UK planning regimes and their impact on onshore wind deployment

An analysis of the policy frameworks throughout the UK for the delivery of onshore wind.

2 November 2020

In 2015, the new UK Government, led by David Cameron, came to power with a manifesto commitment to withdraw market support for onshore wind. It duly delivered on that commitment, and the deployment of onshore wind was largely limited to legacy projects that had previously gained funding support.

Fortunately, a number of companies and developers devised solutions to overcome that lack of market support, and multiple schemes are currently being constructed without any. This reflects the considerable progress that the technology has made, and just how competitive it has become from a UK electricity-generation perspective.

Last year, the UK Government permitted onshore wind in remote island communities to participate in the last round of competitive market support bidding. Onshore wind, even in these challenging locations, was found to be highly price competitive and a number of schemes were successful in that round. This year, it has been confirmed that onshore wind will be able to participate in the next round of CfD auctions, which will allocate market support for projects in the mid-2020s.

This significant shift reflects the importance of the technology in being able to respond to the challenges of climate change in the most cost effective way. Governments are sensitive to the price of electricity and, in particular, are very conscious of the consequences of price increases for consumers, for whom energy costs represent a significant portion of their expenditure. This combination of price competitiveness and the urgent response to climate change that is required has given a new impetus to the onshore wind sector.

The policy frameworks for the delivery of onshore wind vary throughout the UK and present different challenges to those wishing to bring forward schemes. Scotland has seen the largest deployment of onshore wind and also has the greatest potential for further deployment. Scottish National Planning Policy is very supportive to the further development of onshore wind and, at a national level, operates the equivalent of a traffic light system. Onshore windfarms cannot be located within National Parks or National Scenic Areas. In intermediate areas, such as areas of peatland or wild land, the developer has to overcome that constraint in an acceptable way before schemes can gain consent. This has proved to be a significant barrier to many schemes, but equally there are schemes on the periphery of protected areas or on less important parts of wild land that have managed their way through the system. In areas outwith these controls, there is general support for onshore wind, provided it does not have localised adverse impacts that are unacceptable.

This strong positive framework was further reinforced by the Scottish Government’s Scottish Onshore Wind Policy Statement, which recognises the cost effectiveness of onshore wind and its critical role in responding to climate change. This year, the Scottish Government has reaffirmed its commitment to meeting climate change targets and, in March this year, implemented its new targets. This requires us almost to double the reduction in emissions over the next decade. Onshore wind could play a critical role. Notwithstanding this strong national support, at a local government level, onshore wind has faced ongoing challenges. These primarily relate to the fact that many local authorities have commissioned landscape capacity studies, which tend to focus on restricting onshore wind and often find limited opportunity for further development. This has resulted in ongoing conflict in the consenting of onshore wind in Scotland. Many schemes have to go through expensive Public Inquiry/Appeal procedures in order to gain consent. The Scottish Government is about to revise National Planning Policies. This would be a good time for a refreshed approach to onshore wind. It is suggested that, at a local level, capacity studies should be required to actively seek out the most appropriate areas for onshore wind rather than being negative and restrictive. That simple change of approach would potentially change the dynamic of what is delivered at a local policy level.

Another part of the UK with a significant wind resource is Wales. From the outset, Wales adopted a strategic approach to finding areas suitable for onshore wind, in particular large-scale wind over 25MW. The approach adopted was to identify seven key strategic search areas backed up by a policy note, called TAN8. Most commentators believe this approach has not enabled Wales to maximise its opportunities and as of 2018 just over 680MW of schemes were operational, with a further nearly 400MW consented. It has simply taken too long to deliver onshore in Wales and the history is one of many abandoned schemes where developers have lost patience with the system. Recently, the Welsh Government has revamped the consenting scheme, with it becoming the decision-maker in schemes above 10MW, and adopting a fresh approach to development. A new draft National Development Framework was published for consultation with new targets and a traffic light-based approach to onshore wind. This appears to accept the level of change that might be required to increase deployment in Wales with the identification of extended strategic priority areas. These policy changes will result in increased deployment and there is certainly renewed developer interest in Wales, which offers significant potential.

In England, the policy position regarding support for onshore wind can at best be described as lukewarm. The National Planning Policy Framework is written in a way that makes it almost impossible for new onshore sites to come forward. It requires an area for proposed development to be identified as suitable in the Development Plan. In addition, it must also be demonstrated that the planning impacts identified by the local community have been fully addressed and the proposal has its backing. The consequence is that there has been almost no new deployment of onshore wind in England since 2015. However, the national policy document does provide some hope for one element of new development – the repowering of existing windfarms, which is a specific exclusion of the policy requirement. This is already beginning to be tested and there have been decisions that have been supportive of the view that this does offer a real policy opportunity for deployment. The Kirby Moor decision delivered last year gives real hope about the scope of repowering. This at least affords an opportunity for some level of new generation capacity to be delivered in England. It will, however, remain a challenging jurisdiction for onshore wind developers.

Finally, Northern Ireland has a very good wind resource, and a number of the early UK schemes were constructed there. The Regional Development Strategy 2035 and the Strategic Planning Policy Statement for Northern Ireland recognised Northern Ireland’s significant renewable resources and encourage their exploitation, provided this could be achieved without compromising the environmental assets of acknowledged importance. In addition, PPS 18 on Renewable Energy provides positive support for the deployment of onshore wind, recognising the cost effectiveness of the technology. There has been continued deployment in Northern Ireland and there continues to be strong developer interest in developing further. There is an excellent wind resource and it appears to be a key technology in helping Northern Ireland achieve its climate change policy objectives. One of the challenges in Northern Ireland is that a significant number of the areas suitable for onshore wind development are subject to landscape designations. There are quite a large number of landscape designations within Northern Ireland relative to its geographic scale. Again, it is a jurisdiction where decision-making has been a bit mixed and at times there has not been the political leadership required to carry through the delivery of renewables.

The most critical issue in respect of the delivery of onshore wind is the political will to support its delivery. The history of deployment in the United Kingdom demonstrates that where governments are not wholeheartedly behind the deployment, then decisions tend to move away from consent to refusal. Onshore wind has been a technology that has suffered as a consequence of blunt political decision-making. It is, however, an advanced technology that can deliver renewable energy at some of the lowest costs. In addition, developers are looking to maximise the use of these sites through the deployment of other technologies, such as battery storage, to maximise use of investment in grid. The sector is going to have further opportunities over the next decade, which is now recognised even by the UK Government. Given this change of position, it would be very helpful if the UK and the devolved administrations collaborated to create a sector deal for onshore wind. The sector deal for offshore wind has been highly successful in stimulating the UK supply chain and a similar strategic approach could help maximise the economic benefits from the further deployment of onshore wind.