The NPF4 lays out some exciting opportunities for renewable development in Scotland. It potentially provides the mechanisms to allow more (sensitively sited) renewable installations which will help drive Scotland towards its net zero goals. And we are already working with our landowner and developer clients to explore what further opportunities could be unlocked by the updated planning policy.
The twin global climate and nature crises are at the heart of the NPF4 vision and have formed the foundations for the spatial strategy as a whole. Scotland’s Energy Strategy and Just Transition Plan (draft published on 11 Jan 2023) will also set a new agenda for the energy sector in anticipation of continuing innovation and investment to deliver a flourishing net zero energy system.
NPF4 states that Scotland’s future places will be net zero, nature positive places that are designed to reduce emissions and adapt to the impacts of climate change, whilst recovering and restoring our environment. Thus, every decision on our future development must contribute to making Scotland a more sustainable place and as such NPF4 encourages the expansion of renewable energy generation.
The interplay between land and sea will be critical, given the scale of offshore renewable energy sources. Six national developments are identified that support the delivery of sustainable places and those with an energy & renewables focus include the following.
• Energy Innovation Development on the Islands – supports developments in the Outer Hebrides, Shetland and Orkneys groups for renewable energy generation, renewable hydrogen production, infrastructure and shipping, and associated opportunities in the supply chain for fabrication, research and development.
• Pumped Hydro Storage – supports additional capacity at existing sites as well as at new sites.
• Strategic Renewable Electricity Generation and Transmission Infrastructure – supports renewable electricity generation, repowering and expansion of the electricity grid.
Other National Developments that are identified and specifically support the development of the renewable energy sector include Aberdeen Harbour, Hunterston Strategic Asset, Chapelcross Power Station Redevelopment and Industrial Green Transition Zones e.g. Grangemouth.
Energy & Renewables linkages within the specific National Planning Policies set out in NPF4 are:
Policy 1 - Tackling the climate and nature crises – gives significant weight to the global climate emergency and the nature crises to ensure that they are recognised as priorities in all plans and decisions.
Policy 2 - Climate mitigation and adaptation - will ensure that emissions from new development are minimised as far as possible.
Policy 3 - Biodiversity and 4 - Natural Place protect biodiversity and natural assets which in turn play a crucial role in carbon reduction. They rebalance the planning system in favour of conserving, restoring and enhancing biodiversity and promotion of nature-based solutions, benefiting people and nature.
Policy 5 - Soils - provides significant protection for peatland and carbon rich soils. Development on prime agricultural land or on peatland, carbon rich soils and priority peatland habitat will only be supported where it is for the generation of energy from renewable sources that optimises the contribution of the area to greenhouse gas emissions reductions targets.
Policy 6 - Forestry, Woodland & Trees - aims to protect and expand forests, woodland and trees. Development proposals will not be supported where they involve any loss of ancient woodlands.
Policy 11 – Energy - supports all forms of onshore and offshore renewable energy development including energy generation, storage, new and replacement transmission and distribution infrastructure and emerging low-carbon and zero emissions technologies including hydrogen and carbon capture utilisation and storage.
Development proposals for wind farms in National Parks and National Scenic Areas will NOT be supported. Development proposals will only be supported where they maximise net economic impact, including local and community socio-economic benefits such as employment, associated business and supply chain opportunities.
Individual project design and mitigation will be required to demonstrate how the following impacts are addressed.
- Impacts on communities and individual dwellings including residential amenity, visual impact, noise and shadow flicker.
- significant landscape and visual impacts, recognising that such impacts are to be expected for some forms of renewable energy. Where impacts are localised and/ or appropriate design mitigation has been applied, they will generally be considered to be acceptable.
- Public access, including impact on long distance walking and cycling routes and scenic routes.
- Impacts on aviation and defence interests including seismological recording.
- Impacts on telecommunications and broadcasting installations, particularly ensuring that transmission links are not compromised.
- Impacts on road traffic and on adjacent trunk roads, including during construction.
- Impacts on historic environment.
- Effects on hydrology, the water environment and flood risk.
- Biodiversity including impacts on birds.
- Impacts on trees, woods and forests.
- Proposals for the decommissioning of developments, including ancillary infrastructure, and site restoration.
- The quality of site restoration plans including the measures in place to safeguard or guarantee availability of finances to effectively implement those plans; and
- Cumulative impact
However, in considering these impacts, significant weight will be placed on the contribution of a proposal to renewable energy generation targets and on greenhouse gas emissions reduction targets.
Grid capacity should not constrain renewable energy development. NPF4 states that it is for developers to agree connections to the grid with the relevant network operator. In the case of proposals for grid infrastructure, consideration should be given to underground connections where possible.
Consents for development proposals may be time limited however areas identified for wind farms are expected to be suitable for use in perpetuity.
Policy 19 - Heating and Cooling – seeks to encourage and facilitate development that supports decarbonised solutions to heat and cooling demand and connections to expanded heat networks which use and store heat from low or zero emission sources.
Policy 33 – Minerals - is also clear that fossil fuel exploration, development and production (excluding unconventional oil and gas) will not be supported other than in exceptional circumstances.
