Making plans

21/12/15 | Blog

Scotland's planning system is key to the success of the renewable energy sector. As the Scottish Government sifts responses to a review of the process, Policy Manager Stephanie Clark gives the headlines from Scottish Renewables' submission.

While the Scottish Government's commitment to renewable energy has been steadfast, Holyrood's powers to influence the policy landscape around the sector are, by its own admission, limited.

We do however have our own planning system. An ongoing review of that system provides Scottish Government with an opportunity to ensure we continue to make the most of our renewable energy assets.

Scottish Renewables’ response, submitted this month, sets out a number of crucial issues.

Development Planning

Planning policy at a local level, in both Local Development Plans (LDP) and Supplementary Planning Guidance (SPG), does not always align sufficiently with Scottish Planning Policy. This can cause delay and expense for developers.

Our suggestion is that the Town and Country Planning (Scotland) Act 1997 should be amended to include a statutory obligation on local planning authorities to "take into account" the SPP (there exists an obligation to take into account the National Planning Framework (NPF) but not the SPP) and that departures from it are justified only by compelling local factors.

In addition, recent cuts to the UK support framework for renewables mean the approach to onshore wind needs an urgent review to ensure that an appropriate, proportionate and streamlined framework exists which does not place unnecessary burden or cost onto the development process.

Wild Land

It is essential that the Scottish Government’s wild land policy strikes the right balance between protecting Scotland’s outstanding natural habitats and accommodating renewables developments where appropriate.

More than 20% of Scotland – our National Parks and National Scenic Areas – is already deemed a no-go for wind farm developments, with the full support of industry. The wild land areas in Scottish Planning Policy were not intended to rule out further development but instead mean that increased protection is in place to ensure that developments which go ahead do not have unacceptable impacts.

The planning process must strike the right balance between protecting Scotland’s environment and ensuring that proposals are not discouraged or unfairly treated. If this balance is wrong Scotland will lose out on sites which will ultimately help us meet environmental objectives while benefitting our economy.

Development Management

Development Management has improved, but there remain concerns among members with the decision-making process as well as the time taken for decisions to be reached.

We would welcome further discussions to explore interventions which could further improve the efficiency of the process. For example, whether planning fees should be ring-fenced to pay for the service provided in return for a fast-tracked and efficient process.

Environmental Impact Assessment

Feedback from members suggests smaller developments are often required to submit similar amounts of information as larger developments, which increases both the duration of the process and project costs.

There is a need for greater focus on the critical environmental issues to ensure screening and scoping are project-specific to avoid unnecessary work.

Post-planning variation procedures

Experience from our members suggests post-planning variation procedures vary greatly by planning authority due to differing definitions of what constitutes a material and non-material variation. In order to address this inconsistency, clear and concise guidelines are required to set out what constitutes a material change.

Heat Networks

More progressive planning policies would help drive forward and deliver the step change in development needed to meet Scotland’s renewable heat targets.
We would recommend that the Scottish Government consider a similar commitment to district heating as set out in the London Plan, which requires some development proposals to evaluate the feasibility of combined heat and power.

Scottish Renewables’ full response to the Planning Review also includes sections on Schemes of Delegation, repowering and Decommissioning and Restoration Bonds. It can be found here.