Powys LDP Consultation Response:
Further Focussed Change: FFC79 Section: Policy RE1
In my capacity as National Assembly Member for Montgomeryshire, I am writing to register my formal objection to the inclusion of Policy RE1, as outlined in Section FFC79 of the Powys Local Development Plan’s Further Focussed Change document.
The reasons why I contend that this policy should not be included in the Proposed Local Development Plan are as follows:-
My understanding is that, as a result of direction from the Welsh Government through a series of “Dear Chief Planning Officers (CPO)” letters, which form part of the suite of documents supplementing Welsh Government Planning Policy Wales, Powys County Council have been effectively directed by the Welsh Government to provide a means by which a combination of the County’s onshore wind and solar energy sources must be used to generate an additional 600 MW of renewable energy, a target over and above the existing TAN 8 renewable targets already in existence across the County area.
The Welsh Government’s presumed means by which the Powys Local Development Plan must achieve this outcome, is through the inclusion of specific policies within the Plan which provide for the designation of geographically defined Local Search Areas (LSAs). Within these designated LSAs, the LDP policy would provide support in principle for either the development of local-authority scale (5MW – 25MW) onshore renewable energy wind schemes or the release of land for the development of large scale solar array schemes, whichever created the greatest renewable energy benefit.
I note that these proposed new LSAs are not only geographically outside the scope of the existing extensive Strategic Search areas as introduced by Planning Policy Wales and its associated TAN 8, but also have energy generation targets associated with them which would serve to increase the renewable energy targets already required to be achieved across the Powys area by TAN 8.
I have grave concerns, not only as to the manner in which this policy approach has been proposed without due regard for the processes of strategic renewable energy policy formulation through national and public debate, but also in respect of the means by which the Welsh Government now seeks to embed this specific policy approach into the Powys Development Plan process at its final “refinement” stage.
The top down nature of these policy revisions and the considerable additional powers which Welsh Ministers are accruing for themselves, especially over small scale renewable energy developments not only serve to undermine local democracy and adversely affect community engagement but severely undermine the credibility of the whole planning process in Wales.
In reality, local opinion will become irrelevant and allowing this policy intervention represents a charter to ensure that major developments can take place anywhere across Powys, indeed across any part of Wales at the instruction of the Welsh Government, regardless of local circumstances or opinion.
This is in direct contrast to the approach taken by the UK Government where an agenda of localism is being adopted and will also put Powys and neighbouring English authorities in direct conflict with one another over such schemes where impact will be cross border.
In addition, it is particularly concerning, in requiring Powys to introduce the designation of LSA into its LDP, that the Welsh Government has not accounted for the very provisions and obligations set out in its own 2015 Wellbeing of Future Generations Act, the Environment Act 2016 and the Historic Environment Act 2016, all of which are proclaimed as being ground breaking in terms of safeguarding the future wellbeing of local people and the sustainable management of resources of their areas.
It is particularly concerning that the manner in which this policy has been derived has not reflected a process which has engaged and guaged local opinion or taken into account the obligations to recognise, publicly test and demonstrate that the natural and cultural resources of Powys are to be used in a sustainable way.
The proposed designation of LSAs in the Powys LDP not only fails to account for critical considerations which underpin the Principles and Objectives embedded in these three Acts but in addition does not provide the supporting evidence to explain and justify why or how these and other important land use issues and significant environmental considerations and constraints have not been accounted for in the derivation of Policy RE1.
In my view, it is clear that there is neither the justification for, nor evidence base to support this proposed policy approach.
Furthermore, in recognising that the transmission of the energy generated to achieve the 600 MW target for these areas, in addition to those linked to the existing SSAs in Powys, are collectively beyond the capacity of the local grid transmission systems in the Powys area, it is incomprehensible how such a policy approach which must demonstrate its sustainable credentials, can be promoted without taking into account the implications of this increased level of generation and the consequential implications on infrastructure and land use.
With National Grid having currently suspended its plans for the Mid Wales Connection Project, it is essential that the LDP should properly consider the impact of the associated infrastructure which would be needed to export this additional surplus energy generated by any new developments. As far as I can gather, the need for or impact for any associated grid connections or enhanced transmission systems does not appear to be a material consideration in the formulation of Policy RE1 or in the subsequent manner in which it would be implemented in the Planning Authority’s Development Management Process.
I have received numerous representations from constituents who have expressed their concern at the potential detrimental impact which the infrastructure associated with the proliferation of onshore wind energy generation and large scale solar farms could inflict on the communities, landscapes, amenities, wildlife, road and transport systems, and the thriving tourism industry of North Powys, the latter being a key economic driver and employer in towns and villages throughout Montgomeryshire.
I further believe that Powys County Council should ensure that its decisions are made in accordance with its own stated objectives as outlined in early sections of the proposed LDP namely that any:
“development which impacts on the landscape must be carefully managed and appropriately designed particularly in terms of visual impact.” (Para (2.4.13).
I therefore register the fact that, in my view, the local authority, in pursuing this new policy approach, has failed to consider whether the introduction of a Local Search Area policy and their geographical definition contravenes and indeed contradicts previous resolutions of the Council which clearly state that there is no further scope in Powys for renewable energy schemes of the type which the Welsh Government is promoting for the area.
Equally, I believe the Policy RE1 approach fails to account for or reflect the requirements of Part 1 of the 2016 Environment (Wales) Act to ensure that the principles of the sustainable management of natural resources of Powys, which aim to protect the integrity and enhancing the resilience of the County’s ecosystems and habitats, and that these resources are not being put at direct risk by the presumed principle that developments within the defined Local Search Areas is acceptable.
I urge Powys County Council to resist any attempt by the Welsh Government to exert undue influence over its Local Development Plan. Submission to such pressures will not only erode local democracy and strip decision making away from elected representatives of the Authority but will also set a dangerous precedent that other Planning Authorities in Wales will be pressurised to follow.
I passionately believe that efforts should be made to ensure that important planning decisions are made closest to the people they affect. These recent interventions by Welsh Government, reflect their desire to further centralise the important powers of elected representatives, thereby denying local people a voice and most importantly eroding the principles of local democracy.
In his letter of 10th December 2015 to all Chief Planning Officers, the then Minister, Carl Sargeant AM, indicated that
“the designation of such areas would” […] “through the LDP consultation process, give communities a say as to where renewable energy developments should be located.”
The final stages of the scrutiny of the LDP is not the time to have introduced a significant change in local energy policy. Major policy issues of this nature are of significant importance and concern to the people of Powys and there should have been a greater opportunity for communities to be consulted.
I therefore repeat that, in my capacity as National Assembly Member for Montgomeryshire, I oppose the inclusion of Policy RE1 as proposed, in the Powys Local Development Plan.
I am grateful for your consideration of my representations and look forward to learning of the outcome of your deliberations.
Kind Regards
Russell George AM / AC
Assembly Member for Montgomeryshire / Aelod Cynulliad dros Sir Drefaldwyn
Shadow Cabinet Secretary for Economy, Transport and Sport /