NPF4 call for ideas: analysis of responses

Energy - Electricity

Proposed key objectives of NPF4: To maximise the contribution of renewable electricity generation to meeting our net zero target in a sustainable way.

There was support for the proposed key objective, although with caveats including that the meaning of 'a sustainable way' should be clarified and that there must be more progress on other technologies in addition to wind, or that there should be a mix of renewables. A whole system, infrastructure-first approach was recommended, with a focus on reduced demand and increased energy efficiency, then meeting residual need from green technologies. The need to align NPF4 with the Energy Strategy was also noted.

Several respondents emphasised the need for NPF4 to make clear that meeting 2030 targets will require a significant increase in the generation of renewable energy with some arguing that, at present, the planning process does not place sufficient focus on responding to the climate emergency. It was proposed that NPF4 should provide explicit support for renewable energy developments as both sustainable and in the long-term public interest and, specifically, that the weight attached to visual impacts in planning decisions should be reduced. Further, it was suggested that the urgency is such that there should be interim policy guidance ahead of NPF4 being finalised to ensure greater weight and priority are given to low carbon energy developments as soon as possible.

National Development status was proposed for National Energy Infrastructure, with a suggestion this should cover the full scope of infrastructure needed including for energy storage, transmission, interconnectors and strategic electric vehicle charging points. National Development status was also suggested for all renewable energy projects over 50MW.

A rather different perspective was that the need for renewable energy must be balanced against the need to protect natural habitats, historic sites, landscapes and communities. Expressing a view that a planning authority should be able to identify areas where there is no further capacity for development, one Local Authority respondent observed that this means accepting that local landscapes are important and that a community's sense of place should not be dismissed when balanced against the need for renewable energy generation.

It was also argued that the existing policy approach of 'the right development in the right place', should continue to be the over-riding principle in NPF4, rather than what was viewed as a risk of 'development at all costs'.

General features of the planning system

Some respondents commented on general features they would like to see in the planning system including:

• Consistency of approach, both between regions and government agencies so developers can be clear on requirements regardless of the planning authority.
• Shorter timescales. It was suggested measures of performance should be introduced to monitor the efficiency of the planning process, for example through adoption of a code of practice or, introduction of statutory timescales.
• Proportionate EIAs. It was suggested the level of detail being requested in EIA reports goes beyond the intention of the relevant regulations. It was also argued there should be a distinction between reporting significant effects in an EIA and the decision-maker's role in determining whether such significant effects are acceptable.

Grid infrastructure

As well as raising issues about planning for specific types of renewable energy (outlined below) there were frequent references to the need to improve grid infrastructure and capacity and for the planning system to provide support for new and reinforced grid infrastructure. However, it was argued that decisions on national grid infrastructure are separate from the planning process, and sometimes the implications of consenting a proposal on grid infrastructure is not clear. A national capacity study was advocated as was retaining the existing National Development status for transmission infrastructure.

Further suggestions included:

• Prioritising renewable developments in areas where existing grid connections are available.
• Consider including transmission companies as statutory consultees for new renewable energy developments.
• Investment in electricity interconnectors with continental Europe - providing access to low or zero carbon sources of generation and selling our surplus energy.

Rather than looking to upgrade capacity of the electricity grid to allow long range transmission with associated losses, it was also suggested there should be investment in local generation of power and moving energy-intensive businesses closer to where the electricity is being generated. Local generation is discussed below.

Energy storage

There were many calls for NPF4 to support development of energy storage capacity. Energy storage was argued important not only to support delivery of power from renewable sources but also to provide additional resilience for the national grid and was suggested to be a National Priority. Ensuring consents for energy storage developments are favourable where located in suitable locations was proposed.

It was proposed that NPF4 should create a policy framework supporting battery storage developments, including relevant considerations such as suitable land use classifications, environmental impacts and impacts on residential amenity.

Specific suggestions with respect to energy storage included:

• This should be required as part of design process for larger projects.
• Storage centres should be established in all new homes.
• Opportunities for retrofitting energy storage capacity to existing windfarms should be considered.

In general, co-location of compatible technologies - typically wind, solar and storage - was suggested to need greater focus.

Issues for specific sectors

With respect to potential sources of renewable energy there were specific references to offshore wind, solar, hydro, tidal, hydrogen, and energy from biomass and from waste, all of which are discussed below. However, the majority of responses on delivering electricity - some of which were very substantial - related to issues around planning policy relating to onshore wind.

Onshore wind

While the importance of onshore wind was often acknowledged, there were differing views on the extent to which it should be prioritised. In addition to the request for explicit support for renewable energy developments referenced above there were calls for the planning system to allow for:

• Presumption in favour of consent for renewable energy projects

Strengthening of the wording or the weight of the presumption set out in the existing SPP were proposed, and that NPF4 should make it mandatory for all planning determinations to explicitly address the application of the presumption in favour.

• Consents in perpetuity

Now issued for 20 - 25 years it was argued consents should be in perpetuity, with limits put in place only if planning authorities demonstrate exceptional circumstances.

• Repowering

It was suggested that NPF4 should provide a definition of repowering and provide considerations when dealing with repowering applications. Presumption in favour of repowering and life extensions were also proposed with a fast track process not requiring a full planning application, but subject to an EIA where required. It was also argued that the baseline for an EIA at a repowering site should be that of the existing wind farm and not a greenfield or fully decommissioned/ restored site.

Further, it was argued consents should no longer include restrictions on total generation, and that developers should be able to deploy within broad physical constraints without requiring to vary consents or to update environmental assessments.

• Extensions to existing sites

Extending sites was argued to make best use of existing infrastructure and so to provide benefits in terms of sustainable development. Less visual impact than a new development was also suggested.

• Modern/taller turbines

Taller towers, larger rotors, and increased blade tip heights should be acceptable, and each site should be assessed on its merit. Further, limited weight should be afforded to scale disparities between existing and proposed turbines when sites are repowered and blade extensions should be supported and considered for permitted development rights. It was argued that some consented but unbuilt capacity may need to be reconsented with modern turbines if it is to be viable, and also that larger turbines can look better, depending on the environment. There should also be flexibility with respect to future technological developments.

However, there was also concern regarding the prospect of more and taller turbines including in relation to their impact on historic assets from greater distances.

A further concern was expressed with respect to reports of negative impacts of noise and shadow flicker from turbines on those who live nearby. It was argued that control through the planning system is needed to give communities the confidence that problematic development can and will be addressed.

Spatial strategy and spatial frameworks

There were calls for NPF4 to include spatial planning for renewable energy identifying priority areas for onshore renewables and for onshore wind in particular, taking a more national approach to strategic capacity for new wind farm development. In particular, it was suggested that identifying priority areas where onshore renewables might be considered would allow some forward planning for the network in a way that is not always possible under the current LDP-led system.

However, there was also opposition to preferred areas for onshore wind as it was argued these would be landscape led. It was also suggested that, in Wales, the allocation of land for the development of onshore wind farms has not been successful and has failed to deliver the necessary scale of development, so should not be replicated in Scotland.

Although incorporation of existing spatial frameworks into NPF4 was advocated, there were also arguments for changes to the existing frameworks set out in Table 1 in SPP.^[18]

Specific suggestions included:

• Applying a 'presumption in favour' to Group 3 areas.
• Reviewing or removing the Group 2 status of Wild Land.
• Moving World Heritage Sites from Group 2 to Group 1 since, for most sites, a strong landscape context puts them on a par with National Scenic Areas.
• Alternatively, resist elevating World Heritage (e.g. Flow Country)^[19] Sites to Group 1 as this would significantly constrain onshore wind in Highland region.

It was also argued that, outside Group 1 areas, decisions should be made on a case-by-case basis, rather than through the application of constraint-based mapping within LDPs.

Policy on Wild Land Mapping

Concerns were raised regarding the inclusion of Wild Land within Group 2, including because there is no formal designation for Wild Land. Further, it was argued that the requirement set out in paragraph 215 of SPP has proved too high a bar for any wind energy scheme to satisfy^[20] and it was suggested this might be reworded. It was argued that there has effectively been a blanket ban on developments on or near Wild Land and peatland areas, despite some developments being supported by local planning committees. Some respondents - including Community Councils - raised issues regarding the extent of land already designated as Wild Land in Sutherland in particular, and it was argued any further protection could have a detrimental effect on the economic development and social sustainability of some areas. There were calls for Wild Land boundaries to be 'pulled back' in areas where wilderness qualities are more limited or, specifically, for reassessment of the 2014 SNH map to reduce Wild Land areas in both scale and number, while still ensuring protection for the wildest areas.

Issues concerning buffer zones were also raised, with a suggestion that these should be abandoned.

Landscape capacity studies

There were calls for review of the role of landscape capacity studies which, it was argued, do not reflect the urgency of the climate emergency, are often out of date, and are often misinterpreted or misused. It was suggested that there are many instances where use of landscape capacity studies to refuse applications has been overturned on appeal and that such studies should be removed or demoted so they are not given as much weight, but used more as a guidance tool. Landscape sensitivity studies that identify relative sensitivities within the landscape were frequently argued to be more appropriate.

However, it was also suggested that some areas are reaching their capacity for onshore wind and, in such circumstances, LDPs should have the ability to say so.

Other issues

Among other issues suggested for inclusion in NPF4 in the context of planning for onshore wind development were:

• Resolution of the exclusion zone around the Eskdalemuir Seismic Array.
• Development of a more strategic approach to mitigating impacts of wind development on civil aviation radar.

Offshore wind

A greater support for offshore wind was suggested, including to alleviate pressure for further onshore development. However, it was also reported that existing export capacity is already fully subscribed, leading to regular periods of curtailed wind output due to lack of network capacity. It was considered that NPF4 should make clear links to the Sectoral Marine Plan and Offshore Wind Policy Statement and should ensure provision of the necessary onshore facilities including cables, substations and port infrastructure. 'In principle' support for such installations was proposed, as was National Development status for onshore infrastructure associated with offshore wind.

It was also suggested that NPF4 should recognise the potential for floating offshore wind. Although it was observed that floating wind provides an opportunity for a leading role for Scotland, it will require long term support and a pipeline of projects with reasonable time scales to aid delivery.

Tidal

Among advocates of tidal power, it was suggested that this is predictable, would do little damage to the landscape and presents a major future source of renewable energy for Scotland. In particular, it was argued there should be further research on tidal stream generators.

Solar

There was suggested to be significant growth potential for all forms of solar energy development in Scotland and it was argued that NPF4 should create a supportive policy environment, including for co-location of solar and energy storage. However, it was also noted that the policy paper makes no direct reference to solar power.

It was observed that lower sunlight levels and more challenging terrain and wind speeds than in other parts of the UK may reduce the number of suitable sites and the economic viability of solar power in Scotland. Key constraints to attracting more large-scale solar were suggested to be very high planning application costs and a lack of grid capacity at locations that are suitable for solar. Suggestions included:

• Streamlining elements of the planning process. It was suggested that both EIAs and zones of theoretical visibility studies might be simplified for solar developments.
• Encouraging local authorities to use their discretion in relation to both community benefits and non-domestic rates for solar developments.
• Presumption in favour of solar on brownfield sites.
• Reconsideration of extending permitted development rights to larger roof mounted and to larger-scale ground-mounted solar.

In addition to conventional solar farms or roof mounted panels a range of new solar technologies were highlighted - building-integrated solar, floating solar, solar roads and solar carparks with onsite electric vehicle charging.

Hydro

Suggestions with respect to hydro included that NPF4 should:

• Provide a supportive policy framework for the development of new and existing pumped storage hydro schemes including continued recognition of pumped storage hydro schemes as nationally important or affording National Development status to all pumped hydro. Retaining Cruachan 2 as a National Development project was also proposed.
• Support the development of small-scale hydroelectric schemes by making a requirement to conceal pipelines proportionate to the scale of the scheme, subject to a visual impact assessment in Group 1 areas.

Hydrogen

The importance of aligning NPF4 with the forthcoming Hydrogen Policy Statement and Hydrogen Assessment Project was highlighted as was the need for land and facilities for hydrogen manufacture and storage. It was suggested suitable sites will be in industrial or port locations and will be licensed and regulated for containment of flammable gases.

The opportunity for hydrogen hubs to co-exist next to existing oil and gas nodes was also highlighted, with a suggestion that existing nodes might be granted permitted development status for green hydrogen production.

With respect to distribution of hydrogen it was suggested that decisions on the scale of hydrogen network infrastructure should consider economic and technical factors in determining the benefits of national versus regional networks. It was also observed that although the gas grid in Scotland cannot carry hydrogen at present, it could carry hydrogen-enriched natural gas as a short-term measure.

Other energy sources

It was suggested both that biomass should not be considered fully renewable and that there should be no approval for large biomass plants. Issues associated with obtaining energy from waste by anaerobic digestion are considered under the Waste theme.

Decentralised generation, small scale and community energy

There were calls for NPF4 to promote decentralisation of electricity generation, including small scale local and off-grid production as well as promoting community energy and energy co-ops. It was suggested this could support a just transition to a low carbon energy system, create local employment, enhance community empowerment, reduce transmission losses and help to relieve pressure for further development in upland areas. The need to improve grid capacity to receive locally generated electricity was highlighted, although it was also suggested it should be possible for locally-generated energy to be used locally.

Specific suggestions included:

• Solar panels or wind turbines should be required in new build housing developments.
• Non-residential developments above a certain size should be required to include a new renewable source of electricity supply.
• Photo voltaic panels should be mounted on buildings such as schools or leisure centres for community benefit.

National Development proposals

In addition to proposals for the generic National Development projects noted above, National Development status was also suggested for specific types of energy generation, for example solar photovoltaic, or for energy projects, hubs or transition zones.