Driving the Low Carbon Economy - Policy Paper 5: Planning

8/8/2019 Driving the Low Carbon Economy - Policy Paper 5: Planning

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DRIVING THE

LOW CARBONECONOMY PAPER 5: planning

RECOMMENDATIONs

✓ EnsurE a transparEnt and timEly consEntsprocEss

✓ continuE to dElivErstrong policy andpolitical supportfor all forms ofrEnEwablE EnErgy

to EnablE dElivEry of scottish and uK govErnmEnt targEts

✓ alignmEnt of localdEvElopmEnt planswith national policy

✓ EffEctivE linK bEtwEEnrEnEwablE EnErgy projEcts and thE localcommunity

✓ clarity from

statutory consultEEs

introductionThis policy paper is the fth in the Driving the Low Carbon Economy

series produced by Scottish Renewables to outline what investment

and concerted support across all levels of government is required

to realise Scotland’s ambitions of meeting at least 80 per cent of

our electricity needs by 2020. Meeting or exceeding targets will put

Scotland on a path to delivering a low carbon economy, securing

massive environmental, economic and social gains for our country.

This paper outlines the priorities for government, industry and stakeholders

towards creating effective and efcient consenting regimes that balance the

need for renewable energy development with other interests. The terrestrial

and marine planning systems in Scotland must remain modern and able

to cope with the demands of the growing renewables industry by ensuring

appropriate, effective and timely decisions.

In this paper we consider ways in which the Scottish planning system

could be enhanced to support the delivery of renewables development and

help secure the achievement of Scotland’s renewable energy and carbon

reduction targets.



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I n s t a l l e d C a p a c i t y ( M W )

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2010

thE story so far...Scotland’s planning system is undergoing the most

signicant modernisation in over 60 years. With the

implementation changes introduced by the Planning Act currently underway there has never been a more

important time for planning.

It is the stated aim of the Scottish Government to

deliver a planning system that is: efcient, inclusive, t

for purpose and sustainable.

There is a huge amount of potential to develop

renewable energy in Scotland. To realise this we need

to ensure that the regulatory and planning regimes work

together to minimise delays, reduce costs and ensure

applications are dealt with as efciently as possible.

whErE arE wE now? At the time of writing (November 2010) there were just

over 3.5 GW of renewable energy projects awaiting

planning determination in Scotland, with onshore windaccounting for over half of this potential capacity.

With around 10 GW of offshore wind and 1.6 GW of

wave and tidal projects in the early stages of scoping,

the size of development off our shores is due to increase

massively over the next decade and beyond.

The renewables industry prides itself on maintaining

a responsible reputation and this is why a robust and

transparent planning system is so important for the

growth of the industry.

Scottish Renewables has been pleased to see a drive

from the Scottish Government towards a speedy,

efcient and inclusive planning system which has

undoubtedly assisted many projects to gain consent.

The consolidation of policy into the streamlined Scottish

Planning Policy has generally been successful and

resulted in a useful document.

We support the positive role the Scottish Government

has played in guiding local authorities within this

framework and encourage the Scottish Government

to ensure availability of resource in order to deliver an

efcient system.

The Scottish Government must continue to ensure key

messages transfer from central to local government

so that all applications are determined on their merits

against identied, broad criteria that is consistent with

national policy.

what nEEds to changE?

Align policies with obligations on Renewables

and Climate Change

As the renewables industry grows and the areas of

least constraint for development decrease, projects

need to adapt to nd the best way of achieving

acceptable design in more sensitive environments.

Equally, the Scottish Government must nd a way of

balancing competing policy agendas to ensure that

renewable energy can deliver these changes. Many of

these challenges face a common theme: the impact of

outdated regulation that does not fully take account of

the national and European obligations on renewable

energy and climate change.

fe 1. Capacity of renewables projects in the planning

system from November 2008 to November 2010.

Advocate a positive local approach

It is critical to the achievement of our renewable

energy and carbon reduction targets and to driving

sustainable economic growth that local planning

authorities (LPAs) adopt a genuinely positive approach

towards renewable energy development, recognising

both national priorities and the local socio-economic

benets of projects.

In some local authority areas, level of response to

scoping is not currently as comprehensive or upfront

as it could be. Consequently additional issues are often

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T o p f r o n t p a g e p i c t u r e : T e d L e e m i n g



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raised post submission with associated time and cost

implications. This would be improved through positive

and proactive pre-application engagement between

developers, planning authorities and consultees for

all types of projects, leading to meaningful and clearscreening and scoping advice for projects requiring an

environmental impact assessment.

A number of local authorities are recognising the

economic development potential of renewable energy,

not only from commercial projects but through, for

example, Council’s new powers to generate their own

energy. However this connection needs to be made

across all planning authorities.

Clarity of decisions from Statutory Consultees

Scottish Renewables welcomes engagement with

statutory consultees when working to address sensitive

issues, and we engage closely with Scottish Natural

Heritage (SNH) to work through issues of shared

interest and to develop good practice guidance of

mutual benet to the industry and SNH.

SNH recently produced a guidance document

conrming the agency’s approach to determine whether

impacts on natural heritage raise issues of national

interest; if they do not, SNH will only use objections

“sparingly.” This change in approach is of concern

to industry as it enables local ofcers to comment

extensively on a proposal but falls short of offering

objection or support for the project, resulting in a lack

of clarity to planning ofcers.

Consistent Local Planning Guidance

We are pleased to see the drive from the Scottish

Government towards a speedy, efcient and inclusive

planning system and we welcome the up to dateDevelopment Plans that have been drafted and

completed in accordance with SPP with appropriate

industry involvement.

However some authorities have so far failed to update

Development Plans or provide supplementary planning

guidance to reect the SPP approach, while a number

of those that have developed policies appear to have

adopted a defensive approach to renewables. Not only is

this at odds with the inclusive approach directed in SPP,

but it is also at odds with the approach to other areas

of policy development (for example, in housing, where

housing providers are directly involved in monitoring

and in strategy and policy development). The Scottish

Government should provide a clear steer to local

authorities to only develop and adopt a Development

Plan and supplementary guidance that are consistent

with national policy, and that any plan or guidance that is

adopted without consultation is likely to be given limited

weight in the determination of planning appeals.

We are also concerned that a number of LPAs

are departing from national policy and guidance.

Some have produced additional guidance, without

consultation, that diverges from national guidance.

This places additional, excessive requirements and

cost on developers and is inconsistent with nationally

recognised good practice.

Enhance link between project and community

The renewable energy industry in Scotland has a strongtrack record of positive engagement with communities

from pre-planning right through to construction and

operation of projects. This can include sharing some of

the nancial rewards and in a few cases sharing project

risks with communities.

The most successful examples of good practice are

where strong dialogue with communities has taken

place early and throughout the process and also where

a exible and voluntary approach has been applied

leading to good partnership working and a strong bond

between the community and the renewables project.

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Scottish Renewables has learned of specic instances

where local authorities have requested a proportion of

community benet payments to be directed towards

inappropriate uses, such as affordable housing.

Such requests, which are in conict with ScottishGovernment planning guidance, put the developer

seeking planning consent in a difcult position.

Communities are beneting throughout Scotland from

renewable energy projects as a result of effective

dialogue between communities and developers.

Further progress could be made through consideration

of the following actions.

Prompt implementation of General Permitted

Development Rights

Micro-renewables can make a valuable contribution

to a sustainable, low carbon economy by generating

useful energy at the point of demand. Therefore we are

pleased to see that measures are being considered

which will reduce the burden on the consumer and the

planning system, however we need a prompt decision

to allow this to happen.

Supportive advice on renewables

We support the current revision of PAN 45; it is critical

that this advice remains supportive and aligns with

government policy.

Address duplication in water licensing

There is currently duplication between planning and

the water licence processes, resulting in ‘double

jeopardy’ for developers. The planning authority as a

democratically accountable authority is best placed to

consider the social and economic impacts, including

recreation, of an application.

Effective marine planning framework

We welcome the one-stop-shop approach that has

accompanied the creation of Marine Scotland and

the level of engagement we are seeing with industry.It is imperative that the Scottish Government get the

framework right to deliver timely, efcient and inclusive

decision making.

conclusionIn order to achieve our low carbon ambitions, the

Scottish Government needs to address the increasing

cumulative, regulatory burden being experienced by

the renewables industry from a range of government

departments and agencies, whilst continuing to

ensure support for the renewables industry - which is

clearly present at national level - is properly reected

in local plans and supplementary guidance. This

requires ongoing monitoring of the implementation

of the modernised planning system, and the Scottish

Government needs to be prepared to make changes

where necessary to ensure it is delivering its aims.

The above examples are only a relatively small - yet

signicant - proportion of the regulatory pressures being

faced by the industry. Combined, these constraints

threaten the ability of the industry to deliver projects

at reasonable cost, and to meet Scotland’s renewable

energy targets and ambitions for 2020 and beyond.

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Driving the Low Carbon Economy - Policy Paper 5: Planning

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