RTPI Scotland's Response to the Onshore Wind Policy Statement Consultation

1. Does chapter 1 provide a fair reflection of the current situation faced by Scotland’s onshore wind industry?

• Strongly Agree
• Mostly Agree
• Neither Agree nor Disagree
• Mostly Disagree
• Strongly Disagree

Please give reasons for your answer

RTPI Scotland understands the intention of the Onshore Wind Policy Statement (OWPS) is to achieve a consistently higher rate of onshore wind and other renewables capacity is delivered in Scotland. At a strategic and local level, planning has a key role to play in identifying, developing and approving suitable developments, integrating and empowering key stakeholders and enabling communities to deliver low carbon, resilient and affordable energy networks^[1]. RTPI Scotland therefore welcomes the clear recognition in the document of the fundamental role the planning system plays in supporting this delivery, including explicit reference to the draft NPF4. However, RTPI Scotland wishes to stress that to do so, the planning system needs the appropriate support including up to date and clear policy; suitable resources; and fit for purpose consenting procedures. This is especially important when considering the diminished resourcing context of planning authorities with recent research from RTPI Scotland^[2] showing that:

• Nearly a third of planning department staff have been cut since 2009
• Planning authorities’ budgets have diminished in real terms by 42% since 2009
• In 2020 local authorities only spent 0.38% of their total net revenue budgets
• Planning application fees only cover 66% of their processing costs
• There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years

Research has also showed that planning has demographic and succession challenges with a limited pipeline. Only around 9% of staff in planning authorities are under 30 and there is an estimated replacement demand of around 500 planners over the next 15 years is required. There is a need to make sure that we have enough planners to process S36 applications and engage with communities on development plans. Given this RTPI Scotland wishes to stress the need to invest in initiatives to promote planning as a career and widen access to the profession through establishing apprenticeships. Handling onshore wind applications requires particular skills-sets for planners, with their height and movement making them very different to other forms of development. This includes being able to evaluate Landscape Capacity studies, Zones of Visual Influence (ZVI), Landscape and Visual Impact Assessments (LVIA), alongside relatively unique considerations of ecological impacts, construction on peatlands and aviation concerns. Therefore, RTPI Scotland also wishes to see investment in skills development for the next generation of planners to support the challenge of delivering enough renewable capacity for Scotland to meet its net-zero carbon ambitions.

Planning authorities (PAs) currently carry out an extensive amount of technical planning work on Section 36 consultations and require renumerated for such work. This includes their assessment, the drafting of decision and agreements, monitoring and enforcement – all of which are crucial to fostering approval from local communities. To support the processing of S36 applications and enhancing engagement regarding onshore wind with local communities at the plan preparations stage, PAs need to be properly resourced to do so. RTPI Scotland note the recent fee increase for Section 36 & 37 Electricity Act applications, including the voluntary contribution which the Scottish Government makes to planning authorities which was increased to 50% of the fee^[3]. PAs however receive a lesser fee than if they determine it themselves, especially if considering proposed increases to planning application fees^[4]. RTPI Scotland believes that any arrangement should be kept in review to ensure that the fee income received by PAs achieves full cost recovery.

RTPI Scotland supports the exploration of opportunities and challenges of having PAs determine more applications for onshore wind. If more applications were to be decided by PAs it could be argued that a more planned approach to onshore wind would be achieved, but also potentially greater involvement of communities throughout the consenting process. Alternatively, the threshold of applications of over 50MW, which are currently dealt with by Scottish Government Energy Consents Unit, could be reviewed. This is particularly relevant in light of technological advances leading to lesser numbers of turbines able to produce 50MW+ output. This may to an extent reduce any double handling that currently happens through the process.

2. How can the maximum number of developments be enabled to be constructed without finance acting as a barrier?

No comment

3. Can more be done to support the use of Power Purchase Agreements/Private Sector Finance? Is there a need for more policy signals from Scottish Government, and/or UK Government, to provide investment security/surety?

• Yes
• No
• I don't know

What more can be done to support the use of Power Purchase Agreements/Private Sector Finance?

No comment

Is there a need for more policy signals from Scottish Government and/or UK Government, to provide security/surety?

RTPI Scotland wish to highlight the importance for the draft NPF4 to provide enough clarity for decision makers handling with onshore wind proposals. Whilst RTPI Scotland broadly supports the updated policy on green energy within the draft NPF4, providing general support for renewable energy developments in many circumstances. We have some concern that this policy may require improved clarity over wording such as better defining what impacts are considered ‘unacceptable’ and share concerns that it is somewhat weakened by changes to other policies in the Framework.

4. Chapter 1 also underlines the Scottish Government’s strong commitment to the role of community energy, and to community benefit and shared ownership. In what ways can we maximise the benefits of these policies as onshore wind development and repowering increases over the coming decade?

RTPI Scotland believes that fostering public approval for climate change initiatives is key to ensuring the sustained implementation of low carbon policy and continued political support. Therefore, the transition to a low carbon economy provides both a social and a technological challenge for planners. Support from the public for onshore wind is growing with a recent poll showing 70% of respondents supportive of its deployment^[5]. It should be noted that shared ownership schemes tend to be more locally acceptable and can help offset the impacts of renewable projects on the landscape, good practice principles for which are available online^[6].

The process of identifying sites for onshore wind should begin with constructive engagement at the earliest possible stage. SPP instructs planning authorities to set out in the development plan a spatial framework identifying those areas that are likely to be most appropriate for onshore wind farms as a guide for developers and communities. RTPI strongly supports the recent drive towards a more plan-led system, with development plans forming the basis of planning decision-making to enable the right developments in the right locations. The enhanced participation of communities in the plan making process will be critical to increasing local determination, encouraging collective problem-solving and enabling communities to clearly signal appropriate local sites for renewable energy projects to developers.

RTPI Scotland believes that meaningful consultation should consider the impact of decisions by conveying the constraints and opportunities. RTPI Scotland would like to highlight the crucial role that Strategic Environmental Assessments (SEAs) play in underpinning a plan-led approach to renewables - as a systematic method for considering the likely environmental effects of renewables and by facilitating openness and transparency of decision-making. The SEA tells the story of the plan-making process: it documents how planning decisions have been made, and how they have been informed by environmental and sustainability concerns. Through the SEA process, statutory consultees and the public can submit comments, reflected in the scoping and assessment reports alongside any changes have been made in response to these comments. RTPI Scotland notes the available planning advice note for onshore wind turbines which supports an 'early and effective' opportunity for the public to engage in policy development and their environmental effects as part of the SEA process^[7]. A recent review of SEA within development planning conducted by Scottish Government recommended developing policy and guidance on community engagement when integrating considerations of SEA issues in the plan preparation process. This includes using engagement activities with public and stakeholders to highlight environmental information and ensure that the public see the connection between the draft plan and the environmental report^[8]. In particular, buy-in at the baseline stage could be used to understand what local people value and how that should be reflected in policy. To encourage public engagement with the SEA, RTPI Scotland believes that SEAs need to be presented in such a way that it can be readily understood with nontechnical summaries of particular importance and technical, lengthy tables avoided or placed in appendices^[9].

Local Place Plans (LPPs) were introduced as a provision in the Planning (Scotland) 2019 Act. This new type of community led plans provide opportunities for communities to develop proposals and ideas for the development of where they live. LPPs can help community planning and land-use planning achieve better outcomes for communities. RTPI Scotland note that the recently published Local Place Plans – ‘How To’ Guide: Literature Review and Final Report was silent in regards to the role they could play in renewable energy developments^[10]. However, if combined with a rigorous site assessment process to make sure the land is suitable for development, LPPs have the advantage of being developed at a more granular level with local community buy-in about the types of development that are needed and the best locations for the proposals.

At the application stage a two-way dialogue between developers and communities should place emphasis on the conflicting demands that planning authorities have to reconcile which the aim of developing solutions that are viable, rational and legitimate. RTPI Scotland notes the Scottish Government’s suite of Good Practice Principles for renewable energy developments is a useful starting point^[11]. Pre-application consultations (PAC) are an important part of the development management process. Through early engagement with prospective applicants and communities, the planning authority and statutory consultees have an opportunity to discuss important issues in advance of the submission of a formal application. They can improve the quality of planning applications, mitigate potential negative impacts, address misunderstandings and where practicable, address community issues. RTPI Scotland wish to highlight new duties with the potential to support this engagement process that are set out in the Planning (Scotland) Act 2019 including recently issued guidance on the promotion and use of mediation in planning^[12] and changes to the PAC process to include two public events. It is worth noting than ongoing community engagement beyond the pre-application and planning application stages was recognised as an important factor in a review of good practice for windfarm applications^[13].

RTPI Scotland would support the drafting of new onshore wind planning guidance which promotes practical measures to improve the consenting process. This would include some demystification of the consenting process for communities, with current practice involving a vast array of technical information which communities may struggle to engage meaningfully with. RTPI Scotland believes there is a valuable opportunity to improve community engagement with onshore wind proposals through the increased use of digital technologies. The recently launched Scottish Government Digital Planning Strategy^[14] has a range of ambitions to enhance community engagement including:

• Engage and involve a wider diversity of community members to contributing to placemaking through new digital tools and channels to interact.
• Overcome organisational and sectoral boundaries through use of ‘Place-based’ data to encourage better collaboration and community involvement.
• Increase efficiency of community engagement through use of engagement tools that analyse responses digitally.

The COVID-19 pandemic has already necessitated innovative solutions from developers when engaging communities on onshore wind proposals. Many have now developed a suite of materials and digital tools for broader community engagement such as virtual village hall exhibitions, digital feedback functions and 3D visualisations to better convey the expected visual impact of proposals. It should be noted that this could be particularly beneficial for communities who might be experiencing consultation fatigue from multiple windfarm proposals in their areas.

5. What more can be done to ensure that financial mechanisms are available to support development at differing scales?

Planning plays an essential role in delivering net zero carbon targets and supporting a green recovery. Planners can integrate energy, transport and land use planning, encourage sustainable travel, develop the best local solutions to low carbon energy and deliver well located and energy efficient developments. RTPI Scotland believes there is significant opportunity to better co-ordinate infrastructure planning and investment at a regional level to support net zero ambitions. A key financial mechanism which could support delivering a wide range of renewable energy development are City-Region Deals. Beyond unlocking economic growth, with the correct implementation, City Deals and Regional Economic Partnerships should also generate a wide array of social and environmental benefits for the country. If City Region Deals are to provide this transformational change for our communities they need to be part of a strategy that integrates approaches to economic, social and environmental issues, including addressing net zero carbon ambitions. To do so they need to recognise how a range of investments across the region can complement one another and bring mutual benefit and look beyond the immediate to ensure that investments bring sustainable and lasting benefits in the longer term.  They cannot be a list of individual projects and initiatives sitting in isolation. To unlock this transformational change, integration and alignment with other national and regional strategies will be essential. These include:

• Emerging Regional Spatial Strategies
• Regional Economic Partnerships
• National Planning Framework 4 (NPF4)
• National Transport Strategy
• National Economic Strategy
• National Energy Strategy
• National Marine Plan
• Land Use Strategy
• Historic Environment Strategy
• Fairer Scotland Action Plan
• National Waste Management Plan
• Regional Transport Partnerships

Currently the measure of the success of investments from City Region Deals is based upon their contribution to GVA.  We believe that a more holistic approach is required if the City Region Deals are to deliver transformational change and this must mean that environmental and social benefits are also aimed for.

6. What are your views on the level of installed onshore wind capacity that will be necessary over the coming decade, recognising the ambition Scottish Government have proposed for 8-12GW? Please share any analysis that you, or your organisation has conducted on the onshore wind contribution to net zero, or any personal perspectives you have.

RTPI Scotland understands that onshore wind developments can pose a particular challenge balancing the need to protect Scotland’s landscape quality and peatlands, deliver wider community benefits and deploy sufficient electricity generation capacity to meet net-zero targets. With existing consented schemes having been completed on less sensitive sites, it is likely that there will be further public concern as new developments are proposed on more sensitive local landscapes. Therefore the need to resource the planning system sufficiently to support the government’s ambition in delivering onshore wind needs to be seen both in terms of improving performance of the consenting regime but also through fostering public approval through meaningful community engagement.

7. What more can be done to capture the potential and value of hydrogen production from onshore wind and how best can we support the optimal integration of these technologies?

No comment.

8. In what way(s) can we maximise the benefits of repowering over the coming decade?

No comment.

9. We would be grateful for comments on the issue of aviation lighting and suggestions for the focus and outputs of the Aviation Lighting Working Group – what are your views on the assessment of aviation lighting and how this should be undertaken?

No comment.

10. We would also be grateful for your views on network charging and any of the other aspects set out under section 3.4.

No comment.

11. What are your views on the integration of taller turbines in forested areas?

RTPI Scotland would like to highlight that that regulation and guidance for Forestry and Woodland Strategies, provisions for which are set out in the Planning (Scotland) Act 2019, are still to be published. Consideration may be needed as to whether they will align with any policy ambitions of encouraging integration of onshore wind with forestry.

12. Can you provide best practice examples for effective peatland restoration (with carbon benefits) alongside the development of onshore wind?

No comment.

13. What, if anything, is not currently reflected in the good practice guidance for constructing windfarms, in relation to building on peat and other carbon-rich soils?

No comment.

14. From your own experience what can wind farm developments offer in terms of protecting and enhancing the natural environment, in particular through the planting of trees to compensate for those lost during windfarm development and through peatland restoration?

No comment.

15. Can you provide best practice examples of encouraging biodiversity protection and enhancement, including connectivity between natural areas in wind farm sites?

No comment.

16. What is your organisation doing to go above and beyond when it comes to biodiversity protection, conservation and enhancement in wind energy development sites?

No comment.

17. How can habitat management plans better balance protection of the environment with connectivity and the operation requirements of a site?

No comment.

18. What support do Scottish companies need from Scottish Government and agencies in order to successfully bid for and win contracts for the development, construction and operations of onshore wind farms?

Production of the new energy infrastructure required for renewables can be identified as an opportunity for regional industrial growth. By encouraging the creation of vertically integrated supply chains the cost of renewable energy electricity generation, transmission and distribution can be lowered whilst simultaneously stimulating the economic regeneration of areas. RTPI Scotland believe that effective regional economic planning will be key to supporting the development, construction and operations of onshore wind farms. Please see answer to Q5 in this regard.

19. Should government consider options for introducing a sector deal similar to that of the Offshore Wind sector and if not, why is that your view?

• Yes
• No
• I don't know

Please explain your reasons

No comment.

20. How can individual organisations (including onshore wind developers, tier 1 suppliers, and the domestic supply chain) work collaboratively to ensure that key manufacturing projects for Scottish onshore wind stays in Scotland?

No comment.

21. Circular economy and zero-waste are core principles that the Scottish Government are promoting. Where do you see the economic opportunities in relation to these policy issues lying with onshore wind? And are there any practical issues you think need to be addressed in order to maximise the benefits?

No comment

22. How can the Scottish Government best support skills for the future of the onshore wind sector? Specifically we would be interested in oil and gas transition, apprenticeships and entry-level positions for young people, as well as any other experiences you can share.

RTPI Scotland would like to reiterate as set out in Q1 that ensuring a strong pipeline of planners will be fundamental to supporting delivery of onshore wind through the planning system. Therefore RTPI Scotland wish to see a broader consideration of the jobs and skills involved in the sector and would be very supportive of any support from stakeholders in exploring the options for establishing a planning apprenticeship.

23. Do you have any views on the impact of wind farms on tourism?

No comment.

24. What is your organisation doing specifically to promote diversity and inclusion in the onshore wind sector?

No comment.

25. Given the significant contribution onshore wind is expected to make to our net-zero ambitions, and the structure of the ScotWind process for offshore development, should Supply Chain Development Plans be introduced for onshore wind developments in Scotland?

• Yes
• No
• I don't know

Please provide any comments or details explaining your response

No comment.

26. Does the position described in the draft Onshore Wind Policy Statement accurately reflect your view on the current position in relation to the Eskdalemuir Seismic Array and the barrier it presents to deployment in Scotland?

• Strongly Agree
• Mostly Agree
• Neither Agree nor Disagree
• Mostly Disagree
• Strongly Disagree

Please provide any comments or details explaining your response

No comment.

27. Acknowledging that the Scottish Government require further evidence before taking a policy decision, at this point and reflecting the options outlined above do you/your organisation have any thoughts?

No comment.

28. If Option 2 or Option 3 were to be selected, how could we best achieve or calculate an acceptable level of impact? (One example being an agreement of a standard noise budget to MW generated proportional allocation I.e., for X MW generated = X amount of budget allocated).

No comment.

29. Do you/your organisation have any thoughts on how the Eskdalemuir Working Group (EWG) might be restructured to ensure continued engagement for interested parties whilst maintaining the core purpose of the group?

No comment.

30. We are clear on the value and importance of strategic and productive collaboration between the aviation and wind energy sectors. What are your thoughts on our proposed restructuring of the current effort and activity in this area, and the proposed Aviation and Renewables Collaboration Board?

No comment.

31. The work of the Aviation and Renewables Collaboration Board may identify and agree the need technical or strategic investment to achieve specific goals or outcomes. What are your views on how work of this kind might be financed?

No comment.

 

[1] RTPI (2017) Renewable energy - Planning's role in delivering renewable energy in the new low carbon economy. June. Available here: https://bit.ly/3lHBO5r

[2] RTPI Scotland (2021) Resourcing the Planning Service: Key Trends and Findings 2021. June. Available here: https://bit.ly/3s5h4Yc

[3] Scottish Government (2019) Fees charged for applications under the Electricity Act 1989 consultation: our response. January. Available here: https://bit.ly/3ks8RLg

[4] Scottish Government (2019) Planning performance and fees: consultation. Available here: https://bit.ly/3ixV3xI

[5]  Department for Business, Energy and Industrial Strategy (2021) Public Attitudes Tracker: Wave 37. May. Available here: https://bit.ly/39t2EIA

[6] Scottish Government (2019) Community benefits from onshore renewable energy developments. May. Available here: https://bit.ly/3CzBz33

[7] Scottish Government (2014) Onshore wind turbines: planning advice. May. Available here: https://bit.ly/2XEgJQN

[8] Scottish Government (2018) SEA Review Recommendations. Available here: https://bit.ly/3o3pBuq

[9] RTPI (2018) Strategic Environmental Assessment. Improving the effectiveness and efficiency of SEA/SA for land use plans. January. Available here: https://bit.ly/2ZjywxK

[10] Scottish Government (2021) Local place plans: literature review and final report. March. Available here: https://bit.ly/3CwIBph

[11] Scottish Government (2019) Good practice principles for renewable energy developments consultation: analysis of responses. April. Available here: https://bit.ly/39mdosz

[12] Scottish Government (2021) Planning circular 2/2021 - planning system - promotion and use of mediation: guidance. July. Available here: https://bit.ly/2W1g37L

[13] Aitken M., Haggett C., & Rudolph D (2014) Wind Farms Community Engagement Good Practice Review. June. Available here: https://bit.ly/2VYOPPf

[14] Scottish Government (2020) Transforming Places Together: digital strategy for planning. November. Available here: https://bit.ly/3nWz7Qm