energy Generation & Energy Efficiency Study Final Report Feb 2011
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importantly its revision following the 18th June WMS); (2) the Council’s own landscape impact and
tourism studies which, in the case of the former, show how seriously the impact of existing turbine
schemes was misjudged; and, most importantly, (3) the WMS, itself, and the distinction now to be
drawn between wind energy and other renewable energy development.
It has been noticeable that iterations of the draft guidance have been behind the curve in
recognising developing national policy and guidance and the emphasis on other technologies.
Solar PV has only belatedly been covered and the October 15 Draft still fails to recognise the
importance of biomass and biogas technologies nationally and regionally. Greater efforts need to
be addressed to rebalancing strategic guidance to reflect this and to encouraging the development
of alternative technologies.
Submitted through the Northumberland & Newcastle Society
24.11.2015
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