The government’s Clean Power Plan for decarbonising the electricity grid by 2030 envisages that existing solar capacity needs to treble, and onshore wind to double, by that date. As Local Plan reviews fall due, each Local Authority faces the reckoning for its share of the energy burden.
The South Downs National Park Authority has reached the Regulation 18 stage, about half way through the review process. The draft for consultation makes no reference to the Clean Power Plan, nor to the quantity of electricity consumed within the Park boundaries. It offers little concession to the status quo that major developments such as solar farms or wind turbines are not welcome.
National Parks in the UK are distinguished from most of the rest of the world in that they exist not just for visitors but also for the communities that have always lived there. The problem for grid decarbonisation is that these communtiies consume electricity. And the problem for the South Downs National Park is that its population of well over 100,000 people is nearly three times greater than any of the other UK National Parks.
My view is that the National Park should acknowledge the rationale that every locality should contemplate self-sufficiency in electricity generation, lay out how this could be achieved, and only then deploy its special status to justify lesser ambition.
This is a copy of my submitted comments, with apologies for the use of acronyms and some technical terms.
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I strongly disagree with the draft SD51 Policy. I feel that the National Park should recalibrate its interpretation of NPPF guidelines in order to contribute more to a national goal of energy security, relevant to the cost of living and doing business.
Athough I live just outside the National Park, I compile an annual report on Renewable Energy in Winchester District and engage with planning applications for energy developments which often attract comment from your team.
The LUC evidence report attached to your Policy opens by stating that additional renewable energy is integral to achieving UK net zero by 2050. It doesn’t mention that most of the addition will be sourced by solar and wind – and offers no interpretation of what that might mean for the National Park and its own 2040 net zero vision. No baseline energy data is presented and no future target. The national goal of grid decarbonisation by 2035 (since accelerated to 2030) is mentioned only late in the report and is omitted from your list of “Key Issues” relating to Policy SD51.
In a decarbonised grid scenario, the key data metric for any region is the amount of electricity generated locally in relation to local consumption. Those areas where this ratio is less than 100% will be dependent on electricity imported from other areas. My very rough estimate for the National Park is that it generates less than 10% of the electicity it consumes, and possibly less than 5%.
Your draft Policy, focusing on small-scale and community energy development, is very unlikely to make any difference to this measure, let alone improve it, given that demand for electricity is projected to double by 2050, probably more in affluent rural areas. I’m afraid that identifying just four small sites (less than 1MW) deemed to be “suitable” for renewable energy within such a large area is akin to suggesting that a couple of bungalows would fulfil government expectations for new housing.
I suggest that there are two consequences of this lack of ambition that might justify pause for thought. First, that it will be difficult to present the National Park as net zero in 2040, if it remains almost totally dependent on external sources for clean electricity. Second, that public opinion in districts surrounding the Park will become hostile to the land use differential in a decarbonised grid scenario in the 2030s. The half of Winchester District that lies outside the Park is likely to host an increase in solar farms (above 10MW) from the current seven to more than twenty. And more still by 2050.
The results of the LUC survey of public opinion might have been more interesting if this data had been available.
Of course it is right that the National Park should adopt stricter criteria in considering major developments. But the vast scale of the South Downs Park within the highly populated southeast of the country may strain the optics of the energy divide between those inside and outside.
I find it hard to believe that a determined effort to find suitable sites for 3-4 small solar farms (20MW) and a dozen wind turbines (1.5MW) over such a large area could not be successful. That should more than double all the rooftop and community scheme potential that exists. The relevant NPPF guidelines give you powers to define “major” in relation to developments.
The LUC constraints for suitable sites were tweaked to the limit. For example, the apparent exclusion of land within 1km of road or rail infrastructure conflicts with experience that areas adjacent to well-screened roads and railways make excellent locations – visit Winchester District for examples.
Climate Action – the section of the draft Local Plan covering renewable energy
Renewable Energy Study by LUC, the Evidence Base for the draft Policy