4 DEVELOPING OPTIONS
4.1 INTRODUCTION
It is the overall objective of the Scottish Executive that SPP 6 delivers the renewable energy target for 2020 in the most environmentally sustainable way possible. In setting this objective, the Scottish Executive recognises the importance of applying the SEA as early in the process of policy evaluation as possible and has accordingly set down several options of general policy direction which SPP 6 could take. It is proposed that these will be subject to an initial environmental assessment in order to help select the preferred option. The preferred option will then the subject to further detailed assessment during the SEA ( see Chapter 5).
4.2 EXISTING ARRANGEMENTS ( NPPG 6)
Spatial planning for renewable energy is presently the responsibility of planning authorities to consider through the development plan process. NPPG 6 confirms that " broad areas of search may in some circumstances be helpful" and that " such an approach can provide a general guide, particularly in relation to wind energy developments, but the existence of such areas should not exclude development outwith these areas where they can be accommodated in a satisfactory manner." Planning authorities are given an alternative option of using broad criteria to guide development.
NPPG 6 also highlights how other interests, such as the natural and built heritage and local communities should be protected from " serious adverse impacts that cannot be mitigated". Although the planning framework for renewable energy is supportive, the protection given to other interests is much the same as it is for other forms of development. For example, the policies in relation to international and national natural heritage interests reflect those in NPPG 14: Natural Heritage. These other interests should be reflected in renewable energy policies in development plans and these plans can be used to " indicate whether there are areas or sites which, after appropriate assessment and wide consultation, it is judged that for overriding environmental reasons, proposals for renewable energy development would only be considered in exceptional circumstances".
In addition, whilst the policies in NPPG 6 have been successful in creating a positive climate for the industry to bring forward successful renewables energy proposals, the policies have also been criticised for not providing greater clarity on locational preferences and this has led to increasing uncertainty. Indeed, whilst a select few authorities, like Argyll and Bute, have used a criteria and/or areas of search based approach to wind farm development, many councils have either not yet prepared full local policies or have simply settled for defining broad criteria that should be taken into account when bringing forward specific planning applications. Broad areas of search are generally restricted to Structure Plans.
It is a key objective of SPP 6, therefore, to provide greater certainty to the stakeholders. The general policy direction options under consideration for SPP 6 are detailed below.
4.3 POLICY OPTIONS
4.3.1 Introduction
The Executive has identified and defined the following options for consideration as part of the SEA:
- a Status Quo;
- policies in SPP 6 supporting wider or stricter broad criteria;
- requiring planning authorities to identify areas appropriate for development;
- national locational framework;
- regional targets; and
- combination of some or all of the above.
These options are described in more detail below.
4.3.2 Option A - Status Quo
Carrying forward existing arrangements (ie business as usual) is considered likely to exacerbate criticisms that not enough is being done to guide development to the most appropriate sites. Planning authorities would continue to have the option to define only broad criteria and this could continue to lead to local uncertainties if areas of search are not defined in development plans or, indeed, if developers bring forward proposals outwith defined areas (as supported in NPPG 6). However, before dismissing this option, the impact that alternative approaches would have on the Executive's renewable targets will be considered.
4.3.3 Option B - Policies in SPP 6 supporting wider or stricter broad criteria
The situation may be improved by SPP 6 setting out stricter policies in relation to protecting other interests that should be taken into account by planning authorities when defining local broad criteria. However, as stated above, the policies in NPPG 6 already offer much the same level of protection to, for example, the natural environment as is afforded to other forms of development. SPP 6 is likely to consider, as a matter of course, whether existing levels of protection for all other interests (built and natural heritage, communities, tourism, recreation, etc) is adequately covered by existing policies. Consideration could also be given to how the existing policy principle that " the wider environmental and economic benefits ….. should be a significant consideration" should " fit" with statutory obligations to protect the natural and historic environment from inappropriate forms of development.
4.3.4 Option C - Requiring planning authorities to identify areas appropriate for development
This approach could require planning authorities to identify areas within their jurisdiction that they consider to be the most suitable for renewable energy development. Within these areas, specified criteria (including cumulative impacts) would still need to be met before a proposal was considered acceptable. When defining areas, planning authorities would be expected to steer developments to sites that minimised impacts on other interests (the natural and built heritage, local communities, tourism, etc). Outwith specified areas, developments would be looked upon less favourably although a three-tier system may be more appropriate since this would recognise that, outwith preferred area, there may be other areas that could be appropriate for developments and others that would only exceptionally be considered suitable. This approach would provide far greater certainty on where future renewable energy developments should take place although it must be recognised that constraints ( e.g. environmental) could often lead to the best sites not being available and some considerable time could pass before appropriate policies reach development plans. This may result in public and political criticism although some form of interim national locational guidance may resolve this.
4.3.5 Option D - National locational framework
The view has been expressed by many stakeholders that the Executive should set a national locational framework for renewable energy developments. Such calls relate almost entirely to existing planning arrangements for wind farms. This view is generally interpreted as the Executive identifying appropriate areas of search for wind farms throughout Scotland similar to the position adopted in Wales where the Assembly Government has mapped environmental and practical constraints to windfarm development, leading to the identification of strategic search areas.
4.3.6 Option E - Regional targets
This option would focus on setting regional targets for a predefined number of regions within Scotland, the combination of which would equate to the 6 Gigawatt ( GW) target required by 2020. Regional targets would enable planning authorities to deal more effectively with proposals in their areas on the basis that they would know how much renewable energy they would need to provide for and be able to identify land area where their contribution could be allocated. To ensure that acceptable sites are not prevented from being exploited or, alternatively, whether targets could frustrate a planning authority's ambitions to contribute beyond expectations, a three-tier system which recognises appropriate sites exist outwith "preferred" areas could be adopted (as with Option C above). This tiered approach could also be used to safeguard sites that may contribute to revised targets or to make land available once preferred areas are exploited.
When considering the issue of targets, it would be important to recognise that the proper role of the planning system is to support, not set, wider policy objectives. The UK Government's energy policy is not to set targets, limits or shares for individual energy sources. However, targets have been set for renewable energy in order to encourage production at regional, national and UK level. Great care would be required to ensure that targets were not interpreted, by planning authorities, as a maximum contribution.
4.3.7 Option F - Combination of some or all of the above
As a final option, consideration can be given to whether a combination of some, or all, of these options would lead to a preferred policy approach. The most appropriate "combination" approach would, however, be considered following full assessment of the other options and/or after discussions with stakeholders.
4.4 FACILITATING A DIVERSE RENEWABLE GENERATION PORTFOLIO
While there is a national energy policy that promotes a diverse range of renewables, there is currently no intention to specify at the national level how the 6 GW target will be met by individual renewable technologies. Theoretically, the whole target could be met by wind. However, planning authorities are already setting targets for the various renewable technologies. It is proposed that SPP 6 would ensure that planning authorities provide a range of sites for each renewable technology. To achieve this, planning authorities would need to ascertain the demand for the various technologies and provide for them accordingly, taking into account the wider social, economic and environmental issues.