The Renewable Energy Foundation responded to the government’s consultation on proposed changes to the National Policy Planning Framework) which has been updated to make it much easier for onshore wind farms to be approved much more quickly and without local approval as Nationally Significant Infrastructure Projects.

Their response can be found here:

https://www.ref.org.uk/publications/383-ref-consultation-response-on-the-nppf-2024

This is a must read for anyone concerned about the scale of the changes proposed to national planning policy as this gives the government almost limitless power to impose onshore wind farms wherever developers see fit.

Some key comments were as follows:

1. Labour had previously promised to “entrust power with local leaders, who know their area and have skin in the game”. The REF are spot on here as this move goes completely against the drive for devolved power, through local mayors for example.
2. The proposed changes give very little weight to the inevitable economic and environmental dis-benefits of onshore wind.
3. In several areas the REF identify that proposed changes are unreasonable and therefore subject to legal challenge.
4. The REF support the protection of peatland habitats as important for carbon sequestration but highlight that there is a distinct lack of consideration for any other reason for preserving natural habitats. These include no protection for flora, fauna, geological and physiographical habitats.
5. A key point, that we have already picked up on, is that “current planning policy fails to quantify and subsequently demonstrate that the green benefits claimed are actually delivered.” They cite the example of the Viking onshore wind farm which promised to deliver a load factor of 46% but in fact could only manage 16% in its first month of operation. This meant that “the cost of the electricity generated was £199 per MWh compared with the subsidy sought by the company of £67 per MWh (https://www.ref.org.uk/ref-blog/382-newly-opened-viking-wind-farm-taking-nearly-three-times-its-cfd-price-in-august-2024).” And further that applications should be based on a realistic assessment of grid capacity for example.
6. Such unrealistic expectations also mean that carbon payback periods will inevitably be much longer than those quoted based on unrealistic assumptions, to the point where we have to call into serious question whether a wind farm could ever guarantee making this payback. This is particularly the case as it is already known that the Scottish Government Carbon Calculator is known to have serious flaws and is under review.
7. As an aside, the proposed changes remover apparent protection for agricultural land, which is odd given that local farming could be a key tool in reducing carbon emissions.