Fourth National Planning Framework - position statement: consultation analysis

A Plan for Net-Zero Emissions

The first key outcome is Net-Zero Emissions. The Position Statement highlighted intentions to: prioritise the types and locations of development that will help meet emission reduction targets; build on the Climate Change Plan with action informed by the recommendations of the Just Transition Commission; plan future places that reduce the need to travel and build in natural solutions; make buildings more energy efficient; and facilitate decarbonised heating and electricity generation and distribution.

Further detail on the thinking behind the Plan for Net-Zero Emissions was provided under five headings:

1. Prioritise emissions reduction.

2. Integrate land use and transport.

3. Facilitate design solutions and innovation.

4. Promote nature-based solutions.

5. Deliver infrastructure to reduce emissions.

Question 1: Do you agree with our current thinking on planning for net-zero emissions?

General comments

As in respect of the Position Statement overall there were calls for stronger language with respect to planning for net-zero emissions. For example, it was suggested the first bullet point introducing the Plan for Net-Zero Emissions should be amended so that rather than 'prioritising' certain types of development it reads that 'no development should be allowed which has any detrimental impact either on climate or ecology'.

A further suggestion with respect to these bullet points was that the third point should be amended to read ' …planned in a way that reduces the need to travel or promotes active travel, and builds in natural solutions.'

While expressing broad support for current planning for net zero, many respondents also highlighted issues they felt should be included or should have more prominence in terms of achieving net zero emissions including:

• More focus on how tackling net-zero can have a positive effect on place and population health.
• A stronger emphasis on links between the climate and biodiversity crises.
• A role for localised energy solutions, as set out in the recent Local Energy Policy Statement^[6] (January 2021).
• The potential for solar energy generation in Scotland. It was argued solar photovoltaics should be recognised as part of a renewable energy mix and provided with a favourable planning environment.
• The importance of waste management in reducing emissions and promoting the circular economy.
• Food production and particularly the role of aquaculture.
• Land reform.

Although the Position Statement makes clear that reducing emissions is 'not about restricting development' some respondents did not agree that net-zero emissions can be achieved without limiting development.

Prioritise emissions reduction

Climate change will be the overarching priority for our spatial strategy. To achieve a net-zero Scotland by 2045 and meet the interim emissions reduction targets of 75% by 2030 and 90% by 2040, an urgent and radical shift in our spatial plan and policies is required. Scotland's updated Climate Change Plan will be published later this year, setting a course for achieving the targets in the Climate Change (Emissions Reductions Targets) (Scotland) Act 2019. NPF4 will take forward proposals and policies to support it.

No single development or planning policy can achieve this. The strategy as a whole will be designed to minimise emissions from new development. We will work alongside the development of Scotland's next Land Use Strategy to guide long-term land use change in a way that helps to reverse patterns of behaviour that are already contributing to emissions. We will do this in a way that achieves economic, health and other environmental benefits through a just transition.

To help inform this, we will bring together and reflect emerging regional spatial strategies and their proposals for strategic development that helps to reduce emissions and aligns with emerging thinking on wider regional land use. The transition from energy intensive to zero carbon economies is a key challenge that is being actively considered across national and regional scales. It is increasingly recognised that the impacts of climate change may be best tackled at a strategic scale i.e. managing flooding through upland management, and capturing carbon through tree planting and strategic peatland restoration. These are some ways in which regional spatial strategies are reflecting these opportunities. Early work shows that there are opportunities for planning to support a transition to a lower carbon economy in areas that include the Firth of Forth, the North East and island communities.

Around 85 respondents made a comment about prioritising emissions reduction.

There was broad support for the focus on tackling issues relating to climate change and agreement that achieving net zero emissions should be the over-arching priority of the spatial strategy. It was observed that the short timescales mean it will be important that Scottish Planning Policy (SPP) can be implemented as quickly and easily as possible by Planning Authorities. Several local authorities either noted that their own Regional Spatial Strategy (RSS) would support the approach outlined in the Position Statement or referenced their own actions and intentions with respect to the climate emergency.

There was also support for the emphasis on renewables and for the focus on strategic levels of planning. It was agreed that an urgent and radical shift in policies will be needed, although a stronger commitment to the climate change priority was also thought necessary.

The target of achieving net zero by 2045 was welcomed, although it was suggested that there could be confusion between targets for net zero emissions in 2045 and outcomes for 2050. There was also support for the interim targets suggested.

However, some respondents expressed a view that greater urgency or more ambition, is required, or that there needs to be greater emphasis on plans for the next three years and on targets for 2030. A specific suggestion was prioritising schools to reach net zero by 2030, both in order to improve the learning environment in school buildings and also to give students first-hand experience of the changes that need to be made, rather than sustainability being taught as a futuristic concept.

Some respondents argued the urgency of addressing climate change, coupled with the delay to NPF4 until the spring of 2022 means that interim policy guidance is needed with respect to strengthening support for renewable energy. This is discussed further at Question 7.

It was also argued that a true net-zero target should take full responsibility for all Scotland's production and consumption emissions so should, for example, incorporate assessment of emissions arising from imports of manufactured goods and food.

An alternative perspective, from a small number of respondents, was that the proposals set out in the Position Statement are too ambitious, with potential adverse effects on the less well-off.

Overall, it was suggested NPF4 should create an enabling framework for rapid deployment of a diverse renewable energy mix across Scotland, including wind, solar, tidal generation, community renewable energy projects and a range of storage solutions, including battery storage and pumped hydro.

Emissions from new development

The proposals on emissions from new development were suggested to be similar to those introduced in recent Local Development Plans (LDPs) and it was argued that it will be important to have a process which is understood and can be consistently applied across all planning authorities.

There was agreement with the focus on emissions from new development and a suggestion that carbon emissions cost should be measured for new build at the Planning Application stage. It was also argued that NPF4 should support any development which seeks to achieve reduction in emissions.

Strategic scale approaches

There was support for the strategic approach to tackling climate change – for example with respect to flood management - but it was argued this will require co-ordination, financial and staff resources and, potentially, consideration of land ownership. The need to align spatial strategies with the Climate Change Plan and the Land Use Strategy was highlighted.

However, concern was also raised that a strategic approach may lead to increases in land prices in areas deemed suitable for development, leading to delays, increased project costs, and increased cost of the energy generated. Further, it was suggested development of a strategic plan will itself take time and could be subject to judicial review, halting development until resolved. For these reasons it was argued preferable to have clear development criteria against which a project can be tested.

Other suggestions

Respondents suggested a range of additional polices to contribute to the target of net zero emissions. These included:

• A publicly owned energy company delivering energy generation.
• Exploring the potential for tidal stream electricity generation.
• Encouraging deployment of heat networks at scale.
• Stronger legislation regarding emissions from shipping in harbours to tie in with blue space development.
• A ban on any new fossil fuel developments - all new coal, oil or gas energy generation developments, including projects below 50MW.
• A presumption against conventional onshore oil and gas extraction.
• No development of further incineration capacity.
• Ending the expansion of the trunk road network.

It was also proposed that NPF4 should bring the various relevant strategies together, in such a way that it can be clear to communities how their own efforts are contributing to overall emission reductions targets.

Integrate land use and transport

The location of development determines the intensity of emissions that it will generate throughout its lifetime. Our strategy will promote future patterns of development that embed the National Transport Strategy 2 (NTS2) Sustainable Travel Hierarchy in decision making. We will seek to promote high quality walking, wheeling and cycling environments, public transport and shared transport options in preference to single occupancy private car use. This will help us to meet our climate change targets and transition towards healthier, more local, zero carbon living and working. Clear choices will need to be made to direct development to locations which reduce the need to travel and are already well served by sustainable transport options.

Our approach will ensure transport options that focus on reducing inequalities and the need to travel unsustainably are prioritised. We also need to maintain and safely operate existing transport infrastructure and services, and ensure our transport networks can adapt to the impacts of climate change. Only after that should investment involving targeted infrastructure improvements be considered. Ultra-low emission vehicles (ULEV), including electric vehicles will have a role to play, particularly with regard to shared transport, and so we will also plan for electric vehicle infrastructure.

Around 65 respondents made a comment about integrating land use and transport. There was support for integrating land use and transport and a particular welcome for embedding the NTS2 sustainable travel hierarchy in NPF4. Respondents highlighted the high levels of carbon emissions from transport as a sector and, within this, the proportion generated by private cars. However, it was also noted that embedding the sustainable travel hierarchy will be challenging as existing developments will need to be retrofitted and it was suggested multi-layered partnership working will be necessary.

While some respondents welcomed the intention to promote active travel, others argued that simply promoting alternatives to single occupancy car use will be ineffective as long as society is dependent on private cars. One view was that local authorities should be empowered to restrict private car use.

One aspect suggested to be missing from this section of the Position Statement was recognition of the role ports can play in reducing transport emissions including by supporting the movement of freight from road to rail.

Directing development

There was also support for directing development to locations that reduce the need to travel and are well served by sustainable transport options. There were suggestions that:

• Developments that give precedence to active travel and connections to public transport should be prioritised.
• Active travel infrastructure should not be allowed to lag behind provision of new homes since this can lead to residents forming travel habits that are then hard to change.
• Development in car-dependent locations should be restricted.

It was also argued that development could be allowed in locations which are planned to be or could be served by sustainable transport options.

Respondents commented on the potential for development of 20 minute neighbourhoods, support for town centres and restricting out-of-town retail and leisure facilities to reduce reliance on motor vehicles. There were calls for restrictions on development of out-of-town business parks and retail parks.

Facilitating active travel

Elements identified as important to promote active travel were:

• Development and maintenance of active travel routes.
• A requirement that cycling and walking routes must be safe, with safety on separate cycle paths highlighted as a particular issue for children.
• Active travel routes connecting to public transport hubs.
• Storage facilities – for example for bicycles.

The importance of collaborative planning to identify active travel networks was also suggested, with both regional-level networks close to where people live and work and national networks such as the National Walking and Cycling Network highlighted. Opportunities for routes and networks to be greened as part of wider green networks were also highlighted.

While comments on active travel were generally very positive, it was also argued that transport infrastructure is being undermined by the focus on active travel (including the closure of streets to buses) and that the proposals fail to recognise that competing priorities are involved. Caution was also advocated with respect to the proposal that requirement for planning permission for active travel projects should be removed: it was suggested major active travel routes should still be required to go through the planning process in order to ensure communities have a say on routes and possible impacts. Installation of temporary works without any form of consent during the pandemic was reported to have has caused problems in some areas.

Public and shared transport

Several respondents commented on the need to provide and promote use of public transport to encourage sustainable travel, including a suggestion there should be greater emphasis on the bus network. The need to make use of public transport a more attractive option was also noted with a suggestion that communities should be given a voice in planning routes, stops and timetables. However, gaps in coverage created after deregulation of public transport were also noted, and that it will be challenging to persuade people to switch from private cars to walking or cycling.

Investment in public transport was also argued to be key for people with a disability, to ensure an integrated public transport system that is affordable, available and accessible for everyone.

The potential of shared transport schemes such as car clubs in reducing emissions relative to private car use was also suggested. A role for shared bike and E-bike schemes in discouraging private car use was also highlighted and development of mobility hubs was suggested to give scope for redesigning street layouts with less space allotted to car parking.

Rural areas

Some respondents pointed to the need to understand limitations of the sustainable travel hierarchy in rural areas, including that walking and cycling may be required over much longer distances and that public transport provision is more difficult to deliver. It was suggested that:

• If local authorities are going to reduce dependency on cars and promote active travel in rural areas, they will require assistance from the Scottish Government, potentially including funding.
• Without significant investment in public transport continued car use in rural areas is inevitable.
• Appropriate weight should be given to the need for single vehicle transport in rural areas and the sustainable travel hierarchy should give positive consideration to electric or hydrogen-powered vehicles.
• An on-demand mobility service could provide travel options in rural areas.
• There should be a shift away from planning authorities only allowing development of new housing in the countryside if the proposed location is accessible by public transport.

There was also a concern that, if development is directed away from rural areas because transport is not considered sustainable, rural communities may lose benefits including public transport infrastructure.

Electric and hydrogen vehicles

The need for enhancement of the existing low voltage distribution networks to support the roll out of electric vehicle (EV) charging infrastructure was highlighted and the work of a Strategic EV Partnership to develop, demonstrate and trial a new joined‐up model for delivering strategic infrastructure was reported. The need for further details on what needs to be done to facilitate the development of widespread EV charging infrastructure from a planning perspective was also suggested.

Other issues raised with respect to EV charging included that it will be important to ensure adequate provision of charging points in rural areas, which may be disadvantaged by a market-driven charging system.

There was support for the intention to remove the need for planning permission for EV charging points, although it was also reported that the main barrier to installation is usually permission from the landowner, and it was argued installation of EV charging points at a commercial scale should be subject to planning control.

There were also calls for a fuelling infrastructure for hydrogen powered vehicles. Scope to convert existing petrol/diesel engines to use hydrogen was suggested as a means of avoiding emissions associated with the construction of new electric vehicles.

Requirement for strategic connectivity

While some respondents argued there should be no new road building, or argued against road dualling projects, others highlighted the need for improvements in the strategic road network, particularly in rural areas.

Facilitate design solutions and innovation

We will ensure planning policies support the very significant reductions in emissions from buildings that we need to see. This is not just about new development – our existing buildings and places will need retro-fit solutions and we will make use of the embedded carbon across the built environment. Planning can facilitate low carbon methods of construction, which create a whole building approach to emissions including construction and decommissioning. We will support developments that make use of low energy and emission materials as well as natural and micro-climate features which reduce the resource demand of the development. We will align our strategy with Building Standards to create a consistent approach, and actively encourage buildings that go beyond current standards where there is appetite to do so. We will also enable and encourage deployment of renewable and zero emissions heating, including by facilitating development of the networks they require.

Around 75 respondents made a comment about facilitating design solutions and innovation. There was support for reducing emissions from buildings and the construction sector and for the proposal to set out a consistent policy for meeting Section 3F of the Town and Country Planning (Scotland) Act 1997 in relation to emissions policies. There was also a view that language used in the Position Statement should be stronger. Intentions to "actively encourage buildings that go beyond current standards where there is appetite to do so" or "encourage new buildings to connect to existing heat networks …. wherever feasible" were highlighted as illustrations. It was argued that unless mandated, both private developers and local authorities will choose not to implement these measures.

Re-use of existing buildings

Some respondents agreed that support for reuse of existing buildings should be strengthened, although it was also suggested this needs to be aligned to fiscal and other incentives to stimulate re-development, including a funding mechanism to support redevelopment. Commenting on the absence of any mention of investment, one local authority respondent noted that, for them, decaying urban fabric of town centre buildings was a much more significant issue than vacant and derelict land.

However, respondents also highlighted what they saw as limitations in terms of:

• Buildings that do not lend themselves to modern day use.
• Specific requirements of the end users.
• Situations where a net gain from replacement rather than reuse can be demonstrated or where replacement creates an opportunity to intensify land use.
• Complexity and cost/viability of conversion.

Instead, it was argued that each site should be assessed on merit or that:

• There should not be a proscriptive approach where there is limited scope to develop brownfield sites.
• A preference for re-using existing buildings should assess the economic viability and long term future proofing of buildings to assess whether re-use or conversion is realistic.
• Policies might be framed to allow for proportional degrees of new build permission, with re-build favoured for A or B Listed buildings but redevelopment in the form of new sustainable build favoured for C-Listed or non-listed properties.

A focus on carbon assessment was welcomed, although a need for guidance was suggested, as was a requirement that such assessments would need to be built in from an early stage in the development plan process and would need to be mandatory when applications are lodged for even planning permissions in principle. It was suggested that there will be implications in terms of both resources and time for undertaking such assessments, and in training/qualifications for planning officials in order to appraise assessments when determining applications. The need to ensure a requirement for carbon assessments does not duplicate the Building Standards process was also highlighted.

One respondent reported their own research project to understand both the embedded and operational carbon in pre-1919 building stock.

Retrofitting existing buildings

While there was strong support for retrofitting existing buildings to improve their energy efficiency, the scale of the challenge was also highlighted, including for work on traditional buildings, listed buildings and buildings in Conservation Areas, as well as in rural areas.

In view of the costs associated with retrofitting it was suggested that both advice and financial assistance for owners will be needed, with an expanded Home Energy Scotland advice service, an expanded programme of incentives to support home-owners and private landlords, a Rural Homes Just Transition Package and a reduction on VAT for works to existing buildings all suggested.

However, potential scope for enforcement was queried if the planning system can only require installation of energy efficiency measures when planning permission is applied for.

New development

There were calls for new development to be carbon neutral, energy efficient or built to Passivhaus principles and 'future-proofed' as far as possible. It was also suggested that low carbon heating systems should be required and that opportunities for micro electricity generation should be investigated.

A further proposal was that applications for large scale developments should be required to include energy balance sheets, setting out a validated estimate of the energy demands of the development alongside the degree to which the energy demands will be met by verifiable renewable energy supplies.

In order to promote the actions needed to reduce emissions it was suggested that low carbon choices by home-owners might be incentivised by reducing taxation on more energy efficient buildings and that there should also be incentives for zero carbon development within the planning and building standards systems. However, it was also argued that low or zero carbon development should not provide justification for new development over reuse/retrofit of existing buildings or for development on greenbelt land.

Other issues raised in respect of new development included that:

• Consistent policies should be applied across Scotland to allow home builders to make long term investments in low carbon and fabric-first design.
• Emissions during the building process must be considered as well as those represented in the finished building.
• Offsite construction methods can reduce emissions, with benefits including increased build quality and reduction of waste during construction.
• Habitat mapping data could be used to direct development away from wetland and peat soils as a means of reducing emissions.

Supply chain

Several respondents highlighted the need to ensure a workforce with adequate skills for delivery of the construction methods and retrofitting techniques that will be required. It was suggested this will necessitate extensive recruitment and upskilling. Particular challenges in rural and island areas were noted, and an existing shortage of people trained in retrofit of traditional buildings was highlighted.

Attention was drawn to the role of the college sector, both in supporting innovation and also providing opportunities for workers to develop their skills.

Heating

Facilitating development of networks for renewable and zero emission heating was supported, although it was argued that progress towards delivery of renewable heating and heat networks has been slow to date and that NPF4 must address this by providing a favourable planning regime for their deployment at scale across Scotland. Inclusion of local energy generation schemes under this planning policy umbrella was suggested.

The importance of alignment of NPF4 with the forthcoming Heat in Buildings Strategy^[7] was highlighted, with the draft strategy welcomed as a strong push towards resolving heating issues in a strategic manner. It was also noted that the proposed introduction of a New Build Heat Standard will require new buildings to be installed with a heating system that produces zero direct emissions at the point of use and it was suggested that NPF4 should prioritise approval of heat network schemes by their suitability, prioritising development proposals which cause the least disruption. Progress of the Heat Network Bill was also noted, and the need for alignment with the planning system noted.

The importance of enabling and encouraging a range of low and zero carbon heating options and not purely a focus on district heating was also highlighted. In particular it was argued that for rural areas where there is not a high heat demand and no anchor loads, alternative technologies such as heat pumps should be encouraged. However, it was also suggested that technologies such as air source heat pumps may have visual or noise impacts and that their proliferation without careful management, could have a negative impact on both historic and natural environments. Improving energy efficiency was suggested as a priority in rural areas.

Provision of funding to offset the costs of low carbon infrastructure and infrastructure reinforcement that enables low or zero carbon technologies such as air source heat pumps to be used more widely was also suggested.

Building standards

There was broad agreement with the proposal that NPF4 should align planning with Building Standards. The need for urgent updating of standards was highlighted, and a key role for Planning and Building Standards to work together to improve standards of new development was suggested. It was also reported that many local authorities already require higher standards than those set nationally for new build construction.

With regard to the proposed alignment it was suggested that:

• Clarification is needed with respect to how meeting the requirements of Section 3F of the Town and Country Planning (Scotland) Act 1997 will be addressed alongside the Building Standard Regulations, as achieving the ambitions set out in the Position Statement will require higher standards for developers to accord with.
• NPF4 needs to articulate exactly what a new relationship between planning and building standards looks like. Guidance is needed as to how the two separate processes can best be brought together to avoid duplication and ensure planning authorities can benefit from the available expertise.
• It would be best for changes to come through Building Regulations where they will be required, as opposed to solely relying on planning policy. Building standards are the more appropriate way to regulate the way in which buildings work and planners may not have the knowledge, skills or time required to assess some aspects.
• The planning framework and the Climate Change Act should drive building standards to the appropriate level.

It was also argued that policy needs to be flexible enough to accommodate advances in technology and understanding of the issues relating to climate change, or that there should be model policies around latest best-practice rather than taking a prescriptive approach.

Low energy and emission building materials

With respect to use of low energy and emission building materials it was again argued that it would be more effective to 'require' the use of such materials as much as possible rather than simply 'supporting' their use. Other points included that:

• These should not be specified by planning but via Building Regulations.
• A presumption in favour of using local materials could be considered a positive way to encourage development that reduces carbon emissions and helps boost the local economy through adding value to local industries.
• Achieving a consistent approach across Scotland may require compiling a 'bible' of embodied emissions and suitable materials. Architecture and Design Scotland's Library of Sustainable Building Materials was suggested as a possible key resource.
• Clarity will be required on a number of aspects including with respect to the weight given to low embodied energy as opposed to their lifespan of material potential for reuse.

A potential conflict with Building Standards over experimental low carbon materials or need for chemical treatments to make them safe for building use was also suggested.

Promote nature-based solutions

The climate and nature crises are intrinsically linked. It is estimated that around a third of the global mitigation effort needed to deliver the goals of the Paris Climate Agreement could be achieved through nature-based solutions.

Scotland's natural environment plays a vital role in removing carbon from the atmosphere and securing it in natural habitats on land and in our seas. Promoting nature-based solutions to climate change, including tree planting and peatland protection and restoration, and tackling emissions related to soil disturbance and agricultural land use, will be essential to reduce emissions from our land and increase carbon sequestration. They can also help to sustain and grow rural communities and improve the quality of our built environment. Our spatial strategy will explore how we can promote nature-based solutions to climate change, which also protect and restore biodiversity and deliver wider benefits.

Around 45 respondents made a comment about promoting nature-based solutions. There was support for promoting nature-based solutions in respect of climate mitigation and also with respect to benefits to biodiversity, adaptation to flood risk and improved air quality. It was suggested that, in line with the definition used by the International Union for Conservation of Nature, nature-based solutions should be defined as:

"actions to protect, sustainably manage and restore natural or modified ecosystems that address societal challenges effectively and adaptively, simultaneously providing human well-being and biodiversity benefits".

The role of nature-based solutions in cities was highlighted and it was suggested NPF4 should acknowledge that blue/green infrastructure solutions are also a form of nature-based solutions. Referring to use of vacant and derelict land in the context of nature-based solutions was proposed, and the role of greenbelt land in mitigation of climate change was highlighted.

A requirement for regional scale solutions was also noted and it was suggested it will be important to ensure alignment of NPF4 with other strategies and policies including the Land Use Strategy, Regional Land Use Frameworks, the forthcoming Scottish Biodiversity Strategy, and forestry policies. It was also argued that NPF4 should recognise the value of and commit to a Scottish Nature Network.

While many comments on nature-based solutions were supportive, it was also argued that:

• The role of nature-based solutions is not given sufficient weighting in the Position Statement and the framing of nature-based solutions in the Position Statement is too climate-focused.
• The opportunities offered by a biodiversity net gain approach should also be considered and a clear policy steer provided to stimulate a nature-based solution market.
• Language should be strengthened, so the plan goes beyond "promoting" such solutions.

It was also suggested that NPF4 should set out where the Scottish Government sees the most opportunity for employing the use of nature-based solutions and could explore mapping the opportunities, both large and small, and explain how it will support this the growth of implementation.

Peatland protection and restoration

With respect to protection of peatlands it was suggested that new licences for peat extraction for horticultural use should be prohibited, existing licences should be repealed as soon as possible, and restoration of existing extraction sites should be supported. Protection of deep peat from tree planting or replanting was also suggested.

The potential for conflict between policies to support onshore windfarm development and to support protection and restoration of peatland was highlighted. One perspective was that onshore wind projects can be developed on sites which involve peatland and that in many instances there is a net peatland and biodiversity benefit through extensive restoration opportunities enabled by development. Concerns were raised that promoting nature-based solutions could be used to restrict the further development of onshore wind farms.

An alternative view was that wind farm developments can cause significant damage to peatland and that there is neither guidance for decision makers on what is an acceptable carbon 'payback' period for these developments, nor how this should be weighed against associated biodiversity impacts. It was proposed NPF4 should strengthen the consideration given to the likely effects of development on CO₂ emissions, including the long term impacts on carbon storage potential, where peat and other carbon rich soils are present. Generally, greater recognition of the value of soils as a nature-based solution was proposed, as was protection of "ordinary" soils.

Peatland protection is also considered under "Promote sustainable resource management" at Question 3.

Tree planting

Comments in relation to tree planting included that NPF4 should:

• Include policies to encourage conservation and restoration of natural habitats and, specifically, provide strengthened policies to protect existing woodland, ancient woodland and veteran trees.
• Provide a plan-led approach to woodland restoration and creation to achieve the right trees in the right places. A target of planting a billion trees was suggested.
• Encourage establishment of native woodland and promote natural woodland regeneration where practicable.
• Require specific developments to achieve a net increase in tree planting, including woodland enhancement and creation where appropriate.
• Treat offsetting emissions by tree planting with caution since carbon is released from soil during the disturbance associated with planting.

Coastal habitats

In relation to coastal habitats and marine habitats it was argued that:

• There should be areas of no seabed interference to enhance their carbon entrapment and increase biodiversity.
• There should be consideration of sand dunes and saltmarsh which function as carbon stores and are also critical for adaptation and resilience to climate change, flooding and erosion.
• Seaweed farming should be referenced as a means of reducing CO₂ emissions.

Other issues raised

With respect to the historic environment it was suggested that there needs to be a planned approach to implementation of nature-based solutions to ensure proper archaeological assessment can take place and to avoid unintended consequences.

The potential for planning to support local growing and nature-based activities was also highlighted, with benefits not only to mental and physical wellbeing, but also in involving citizens and communities in action to address the climate and biodiversity crises and thereby encouraging people to appreciate how their own decisions can make a difference.

Deliver infrastructure to reduce emissions

We expect that NPF4 will confirm our view that the Global Climate Emergency should be a material consideration in considering applications for appropriately located renewable energy developments. We have made good progress in transitioning from reliance on fossil fuels to renewable electricity generation in a way which is compatible with our environmental objectives. Scotland is a net exporter of electricity and in the past decade renewable electricity output has grown markedly. However, significant further investment will be needed to support new technologies for carbon capture and storage; hydrogen; sustainable and active travel; electricity grid capacity (including subsea links to the islands); and decarbonisation of heating, our transport networks and vehicle fleets.

As a priority, our strategy will need to facilitate the roll-out of renewable electricity and renewable and zero emissions heat technologies. We will need to switch to low and zero carbon fuel sources, and support the delivery of associated infrastructure, such as grid networks and gas pipelines. We will ensure that NPF4 helps to deliver on our wider energy strategies including the Scottish Energy Strategy (including any updates), our Energy Efficient Scotland route map, the forthcoming Heat in Buildings Strategy, our vision to 2030 for Scotland's electricity and gas network and the Infrastructure Investment Plan.

Around 60 respondents made a comment about delivering infrastructure to reduce emissions. Respondents expressed support for:

• The Infrastructure Investment Plan, including the priority given to enhancing existing assets over new build.
• Updating the spatial framework for onshore wind.
• Expanding and repowering windfarms, although with calls both for a focus on existing sites and for clarification that the support also extends to new projects.

Elements suggested to be missing from the Position Statement or to require stronger support included:

• Solar photovoltaics. Without recognition in NPF4 it was suggested proposals for solar power development could be assessed against similar criteria as onshore wind, despite what were argued to be important differences in both physical impact and the underlying economics.
• Hydro, and marine renewables.
• Household/community energy generation.
• Battery storage, specifically with respect to changes to the current consenting regime. Renewable energy hubs where technologies can be co-located were also suggested.
• Investment in grid infrastructure to accommodate additional demand for electricity. The importance of grid infrastructure to connect to offshore wind projects was also noted. There was a request both that all transmission infrastructure retains National Development status and that direct grid involvement in existing NPF4 working groups is encouraged.
• Waste management infrastructure, including recycling infrastructure and energy from waste plants. Creation of a strategic planning group of multidisciplinary experts to develop the resource management infrastructure system was suggested.
• Policies to support the roll out of Ultra‐Low Emission Vehicles (ULEVs).

It was also suggested that reference to the forthcoming statutory duty on Local Heat and Energy Efficiency Strategies, and their intended role alongside LDPs, would be helpful in this section.

Material consideration

A number of respondents noted and welcomed the statement that it is expected "that NPF4 will confirm that the Global Climate Emergency should be a material consideration in considering applications for appropriately located renewable energy developments." As noted previously, some expressed a view that this does not provide the weight that it is required since being a material consideration simply suggests that it needs to be considered in decision making and does not provide a clear direction to rebalance the system in favour of climate mitigation. However, it was also argued this section needs to be very carefully worded since status as a material consideration could easily outweigh local issues such as a protected landscapes or places of historic significance.

Suggestions included that NPF4 should:

• Include a presumption in favour of renewable energy proposals and specifically of onshore wind applications.
• Make addressing climate change either a significant material consideration or add a test of special regard for climate.
• Make the reversibility of onshore renewable generation projects a stronger material consideration.
• Make action to address the biodiversity crisis a material consideration in planning decisions with equal weight to the climate emergency.
• Make the climate emergency a material consideration for other types of development, including aquaculture.

Appropriately located renewable energy development

With respect to what constitutes an appropriate location for renewable energy development it was suggested that this is not a simple matter and requires further detailed consideration. It was noted that disagreement over whether or not a project is appropriately located is often why developments end up at appeal or public inquiry and it was suggested a clear framework will be required to provide certainty and avoid delays.

A number of respondents suggested that the planning system should attach greater weight to the positive aspects of onshore wind developments or less weight to landscape and visual impacts and there was a suggestion that the term "appropriately located" should be removed, as this is for the planning system to determine. However, others argued that a balance must be struck between delivering renewable energy and protecting nature or protecting landscape quality, or highlighted the tensions between delivering renewable energy and protecting landscapes or recognising the impacts on local communities.

Some individual respondents identified themselves as living in areas where they felt there were already too many wind farms and expressed concerns that the proposed policy changes could lead to further development or voiced opposition to developments currently in construction.

Suggestions with respect to locating renewable energy developments included:

• A national assessment of where renewable energy schemes can be installed with minimal environmental damage that can be built into RSSs and Regional Land Use Frameworks.
• A plan-led approach and a brownfield first principle for onshore wind developments.
• An updated spatial framework for onshore wind that allows appropriately located development to proceed. Concerns with respect to the current framework were highlighted, including with respect to the classification of wild land.
• Discontinued use of Landscape Capacity and Sensitivity Studies and reliance on landscape character studies as part of the Environmental Impact Assessment (EIA) process.
• Consideration of whether developments may be in the long-term public interest – for example by securing positive effects for biodiversity.
• A presumption against new, large-scale built development that would result in excavation and disruption of healthy peatland bogs.
• Retaining the existing policy principle of "the right development in the right place" and not "development at any cost".
• Retaining the principle of a clear steer on planning policy in relation to areas that are identified as having significance in terms of their landscape, biodiversity and/or carbon sequestration values (such as National Scenic Areas, wild land areas and peatlands).
• Greater emphasis on positive benefits for local communities as a direct result of renewable energy developments, including cheaper electricity costs and investment in local economic development.

Clarity was also requested with respect to two issues relating to wording in the Position Statement that was seen as having the capacity to restrict renewable energy development. First, concern was expressed with respect to the key opportunity regarding 'shifting future development away from greenfield land including by actively enabling the redevelopment of vacant and derelict land'. It was suggested this could have consequences for the development of new onshore wind sites since there is limited potential for large-scale renewable energy development on brownfield sites. Clarification that support for renewable energy extends to developments on greenfield sites was requested. In a similar vein, clarity was requested that explicit support for repowering and life extensions for onshore wind energy developments does not preclude the possibility of new onshore developments on greenfield sites.

Repowering windfarms

Although there was support for repowering windfarms, it was also suggested that the increased turbine heights associated with repowering require strong policy to address potential adverse effects, and it was argued a balance with respect to landscape effects should still be maintained.

However, a case was also made for considering how processes to repower or amend permissions – including to reflect changes in turbine technology - could be simplified to help more rapid roll-out, and a presumption in favour of repowering and extension was proposed. To avoid any ambiguity, it was also suggested that there should be reference to support for new renewable energy developments as well as to support for wind farms in the context of repowering and extensions.

New technologies

There was support for recognition that investment in new technologies will be required, with a suggestion that clarity is required with respect to what can be considered as zero or low emission technologies.

There were also some differing perspectives with respect to the potential of some of the technologies mentioned in the Position Statement. With respect to hydrogen, it was argued that:

• NPF4 should specify green hydrogen production and infrastructure and that hydrogen is only a renewable fuel source if generated using electricity from renewable sources.
• References to policy and delivery of hydrogen could be stronger and upgrading or upscaling of the gas network to accommodate hydrogen should be included.
• Less prominence should be given to hydrogen since the technology is unproven and there is no evidence it will have a meaningful impact over the timescale of NPF4.

Similarly, it was argued too much prominence is given to Carbon Capture and Storage (CCS) given it is also an unproven technology.

Resources and delivery

It was argued that an 'infrastructure-first' approach must recognise both capital expenditure and revenue costs for councils and public bodies, and that it will not be sufficient to provide only for capital costs.

It was also argued that clear and meaningful engagement with city region deals and partner authorities will be important to ensure that the right infrastructure is delivered at the right time. It was suggested to be unclear at present how this will be achieved.

Other resource implications identified included a requirement for extensive upskilling of the workforce which, it was suggested, should be taken into account when considering the resource implications of the strategy.