Harking back to April 2019 when the climate emergency was formally declared by Scotland’s First Minister, Nicola Sturgeon – we now have the final draft of new planning policy for Scotland. The big question is: does it live up to the billing expected when the FM said it needed to be ‘radical’?
I would say yes in many respects it does, but as ever there are some caveats to that. It certainly puts climate change and renewable energy development front and centre, stating: significant weight will be placed on the contribution of the proposal to renewable energy generation targets and on greenhouse gas emissions reduction targets. There was already ‘significant weight’ attached to developments that can help tackle climate change in NPF3 and subsequent Chief Planner guidance. This is maintained in the new policy and strengthened because it is specific to energy generation and emission reduction targets. The more important point is whether everything else that was previously considered to have ‘significant weight’ and could trump climate action, was going to have less importance.
In many areas, this has happened. Policy in so-called ‘wild land’ is now more balanced to favour appropriate development of renewable energy schemes. This change in approach isn’t bad news for Scotland’s landscapes. It is important to remember that most of what is described as wild land is already afforded protection by being within the boundaries of National Parks and National Scenic Areas. The ‘wild land’ areas that can now be considered open for appropriate development are not within such designations and are not Scotland’s nationally important jewels in the crown of our landscapes. It has taken many years for the penny to drop that the ‘wild land’ tool was principally being used to block wind farms in some of Scotland’s windiest locations. I am glad that those days are gone now. Climate change is by far the biggest threat to all our landscapes and ecosystems.
Local authorities must now also realise the full potential of their areas for renewable energy generation. This link to the renewable resource potential makes a lot of sense. Not everywhere has the same amount of land, wind, water and solar irradiation. This is important so that energy can be harnessed where it is available and efficient to do so, and can be supplied to those who have less of it, like in cities. This is good news for the cost of energy and good news for communities who can benefit more from rich resources in their backyard.
It also sends a signal that we need to do the maximum. This perhaps puts being able to see renewable technology in the environment in a sharper focus, consistent with views of the vast majority of people, as a good thing – and the Scottish Government also recognizes that renewables will become much more common place as part of the human environment.
For developers and investors (including community investors), such positive policy is very welcome, but (and quite rightly in my view) there is also pressure put back on developers, to maximise net economic impact, including local and community socio-economic benefits such as employment, associated business and supply chain opportunities. There is also an expectation that where feasible there will be positive benefits for biodiversity from any development – and for responsible developers this goes with the territory to ensure best practice and practical steps to improve habitat management for example, or to deliver associated restoration work. There is a nature crisis too, action on this is strengthened in the NPF4.
The importance of targets for renewable energy development is strongly recognised and as well as the ambitious targets for onshore and offshore wind, this now makes setting targets for Solar Energy really important in the soon to be published and revised Scottish Energy Strategy. It also means that we now need reinforced targets for renewable electricity to decarbonize heat and transport, not just traditional power consumption, in order to make the NPF bite. Solar PV arrays are also more explicitly listed in the document as a favoured technology which is to be welcomed.
Much of what trade body Solar Energy Scotland and other renewable energy interests asked for has been incorporated positively to some degree – including the removal of oddities such as automatic requirements for glint and glare studies, and support for appropriate renewable energy development in greenbelts. And ahead of the NPF4 being published the Scottish Government has announced an acceleration of a Permitted Development Rights review for solar panels at scale on industrial and commercial premises.
Some potential contradictions remain – for example it does appear that planning authorities might consider a development unacceptable where “by virtue of type, location or scale will have an unacceptable impact on the natural environment, will not be supported.” And then in the rural section it states: “Development proposals in rural areas should be suitably scaled, sited and designed to be in keeping with the character of the area.” Such potential contradictions might be used to justify a ‘not here, do it somewhere else’ approach.
Yet elsewhere policy states that landscape and visual impacts for example “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”. The policy will obviously have to be considered in the round, in reaching a balanced judgement, and hopefully finding that balance through political leadership and bold decision-making consistent with what the climate crisis needs, and less through court challenges and public inquiries. As well as the question of whether the policy is radical enough, the true test will be whether we will see a reduction in the proportion of projects going into such long drawn out expensive processes – while the planet floods and burns.
George Baxter is Vice-Chair of Solar Energy Scotland and Director of Development at GreenPower