Planning, building and the environment

Review of Planning Policy Statement 22 (PPS22): Renewable energy policies in emerging development plans

The nature of the review

In March 2006 the ODPM (now Communities and Local Government) examined 121 emerging development plans that had been referred to Government Offices in accordance with statutory requirements. The purpose of the review is referred to in Hansard as:

to determine whether there is a problem with emerging plans that do not fully incorporate PPS22 guidance. (Hansard 9 February 2006, Column 84)

This undertaking was given by the Government on 9 February 2006 during the Committee Stage of the Climate Change and Sustainable Energy Private Members Bill. The particular issue was whether emerging plans contained a policy that reflected paragraph 8 of PPS22 which says:

8. Local planning authorities may include policies in local development documents that require a percentage of the energy to be used in new residential, commercial or industrial developments to come from on-site renewable energy developments. Such policies:

(i) should ensure that requirement to generate on-site renewable energy is only applied to developments where the installation of renewable energy generation equipment is viable given the type of development proposed, its location, and design;

(ii) should not be framed in such a way as to place an undue burden on developers, for example, by specifying that all energy to be used in a development should come from on-site renewable generation.

Further guidance on the framing of such policies, together with good practice examples of the development of on-site renewable energy generation, are included in the companion guide to PPS22.

The Findings

  • since PPS22 was published in August 2004 121 emerging development plans have come forward in England
  • 29 of these were new style plans where a policy reflecting paragraph 8 of PPS22 could reasonably be expected
  • 90% of those new-style plans (26 out of 29) did include a paragraph 8 policy
  • a further 13 old-style plans also included paragraph 8 policies.

121 plans, coming forward since August 2004, were examined to see whether they contained a policy reflecting the advice in paragraph 8 of PPS22. The detailed results are set out below.

Of the 121 plans, for 69 of them it was considered reasonable to expect  a paragraph 8 policy to be included. 39 out of the 69 plans did contain policies that reflected paragraph 8. (See end of document for reasons why such policies might not reasonably be expected).

Of the 39 policies reflecting paragraph 8 of PPS22, 26 were new-style, which represented 90% of the 29 plans where such a policy could reasonably have been expected.

For the remaining 52 plans where it was not considered reasonable to expect a PPS22 paragraph 8 policy, 27 were new style plans and 25 old style plans.

Overall 56% of the plans referred to Government Offices between August 2004 and February 2006 that could reasonably have been expected to contain such a PPS22 policy did so.

The exercise only considered emerging plans referred to Government Offices after August 2004. Therefore, it would not have captured those plans adopted or which had already been referred for the final time before that date. Some such excluded plans (eg Merton and Croydon) did contain such policies.

New-style plans (56 plans)

(Regional Spatial Strategies (RSS), Local Development Frameworks (LDF) - Local Development Documents (LDD), Development Plan Documents (DPD))

(i) with paragraph 8 policies (26 plans):

Yorkshire and Humber draft RSS
East of England draft RSS
North East draft RSS
Bedford Core Strategy DPD
Huntingdonshire Core Strategy DPD
South Cambridgeshire Development Control Policies DPD
South Cambridgeshire/Cambridge City (Cambridge East Area Action Plan) DPD
Breckland Core Strategy / Policies DPD
Newcastle under Lyme (Knutton Area Action Plan) DPD
Lichfield Development Control Policies DPD
Blyth Valley Core Strategy and Development Control Policies DPD
Darlington Core Strategy Preferred Option DPD
Middlesborough Core Strategy Preferred Options DPD
Redcar and Cleveland Core Strategy Preferred Options DPD
South Tyneside Core Strategy Preferred Options DPD
Ryedale DC Core Strategy DPD
Doncaster MBC Core Strategy Preferred Options DPD
Hambleton DC Development Policies DPD Preferred Options DPD
Wakefield Core Strategy and Development Control Policies DPDs
LB Tower Hamlets Core Strategy and DC DPD Preferred Options
LB Newham Draft Preferred Options for Core Strategy DPD
LB Hillingdon Core Strategy Preferred Options DPD
Surrey Heath Core Strategy Preferred Option DPD
Woking Core Strategy Preferred Options DPD
West Berks Core Strategy Preferred Options DPD
Gloucester City Council DC DPD Preferred Options DPD

(ii) without paragraph 8 policies (3 plans)

Runnymede Core Strategy DPD and Development Control Policies DPD
Havering Core Strategy Preferred Options Report
Alnwick DC Core Strategy DPD and Development Control Policies DPD

(iii) where a paragraph 8 policy was not present but it was judged that such a policy can still be included in the authorities later LDDs (27 plans)

Stafford BC Preferred Options DPD
Cannock DC Core Strategy Issues and Options DPD
Staffordshire Moorlands DC Area Action Plan DPD
Chelmsford Core Strategy DPD
Broads Authority Core Strategy DPD
Southend-on-Sea Core Strategy DPD
Barnsley MC Policies Preferred Options DPD
Lancaster CC Core Strategy Preferred Options DPD
Blackburn with Darwen BC Core Strategy DPD Preferred Options DPD
Rossendale BC Area Action Plan Preferred Options DPD
Bracknell Forest Core Strategy DPD
Chichester Core Strategy Preferred Options DPD
Crawley Core Strategy Preferred Options DPD
Epsom and Ewell Core Strategy Preferred Options DPD
Horsham Core Strategy Submission DPD
Reading Core Strategy Issues and Options
Slough Core Strategy Issues and Options
Waverley Core Strategy Preferred Options DPD
Windsor and Maidenhead Core Strategy DPD
Wokingham Core Strategy LDF
Tynedale DC Core Strategy Preferred Options DPD
Hackney Core Strategy Issues and Options Consultation
Hammersmith and Fulham Issues and Options Consultation
Kensington and Chelsea Planning Policies Issues and Options
Redbridge Preferred Options Report, Borough Wide Primary Policies 
Richmond upon Thames LDF Issues and Options Consultation
Sutton Preferred Options DPD

Old-style plans

(Local Plans, Unitary Development Plans (UDP))

(i) with paragraph 8 policies (13 plans)

Warwick Local Plan
Cambridge City Local Plan
Luton Adopted Local Plan
Calderdale Replacement UDP
Oldham MBC UDP
Gateshead MBC UDP
North Somerset Local Plan
Lambeth Replacement UDP
Southward Revised Deposit UDP
Greenwich UDP
Haringey UDP
North Warwickshire Local Plan
Rugby Local Plan

(ii) without paragraph 8 policies (27 plans)

Walsall MBC Local Plan
Wolverhampton CC Local Plan
East Staffordshire DC Local Plan
Malvern Hills DC Local Plan
Redditch BC Local Plan
Bridgnorth DC Local Plan
Nuneaton and Bedworth
Basildon District Replacement Local Plan
Braintree District Local Plan Review
Broadland District Local Plan
East Hertfordshire Local Plan Review
Epping Forest Local Plan
Rochford District Replacement Local Plan
St Edmundsbury Local Plan Review
Tendring District Replacement Local Plan
Copeland BC Local Plan Review
South Oxfordshire Local Plan
Vale of the White Horse Local Plan Review
Wansbeck DC Local Plan
City of Leicester Replacement Local Plan
West Lindsey DC Local Plan
South Holland DC Local Pan
Chesterfield BC Local Plan
NE Derbyshire DC Local Plan
Notts CC Nottinghamshire and Nottingham Joint Structure Plan
North Wiltshire DC Local Plan
Swindon BC Local Plan

(iii) where a paragraph 8 policies could not reasonably have been expected (see possible reasons below) (25 plans) 

Herefordshire UDP
Babergh Local Plan Alteration
Harlow Replacement Local Plan
Suffolk Coastal Local Plan 2nd Alteration
Hertfordshire CC Minerals Local Plan Review
Norfolk CC Waste Local Plan Review
Basingstoke and Deane Local Plan Review
Bracknell Forest Local Plan Alteration
Brighton and Hove Local Plan
East Sussex CC and Brighton and Hove Waste Local Plan
Gosport Local Plan Review
Rother DC Local Plan
Test Valley Local Plan Review
West Oxfordshire Local Plan Review
Hartlepool BC Local Plan
Rushcliffe BC Replacement Local Plan Revised Deposit Draft
Northants CC Waste Local Plan
Kingston upon Thames UDP
Isles of Scilly Local Plan
East Devon Local Plan
Weymouth and Portland Local Plan
South Gloucestershire Local Plan
Bath and NE Somerset Local Plan
West Dorset Local Plan
Cheltenham BC Local Plan

The above plans would not reasonably be expected to include policies on on-site renewables for a variety of reason which include that they:

  • were specialist waste and minerals plans
  • were partial alterations of existing plans
  • were 'old style' plans in the final stages of preparation when PPS22 was published. Incorporating a policy which was more compliant with paragraph 8 in such plans would have been likely to result in serious delays in their adoption and delayed the move to the new style plans required post September 2004.

Published June 2006

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