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Published byDorothy Montgomery Modified over 5 years ago
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Using the planning system to enable community energy
Rachel Coxcoon Head of Local & Community Empowerment Centre for Sustainable Energy CSE is a Bristol based charity, established in We do lots of things, which I don’t have time to go into here. I lead a team of people who work on supporting the development of community energy, educating young people through our Bright Green Future scheme, and in strategically engaging with the planning system to deliver a low-carbon future. It’s the role of the planning policy system, and encouraging the community energy sector to use this more effectively, that I want to talk about today.
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The hierarchy of planning
NPPF – national policy Local Plan – Sets out strategic policies for an area. Compulsory. Comprehensive. Neighbourhood Plan – Not compulsory. No requirement to cover all issues. Must be in general conformity with the Local Plan. Not sure what the background understanding is of the broad audience in this room, so this is just a brief look at how the different components of the planning policy system fit together. Local plans are compulsory for local authorities, and they have to cover all aspects of planning (housing, economic growth etc) Neighbourhood Plans are a right under the Localism Act, but you don’t have to make one, and they also don’t have to comprehensively cover all planning. Once adopted they become part of the Local Plan and are ‘owned’ by the local authority. Local Plans have to follow the guidance set out in the NPPF and Neighbourhood Plans have to be in general conformity with the Local Plan. BUT – where the local plan is silent on an issue, Neighbourhood Plans can introduce policies that are in line with the NPPF, so long as they don’t directly challenge a policy in the Local Plan.
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Very simplified view of the planning system in a local area.
Not going to go through this in detail, it’s really just to show that there’s a long and drawn out process to create the local plan in the first place, and for it to be found ‘sound’, huge volumes of evidence and studies have to be produced – and it’s like painting the Forth Bridge – no sooner is it finished than you have to start all over again Once the plan is adopted, any number of other, more detailed planning documents can be ‘hooked’ onto policies within it, to give more steer on how certain policies within the local plan can be delivered. These are known as Supplementary Planning Documents (SPDs), and they have their own drafting, consultation and adoption processes And then there are Neighbourhood Plans – developed at the Parish or neighbourhood level, these again go through consultation, drafting, examination and even referendum before they can be adopted. And once they are, they become a part of the local plan. We are talking serious volumes of evidence and policy paperwork here…. And just to note, as I’ll come back to it later, I’ve put the word consultation in quote marks because the approach to consultation taken by most local authorities is less than ideal, and this has serious consequences for how energy is treated in the preparation of local plans.
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Moving on to how this then gets used in decision-making.
Here’s a planning application, and here’s our planner who has to look at it. As soon as it’s in, and registered, he’ll have to contact neighbours and advertise to any likely affected party. Battle lines are drawn and everyone has 16 weeks in which to make the most noise about whether this thing should go ahead or not. This begins the letter-writing campaign, in support of, and objecting to, whatever the application is. Many of these letters won’t even contain matters that are ‘material’ to a planning decision. They carry no weight at all. Even those that do are set against the mighty weight of the NPPF and any ministerial statements in force, and then the local plan with its policies (that claim to have been consulted on), and for which an evidence base exists, and which may even be supplemented by an SPD and a Neighbourhood Plan that give even more detail. Fundamental problem is that most people writing in, either in support of or against an application, are not fully cognisant of the fact that they are not necessarily being asked whether this thing should happen at all. They may actually be being asked about the details, because the principle of something happening or not is already in the Local Plan. Take a housing example – people write in and say they don’t want houses there. If there’s already an allocated housing site in the plan, then they aren’t being asked if there should be houses there, or even how many. They’re being asked how big, and what colour should the front doors be. And this can feel very disempowering. This fact that the planning documents in force carry so much more weight than the correspondence that comes in during the consideration of a planning application is one of the reasons I am surprised at how infrequently I come across community energy people who are also very active in planning. Getting a supportive policy framework in place could be such a powerful weapon in the community energy armoury, and yet it’s very seldom deployed. The take-away message from this is that if you only get involved in planning when you want to submit an application, or comment on one that has been submitted, you are coming to this party very late, and the amount of influence you have is low.
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Informing or consulting?
Local Authorities have a relatively poor track record in genuine consultation during the plan making process, and are dominated by housing. Neighbourhood Plans end with a referendum – all or nothing. Leads to ‘conservatism’ on pursuing ambitious ideas for fear of losing the whole plan. Genuine consent for a low-carbon future can only be secured through genuine engagement. Not through a D-A-D approach. I mentioned earlier that consultation that goes alongside the development of all types of local plan, but that it is usually less than ideal. Local Authority plan-making consultations are done according to statutory guidance on how to consult, but they often fall far short of genuine engagement and are more about informing local people. The local plan is also the government’s main mechanism for delivering new housing, to the extent that local plans are completely dominated by it. Unless there is SIGNIFICANT POLITICAL WILL or a huge amount of public pressure to consider energy infrastructure, it will barely get a look in. Neighbourhood plan referendums are all or nothing. It’s risky to include something contentious in case it causes the whole plan to fail. At both levels of planning therefore, some serious effort is needed to get people to come up with their own solutions on energy, so that these can be implemented into the policies with confidence that there is genuine local support for them I want to talk about a few ways you could make that happen, one is to introduce you to some tools we’ve developed ourselves, and the other is a suggestion for how you can create the political will to plan for a low carbon future in your area
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Understanding the ‘social gap’
Disjoint between high levels of support for renewables nationally, but strong resistance locally. Gives politicians (and therefore planning officers) an excuse for inaction. Planning policy-making generally ignores values- based considerations. Place attachment Distributive fairness Procedural justice One thing I hear a lot, and which is used a lot in community energy literature and websites, is this claim about the very high levels of support for renewable energy. What is seldom mentioned is that there is strong evidence that this support dissipates when a local project is proposed, a phenomenon called the Social Gap – you can ask 100 people in the street if they support renewable energy and 87% of them will say yes. But this support dissipates (or dissappears) when a local project is proposed – finding the point at which this support disappears is the solution to developing a different kid of energy future. Our contention is that planning policy ignores values-based considerations, and that only by investing in understanding these things better can we move this situation on (possibly the same is true of housing also…). Go right back to the start of time and you find local opposition. Why? No real local consent. NIMBYism is an unhelpful dismissal, and it’s clear that values-based considerations (such as place attachment, distributive fairness and procedural justice are absent from planning policy practices).
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Building genuine consent – Future Energy Landscapes
‘Grounding in place’ Appropriate geographical scale: considers energy infrastructure in real, not abstract terms. Trials resulted in ambitious local energy plans that could be used in Neighbourhood Plan evidence base. So we developed and trialled a new, in-depth consultation process, in which the process of ‘grounding in place’ is a unique and fundamental part. By taking people back to the beginning and really getting them to consider their community and then the energy system, we were able to develop community energy plans that reflect local people’s understanding of what will work, and is acceptable, in the place they call home. The FEL methodology is a deliberative participatory workshop format that helps participants develop their thinking around energy planning, informed by a consciously created and shared understanding of their community. Participants have the time to consider their community in terms of people, organisations, services, landscape and place (and what is important to them about all of these) before being asked to consider appropriate future energy transitions for their community. NOTE: Grounding in place cannot be shortcut, and it does not work at larger spatial geographies (such as whole local authority areas) because people need to relate their FEL community energy plan to the realities of the community dynamics and landscapes where they live. One of the fundamental learnings from this project was that people do not consider their local authority to be local. Therefore, the challenge for local authority polocy planners must be to help communities self-identify what is ‘local’, and build together a patchwork of those local visions into the wider authority strategy.
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Resources l The three Neighbourhood Planning tools can be downloaded from here: The Future Energy Landscapes facilitator resources can be downloaded from here:
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Other Resources l The energy performance Matrix can be downloaded here: The Wind allocations document can be downloaded here:
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Policy 15 – Cornwall Local Plan
“...Particular support will be given to renewable and low carbon energy generation developments that.. are led by, or meet the needs of local communities...; Few LPA’s have adopted policies specifically mentioning community-led renewables Check out Cornwall’s Local Plan and associated SPD: The Cornwall SPD can be downloaded from here: renewable-energy-planning-advice-march-2016.pdf
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If you’re sitting there thinking, I know all this Rachel, I totally agree, but there’s simply no political will to change this where I live, then now’s your chance. There are six months to go to the next Local elections. 270 local authorities are up for grabs. Many of you have a fantastic track record of community energy activity, you’re well known and trusted in your communities. Turnout at local elections is hardly ever over 30%. In a district ward, that could mean you need under 1,000 votes to get elected. You may already have several hundred local members! The revolution starts here! Thursday, 2nd May 2019
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Thank you – questions? .
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