Local development planning - regulations and guidance: consultation

No – there is currently a lack of recognition of the climate emergency and net-zero targets. Additional text is required to emphasise the importance of renewable electricity generation. SSERs comments on Draft NPF4 raise significant concerns regarding the ambiguity of policies in that document, supporting renewables on the one hand, but with the wording of protectionist policies which do not recognise the need for a balance of considerations in favour of the national priority of tackling the climate emergency and energy security. Although it is essential anyway, if LDPs have minimal policy wording then it is even more essential that NPF4 avoids the use of conflicting policies which could lead to uncertainty and confusion for decision makers. In our strong view, the policy framework in Draft NPF4 is not sufficient to allow minimal wording in LDPs.

No. The guidance should identify how the Delivery Programme should deal with the key objective of delivering accelerated and significantly increased renewable electricity generation.

No. There is a lack of reference to renewable electricity generation. If capacity is to be significantly accelerated and increased, as is necessary to meet net-zero targets, then a far better understanding of the baseline position is required than at present. For example, it should be recognised that a significant number of consented projects do not work in a subsidy free world, and are also based on turbine heights which will no longer be available on the market.

No. SSER consider that the Call for Ideas should be a mandatory part of the process, ensuring that all stakeholders have an opportunity at the outset to express their opinion on the content of the LDP. Moreover, we consider that the Call for Ideas be initiated before the preparation of the Evidence Report.

No. SSER, in accordance with its comments on Draft NPF4, recommends that the Climate Emergency, Energy Security, Net-Zero Targets and Renewable Energy Generation are included in the Themes identified in Figure 6. In our view, it is a significant omission not to include these key underlying topics in the key themes for both the LDP Guidance and NPF4.
SSER recommend that the Evidence Report should identify the deliverable baseline supply of renewable electricity generation.

No. There is obviously an inter-relationship between Draft NPF4 and this LDP Guidance. SSER is very concerned that Draft NPF4 does not go far enough in its efforts to address the climate emergency or energy security concerns, particularly in respect to meeting the Scottish Government’s net-zero targets, and the vital role that onshore wind energy has to play, particularly in the short-term.

Although Draft NPF4 begins to recognise that a rebalancing of planning considerations is required in order to significantly increase renewable energy supplies, this is not reflected in some of the individual policies. Indeed, we believe that if NPF4 is approved in its current form, it will perpetuate and perhaps exacerbate cumbersome and lengthy processing of applications and refusal of applications because of policies which are directed against onshore wind, particularly in respect to landscape.

Although Draft NPF4 says that significant weight should be given to the Global Climate Emergency, which SSER welcome, this has no clear meaning in itself for the content of local development plans and the assessment of individual wind energy applications. That would be fine if the topic specific policies in Draft NPF4 provided that clarity, but they do not.

Instead, the detailed policies on such topics as Nature Crisis, Green Energy, Historic Assets, Natural Places and Soils place unnecessary barriers on renewables, creating a balance of planning considerations that will prevent necessary development rather than support it. At best, the policy framework in Draft NPF4 is highly ambiguous, on the one hand supporting renewable electricity generation, but on the other hand continuing to apply strict protectionist policies against development.

This, in our view, will result in significant uncertainty and inconsistency in decision making, which will perpetuate existing conflict and delay in the planning process sending uncertainty into the supply chain and significantly reducing the likelihood that we will meet our net-zero targets.

It is therefore absolutely crucial that NPF4 and LDPs do not contain such negativity and ambiguity and instead drive forward a clear policy framework for the delivery of renewable energy, and onshore wind in particular, as a priority. The balance of planning decisions must shift significantly towards allowing development, and in our view the mechanism to achieve that is ‘a presumption in favour of strategic renewable electricity generation’.

A further concern for SSER is the length of time it will take new LDPs to be prepared and adopted, which realistically will not be until 2027 in most cases. They will therefore not be in place quickly enough to guide the imperative of delivering onshore wind energy in the short-term. NPF4 should therefore make it clear that the presumption in favour is immediately applicable.

The landscape of a net-zero Scotland will look different from our current landscape, and it will include more and taller turbines in addition to forested hills, active wetlands, and restored peatland. All of this should be viewed as a positive sign of a progressive nation proactively addressing the climate and biodiversity emergencies in an integrated way. In rebalancing policy, it is essential that it reflects established public opinion where the majority consider onshore wind a positive addition to Scotland’s landscape and moves on from the outdated narrative of some that onshore wind is an inherently negative addition to our landscape.

SSER agree with paragraph 412, which is unambiguous in its support for renewable electricity generation.

No. As explained above, great care is required to avoid creating significant ambiguity in decision making. SSER’s response to Draft NPF4, and as referenced above, is deeply concerned that there are conflicts between some protectionist policies and the need for significantly accelerated increases in renewable electricity generation. That is why SSER is strongly recommending a ‘presumption in favour’ of renewables. It is important that matters of lower priority e.g. assets of local or regional rather than national importance; are not given status in LDPs or NPF4 that is equal to the national priority of tackling the climate emergency. Any ambiguity on this point will create confusion for investors and decision makers, resulting in conflict and delay.