In the second of our blogs on the draft National Planning Framework 4, the focus is on renewable energy, particularly onshore wind.
Demand for green electricity
"The transition to net zero means that our demand for green electricity will increase substantially over the course of the next decade. This means that a consistently higher rate of onshore wind, and other renewables capacity, will be required year on year."
The Scottish Government's Onshore wind - policy statement refresh 2021: consultative draft is very clear about the need for a supportive policy environment to enable the additional 8-12GW of onshore wind to be installed in Scotland by 2030.
The Scottish Government's current planning policy (SPP) is supportive of onshore wind: the concern is whether the draft NPF4 gives the extra support required.
The new climate emergency policy (Policy 2) is a good start - significant weight to be given to the Global Climate Emergency. The difficulty is knowing what that means in practice. If the Scottish Government intend the decarbonisation benefits of renewable energy to be given significant weight, that needs to be stated explicitly.
Unfortunately the strong(ish) start is let down by Policy 19: Green Energy. That says that new wind farms (and repowering, extension and expansion of existing wind farms) should be supported, with some exceptions, unless the impacts are "unacceptable". That actually weakens the current position in the SPP, because there is no explanation of what is meant by "unacceptable", leaving it open to interpretation.
Subsequent policies also weaken the SPP approach. Policy 28: Historic Assets and Places takes a much more restrictive approach to development. For wild land, the current position in the SPP, that "wind farms may be appropriate in some circumstances", becomes support only for development that cannot reasonably be located outside of the wild land area (Policy 32: Natural Places), which seems an impossible test for commercial wind farms to meet.
The list of national developments in the draft NPF, includes renewable electricity generation developments, but only those of 50 or more MW. That is inconsistent with the recognition given in decision-making in recent years to the significant role which sub 50MW projects can play in meeting climate change targets.
Planning to succeed?
Veterans of consenting battles know that even the clearest policy statements can be weakened by opponents claiming inconsistencies elsewhere in the policy document. There is a reason why we keep saying the devil is in the detail....
The draft NPF4 needs much strengthening to ensure that sufficient consents will be granted in time for the additional 8-12GW of onshore wind to be installed in Scotland by 2030.
The Scottish Government's Position Statement referred to "Strengthening our support for repowering and expanding existing wind farms". However, the draft NPF appears to weaken the support.