Local authorities and the communities they represent are critical to the success of local and national inclusive growth, and the delivery of much-needed infrastructure.
Dear Infrastructure Planning Team,
I am writing in response to MHCLG’s consultation on streamlining infrastructure planning.
The LGA is the national voice of local government. Our purpose is to strengthen local government so communities thrive. As the consultation rightly highlights, “upgrading the country’s major economic infrastructure – including our electricity networks and clean energy sources, roads, public transport links and water supplies – is essential”.
Local authorities and the communities they represent are critical to the success of local and national inclusive growth, and the delivery of much-needed infrastructure.
Engagement at pre-application stage
Councils are committed to good local place-making and democratic engagement in infrastructure schemes. The proposed removal of the statutory requirement for applicants to consult with local authorities and communities before submitting their application, through the Planning and Infrastructure Bill, may have long-standing implications for areas and their communities.
As the consultation rightly acknowledges, local authorities have “expert knowledge of the local community, businesses and other interests, as well as responsibility for the development of their local area... [and] can use this expertise to support applicants in developing proposals, ensuring local issues are understood and taken into account”.
The pre-application stage, where early but essential engagement is front-loaded between the applicant and statutory bodies, is the vital first step to drawing out fundamental challenges, concerns and opportunities, including community benefit and enhancement associated with any scheme, at a phase where feedback can be readily actioned and negotiated. Removing this statutory requirement, and instead providing guidance for applicants on best practice, may have unintended consequences for both sides of delays at the submission or examination phases of the process – the very thing the Government is seeking to avoid.
If the Government goes ahead with the proposal, any new guidance produced by the Secretary of State must be co-designed with local government so that it most accurately reflects their needs/requirements from applicants in order to fulfil their own obligations as part of the NSIP process through the preparation of Local Impact Reports.
Costs
It is positive that government has committed to enabling local authorities to recover costs for eligible NSIP services, and we urge Government to introduce the required legislation as soon as possible.
Onshore wind
If climate action is going to be achieved in a cost effective and fair way, then localism will need to be considered front and centre. Councils are democratically elected and, as place makers, where critical infrastructure is planned in a local authority area, they need to be consulted early to maximise the potential local benefit and help bring communities along.
Onshore wind projects are not only visually impactful but also bring potential community benefits and shared ownership opportunities to local communities. Early engagement with communities can be beneficial in both the design of the project and the development of meaningful community benefits and therefore government should retain regulations requiring applicants to consult with the local community ahead of submitting a planning application for development proposals for onshore wind projects for more than two turbines, or where the hub height of any turbine exceeds 15 metres.
Councils will need to play an increasingly predominant role in energy systems planning as the local planning authorities, place shapers, conveners of communities and asset-owners. The only exception to the above position of retaining regulations requiring applicants to consult with the local community ahead of submitting a planning application, is where local authorities have identified sites suitable for onshore wind in their local plan, and that local plan has been fully consulted on and approved by the planning inspector.
Given the link between local spatial plans and strategies produced by councils and the overlay of regional system plans, councils are not only keen to be consulted on what is planned in their area but also ready to help, support and create local socioeconomic opportunities.
Concluding remarks
As the Government continues to consider further how to speed up the delivery of infrastructure, the LGA and local authorities would welcome further engagement to ensure that it optimises the speed and deliverability of schemes for local communities. Councils must remain at the heart of the planning process, with the funding, powers, and capacity to ensure that decisions are made transparently and in the best interests of the people they represent.
Yours sincerely,
Councillor Tom Hunt
Chair, Inclusive Growth Committee
Local Government Association