The recent approval by the Scottish Government of the Revised Draft NPF4, comes in tandem with the publication of key policy documents; Onshore Wind Policy Statement 2022 and Draft Energy Strategy and Just Transition Plan. All documents emphasise the drive to achieve Net Zero by 2045 in Scotland and the significant role which the renewable energy sector can play. Principal Consultant, EIA, Jenni Mcleod offers a brief summary of the key elements with regards to renewable development and what the implications for developers.
NPF4 Revised Draft
Approved by the Scottish Parliament on 11th January 2023, the Revised Draft NPF4 was approved by the Scottish Government on 11th January and on its way to becoming the statutory development plan, with the intention Scottish Ministers will adopt and publish NPF4 on 13th February 2023.
Once adopted, NPF4 will have increased status in comparison to NPF3 and will become part of the statutory Development Plan, allowing its policies to have a stronger role in day-to-day planning decision making. NPF4 will also supersede Scottish Planning Policy, setting objectives for Local Development Plans (LDPs). At that point strategic development plans (i.e. the city regions plans for Aberdeen Dundee Edinburgh and Glasgow) and any supplementary guidance issued in connection with them also cease to have effect.
Throughout NPF4 weight is given to the dual global climate and nature crises (Policy 1), with the importance of renewable energy generation targets and on greenhouse gas emissions reduction targets (Policy 11). Notwithstanding, the application of the policies within NPF4 remains open to interpretation, with the room for personal judgement.
Landscape: Landscape and visual policies show a marked change in approach and intent from NPF3. Policy 11 in particular recognises the necessary impact from renewable developments, while noting these are likely to be deemed acceptable with the application of appropriate design mitigation. As such, during the planning stage there will an increased need for emphasis on the overall design development process.
Wild Land: Policy 4 notes renewable energy development in Wild Land Areas will be supported where the proposal “will support meeting renewable energy targets”, subject to an appropriate impact assessment and if necessary, mitigations. Wild Land Assessments are now also only considered to be required for areas within WLAs.
Peatland: Under Policy 5, development proposals on peatland, carbon-rich soils and priority peatland habitat will only be supported for (amongst other development types) the generation of energy from renewable sources that optimises the contribution of the area to greenhouse gas emissions reductions targets and will require a detailed assessment of the peat and the likely net effects on climate emissions and loss of carbon. Development design will be required to follow the mitigation hierarchy, be in accordance with guidance and consider other appropriate plans required for restoring and/ or enhancing the site into a functioning peatland system capable of achieving carbon sequestration.
The full revised draft is available here
Onshore Wind Policy Statement 2022 (OnWPS)
Published on 21st December 2022, The OnWPS 2022 outlines the Scottish Government’s ambitions and aspirations for the Onshore Wind Sector, highlighting how these can be delivered. The urgency and relevance of the sector is stressed through the statement that “We must now go further and faster than before”.
Landscape: A renewed approach to Landscape and Visual effects is evident, with the acknowledgement that changes to the landscape will occur as taller turbines will be required in order to meet the ambition of “a minimum installed capacity of 20 GW of onshore wind in Scotland by 2030”.
Community Benefits: Developers are encouraged to further explore the shared ownership opportunities, whilst acting as ‘good neighbours’, working in tandem with local communities, communicating over the course of a wind farm’s life and building good relationships.
Peatland: The Scottish Government outline their intention to convene an expert group to provide advice on this subject. The report also notes work is underway to update or replace the Carbon Calculator – so one to watch in the future.
Biodiversity: The sector is expected to step up to the challenge of biodiversity loss by showcasing considered schemes. Best practice examples are provided with the expectation that all developers will draw on these when demonstrating a clear commitment to biodiversity. There is an opportunity for the sector to make the most of the current approaches to biodiversity to maximise habitat and biodiversity enhancement opportunities as integral aspects of development proposals.
The full OnWPs can be found here
Draft Energy Strategy and Just Transition Plan
Published on 10th January 2023, the Draft Energy Strategy and Just Transition Plan details the Scottish Government’s key ambitions for Scotland’s energy future, as well as “proposing a vision for a just energy transition” which provides socioeconomic benefits whilst protecting the environment and providing energy security.
Further emphasis on the socioeconomic benefits which the renewable energy sector can offer is reiterated through the ambition that “By 2030 the volume of renewable electricity produced in Scotland will open up huge opportunities for electricity export….. contributing to economic growth, jobs and investment.”
As in OnWPS, the document encourages developers to offer community benefit and shared ownership opportunities “as standard on all new renewable energy projects, including repowering and extensions to existing projects”.
Consultation questions are available in Annex B of the text with responses encouraged by 4th April 2023.
The draft strategy can be found here.
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