Patrick Munro

and I attended the Scottish Renewables Planning Conference this week, where the industry was debating what the implications are of the recently adopted National Planning Framework 4 (NPF4) and how that can translate into delivery of the development needed to reach net zero targets.  Five key things that we took from the discussion were:

1. Optimism – NPF4 contains significant policy support for renewables, with policy 1 requiring decision makers in all planning applications to give significant weight to the climate and nature emergency and policy 11 giving in principle policy support to all renewable technologies.  There was a consensus that the planning policy position is in the best place it has been for a long time and should give the policy certainty required to support delivery of developments.

2. A need for speed (in decision making) – Decision making on applications needs to speed up if Scotland is to meet its 2030 and 2045 targets.  Section 36 applications that go to a public inquiry are taking on average over three and a half years to determine from the point of application.  Speakers from the Energy Consents Unit and the DPEA stressed that they are working to reduce decision making timescales.  Key messages for developers were: (i) make sure that your application documents are thoroughly prepared, (ii) amending the scheme during the process will cause delay and (iii) providing summaries of cases at the end of an inquiry procedure can help speed up the time it takes a Reporter to draft their report to the Scottish Ministers. 

3. Leadership and bravery – It has taken 30 years for Scotland to reach an installed capacity of 9GW of onshore wind and there are now less than seven years left to install a further 11GW to meet 2030 targets.  To reach those goals will need strong leadership and bravery from all parties that play a role in the planning system.  That could be a developers and decision makers working together to ensure applications are focused only on the points that matter and that an EIA no longer needs to be thousands of pages long.  It could be greater collaboration between developers to share data and work together on matters such as habitat improvement.  It was agreed by all in the room that ‘business as usual’ was not going to be enough going forward.

4. Biodiversity enhancement – a need for definitive guidance – Policy 3 of NPF4 requires Major or EIA development (as many renewable developments will be) to demonstrate that the proposal will enhance biodiversity.  There was strong support in the room for the intention of this policy and it was recognised that renewable developments have already been contributing to enhancement through habitat management plans, peatland restoration etc.  However, there was concern that without clear guidance on what this policy required, this policy could create problems when developers attempt to evidence compliance.  There was a call for guidance to be produced as soon as possible, together with a metric suitable to Scotland that will allow biodiversity enhancement to be measured and evidenced.

5. Just do it! – The renewables industry now has the strong planning policy support that it has for many years been calling for.  It is now time for the industry, government, local authorities, communities and other key stakeholders to work together to deliver great projects that will make a significant contribution to Scotland reaching its climate change targets.

Earlier this we delivered our first webinar in our 2023 Planning and Compulsory Purchase Webinar Series, where we discussed NPF4 and what this means for development in Scotland, including renewables.  If you missed it, a recording is available on our website.  Head to Planning and Compulsory Purchase Webinar Series 2023 (burges-salmon.com) and click “register” to watch.