Chapter Three: Comments on the General Approach and Principles
General Observations
3.1 There was overwhelming support for the production of an SPP on this topic. It was thought to be timely given the substantial current pressure to develop renewable energy sources. There were a few explicit comments to the effect that the planning system was in a key position to direct developments and also that it was important to finalize the guidance quickly.
3.2 There appeared to be a general recognition that the SPP was trying to strike a balance between promoting developments to meet renewable energy targets and protect important landscapes. There were different views about whether the document had got the balance right - respondents from the energy industry tended to consider the proposed planning regime too restrictive while voluntary bodies and individuals tended to take the opposite view.
3.3 There were some views that in trying to achieve a balance, the guidance had become "all things to all people" and that, therefore, there was a need for a clearer set of priorities in the final version. Some local authorities expressed concerns about the overall resource implications of the guidance, in particular the heavy demands it would place on staff time, the costs of procuring the necessary skills and hence increased financial burdens.
3.4 There were some suggestions that it would be helpful if the final SPP could include a Glossary of terms - the need to better define "wind farm" and "areas of search" were particularly highlighted.
Supporting Renewable Energy
3.5 This section of the SPP attracted 96 comments, the third largest number giving a good representative cross section of respondent views (see Table 3.1). Most of the respondents to the consultation supported the aim of increasing the amount of electricity from renewable energy sources. There was general support for achieving the 40% target by 2020 and the view in the document that it should not be regarded as a cap.
Table 3.1: General Views on Supporting Renewable Energy
Respondent Categories | Broadly Positive Views | Broadly Negative Views | Mixed Views and Queries | Total Responses |
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No. | % | No. | % | No. | % | No. | % |
|---|
Local Authorities | 5 | 5% | 0 | 0% | 5 | 5% | 10 | 10% |
|---|
Public Bodies | 3 | 3% | 0 | 0% | 3 | 3% | 6 | 6% |
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Businesses | 14 | 15% | 6 | 6% | 6 | 6% | 26 | 27% |
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Professional & Academic Bodies | 4 | 4% | 1 | 1% | 1 | 1% | 6 | 6% |
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Voluntary Sector | 6 | 6% | 4 | 4% | 14 | 15% | 24 | 25% |
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Public and Politicians | 4 | 4% | 14 | 15% | 6 | 6% | 24 | 25% |
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Totals | 36 | 38% | 25 | 26% | 35 | 36% | 96 | 100% |
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3.6 There were some concerns that the timescale for achieving targets was having the effect of skewing the energy market in favour of on-shore wind developments. There were, in this context, widespread views that the document was less balanced than was desirable in respect of renewable energy technologies other than on-shore wind. Some compared the Draft SPP 6 unfavourably with NPPG 6 in this respect.
3.7 There was a cluster of responses advocating a more directive and holistic national approach to energy planning. This took various forms which included calls for a Scottish Energy Strategy, which some thought could usefully include a Statement of Need, while others raised the need for a national approach which recognised an energy hierarchy giving greater emphasis to promoting energy efficiency measures and dealing more comprehensively with heat and transport issues.
3.8 There were also some views that, at a minimum, there should be a national framework with regional renewable energy targets, possibly set out in the revised National Planning Framework, which could provide a context for local authority contributions.
3.9 A relatively small number of respondents specifically welcomed the inclusion of the statement that SPP policies would apply to schemes under Section 36 of the Electricity Act 1989 and some indicated that it should be extended to cover Section 37 as well, which was concerned with the transmission grid.
Sustainable Development
3.10 There were very few comments on Paragraph 6 of the draft document but one point was made regarding the need to place greater emphasis on energy use reduction and improved building performance within an overall sustainable development strategy. It was also suggested that paragraph 6 could usefully be cross referenced to SPP1: The Planning System, SPP 3: Planning for Housing and SPP 17: Planning for Transport.
Modernising Planning
3.11 There were also few responses to Paragraph 7 of the draft document, but a local authority commented on one of the objectives of the new system - speeding up decisions - that only with properly completed planning applications, which included all the environmental and other data requested, could planning authorities determine renewable energy proposals swiftly.
SPP Principles
General Points
3.12 A quarter of all respondents to the consultation commented on this section of the document, and two-thirds of these were split evenly between businesses and voluntary sector respondents (see Table 3.2). Nearly 80% of respondents broadly supported the approach set out in paragraphs 8 and 9 of the draft SPP, although almost half of those had some queries or suggested additions and amendments. As a group, business respondents had the most reservations about the approach.
3.13 There were a cluster of responses proposing changes to the bullet points in paragraph 9 and these included the following:
- bullet point 4……….Remove "fully exploited" and replace with "fully realised", or "maximised" or add, "consistent with the Development Plan"
- bullet point 5………Add reference to the National Parks Sandford Principle on the primacy of conservation interests
- bullet point 6……….Add references to "fish and fishery interests"; "local cultural heritage" and "Designed Landscapes". There was also a suggestion that there should be a reference to "avoiding adverse impacts"
3.14 There was another group of responses suggesting that there should be a role for the National Planning Framework in the renewable energy planning process - setting strategic direction and regional targets etc. which should be highlighted here. The absence of references to the role of strategic plans was also noted by some respondents.
Table 3.2: General Views on SPP 6 Principles
Respondent Categories | Broadly Positive Views | Broadly Negative Views | Mixed Views and Queries | Total Responses |
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No. | % | No. | % | No. | % | No. | % |
|---|
Local Authorities | 3 | 5% | 0 | 0% | 3 | 5% | 6 | 11% |
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Public Bodies | 0 | 0% | 1 | 2% | 5 | 9% | 6 | 11% |
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Businesses | 7 | 12% | 7 | 12% | 5 | 9% | 19 | 33% |
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Professional & Academic Bodies | 1 | 2% | 1 | 2% | 1 | 2% | 3 | 5% |
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Voluntary Sector | 11 | 19% | 1 | 2% | 6 | 11% | 18 | 32% |
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Public and Politicians | 1 | 2% | 2 | 4% | 2 | 4% | 5 | 9% |
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Totals | 23 | 40% | 12 | 21% | 22 | 39% | 57 | 100% |
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3.15 A few respondents raised the issue of the impact of transmission networks and, while these were not approved under the Planning Acts, there were views, as mentioned earlier, that the SPP should make clear planning objectives as they related to them.
3.16 There was support for the need to keep this policy area under review and a suggestion that reference could be made to a revised PAN 45 which could be used to update the situation in respect of new technologies. There were also pleas for the annual monitoring of the implementation of new generating capacity and for a broad timetable for the review of the SPP itself.
Site Selection
3.17 Just over two thirds of respondents supported the general thrust of paragraph 10, although over half of these had queries and reservations about elements of the suggested approach. Views tended to be polarized, with 60% of all business respondents (mainly energy businesses) against the "broad areas of search" approach, while most other groups tended to be generally in favour.
3.18 Those with reservations about the approach felt it would be too crude and broad brush, given the many factors that affect commercial and environmental suitability. They felt that it was likely to encourage local authorities to be too restrictive and that regular updating would be both necessary and time consuming. They argued for a more indicative approach (there was a suggestion that the term "Areas of Wind Energy Potential" should be used) which would have greater flexibility and would leave detailed considerations to application EIAs. Amongst this group of respondents were some who felt that the site selection criteria were what was important (and should be a material consideration) and that each application should be examined on its merits against the criteria.
Table 3.3: General Views on Site Selection
Respondent Categories | Broadly Positive Views | Broadly Negative Views | Mixed Views and Queries | Total Responses |
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No. | % | No. | % | No. | % | No. | % |
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Local Authorities | 5 | 9% | 2 | 4% | 3 | 6% | 10 | 19% |
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Public Bodies | 2 | 4% | 0 | 0% | 1 | 2% | 3 | 6% |
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Businesses | 1 | 2% | 12 | 23% | 7 | 13% | 20 | 38% |
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Professional & Academic Bodies | 2 | 4% | 0 | 0% | 2 | 4% | 4 | 8% |
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Voluntary Sector | 5 | 9% | 2 | 4% | 4 | 8% | 11 | 21% |
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Public and Politicians | 1 | 2% | 1 | 2% | 3 | 6% | 5 | 9% |
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Totals | 16 | 30% | 17 | 32% | 20 | 38% | 53 | 100% |
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3.19 Various concerns were expressed about the ability of local authorities to assess the contribution of their search areas to meeting national targets. These included: the availability of appropriate skills and expertise; the quality of the data on which such assessments would be made; the need for all stakeholder "buy in" to the process; ability to judge what a "realistic" contribution might be in the absence of regional targets and the overall cost implications for local council tax payers. Local authorities themselves shared some of these concerns and one made the suggestion that the "broad areas of search" approach should only apply to large scale wind farms and that criteria-based policies should be used in all other circumstances.
3.20 Some groups of respondents, mainly from the voluntary sector and private individuals, felt that the "areas of search" approach should be tightened up. There were suggestions that there should be a presumption against development outside of the "areas of search" or that this should only be allowed where it was of, "overriding importance to the national interest" and that Scottish Ministers should give an explicit commitment to back this approach. Some concerns were expressed about the ability of local authorities to opt out of the approach in "exceptional circumstances" and wanted these more clearly defined.
3.21 Many responses highlighted the need for further guidance and this included:
- the methodology for calculating "realistic" or "reasonable" contributions for each local authority area
- the methodology/criteria for defining the "broad areas of search" which might be suitable for onshore wind farm development, as well as "no go" and "intermediate" areas
- what would constitute the "exceptional circumstances" opt out from the approach
- relevant criteria for renewables other than wind farms which might need to be factored into the approach
Local Communities and Renewable Energy
3.22 A third of all respondents commented on these paragraphs in the consultation document, with a good spread of responses across all respondent categories. There was near universal support for the need to involve local communities in all stages of the planning process and to encourage local community renewable schemes, however, there were more divergent views on the issue of Community Trust Funds and what their relevance, if any, should be to the decision-making process.
Table 3.4: General Views on Local Communities and Renewable Energy
Respondent Categories | Broadly Positive Views | Broadly Negative Views | Mixed Views and Queries | Total Responses |
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No. | % | No. | % | No. | % | No. | % |
|---|
Local Authorities | 8 | 10% | 1 | 1% | 3 | 4% | 12 | 16% |
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Public Bodies | 4 | 5% | 0 | 0% | 0 | 0% | 4 | 5% |
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Businesses | 8 | 10% | 2 | 3% | 5 | 6% | 15 | 19% |
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Professional & Academic Bodies | 3 | 4% | 2 | 3% | 3 | 4% | 8 | 10% |
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Voluntary Sector | 8 | 10% | 4 | 5% | 9 | 12% | 21 | 27% |
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Public and Politicians | 5 | 6% | 2 | 3% | 10 | 13% | 17 | 22% |
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Totals | 36 | 47% | 11 | 14% | 30 | 39% | 77 | 100% |
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3.23 Views were split on the weight that should be attached to public concern or support for renewable schemes. Some energy businesses argued for more robust assessments, not just based on numbers, recognising that there were often organised anti-wind farm campaigns. It was also suggested that the draft SPP should give examples of non-material community considerations (eg. effect on property prices) and there was an isolated view that community concerns should not be a material consideration at all.
3.24 Alternatively, a number of voluntary bodies and individuals felt community views tended to be ignored and that there was a need for them to be given greater weight. It was suggested that some recent appeal decisions relating to wind farms had undermined rather than strengthened community involvement and that the draft SPP 6 gave communities less protection than NPPG 6.
3.25 There were views across the main respondent groups that the community consultation process needed to be quality controlled and that better information and capacity building would be useful. Suggestions included: more accessible information and consistent use of language; more open and reliable techniques for gauging public views (including independent surveys); greater involvement of SNH and SEPA; ensuring all relevant views were taken into account (including a wider range of third party interests) and incorporating best practice guidelines within the SPP guidance.
3.26 With a few exceptions, the guidance in respect of the promotion of community wind farm schemes was supported, although there were several comments that this should clearly apply to other renewable energy technologies as well. Some respondents also felt it would be useful if the draft SPP defined "small scale wind farms" in terms of their generating capacity and number of turbines, and/or that there was some other definition of a "community project" (eg. meeting local needs rather than distribution to the grid). There was a view that community ownership with potential local social and economic benefits should be made a material consideration.
3.27 The main concern expressed by several respondents was the need to qualify support for community renewables with the caveat that they would have to satisfy the same tests of environmental acceptability as commercial schemes. A local authority was concerned that the SPP was unclear regarding the extent to which benefits to communities should be taken into account in determining applications and cited paragraphs 12, 13 and 61. In this context it was suggested that the finalised SPP might usefully include a model policy covering community and household renewable schemes.
3.28 The reference to Community Trust Funds ( CTFs) was the most controversial element of this section of the draft SPP. While many responses welcomed the stance set out in the draft, a small cluster of comments considered that all references to such funds should be removed from the document while an alternative group sought to make the establishment of CTFs compulsory.
3.29 There was a larger number of responses seeking clarification of various points and making further suggestions and these included:
- the need for SEDD guidance on such matters as the key parameters and scale of community contributions (£/Mw) in order to ensure a consistent approach across Scotland. A model agreement template was suggested in this context.
- the need for community capacity building to ensure that CTFs were used wisely and beneficially. There were some views that payments should be made to a central fund administered by the local authority.
- a couple of respondents referred to the document prepared by the DTI's Renewables Advisory Board, " Delivering Community Benefits from Wind Energy Development - A Toolkit", to which it was considered the finalized SPP could usefully make reference.
Economic Benefits
3.30 A majority of consultation respondents supported the approach set out in paragraphs 14 and 15 of the draft SPP, but a significant number had some concerns or sought clarification on key points. Support was concentrated amongst the business community while reservations were most prevalent amongst voluntary bodies (see Table 3.5 for details).
3.31 Many business respondents thought that the economic benefits arising from renewable projects were the most important consideration in the decision-making process and should be given greater weight. Most felt that the national economic interest should be paramount and a few thought that it should be the sole consideration, others felt that this would bias the process against smaller schemes. Some thought that the best way to increase economic impact was to consent more schemes and that SEDD should lay down stricter timetables for processing applications and enforce them. A local authority felt that the scope for locating renewable energy industries on brownfield sites should be highlighted.
Table 3.5: General Views on Economic Benefits
Respondent Categories | Broadly Positive Views | Broadly Negative Views | Mixed Views and Queries | Total Responses |
|---|
No. | % | No. | % | No. | % | No. | % |
|---|
Local Authorities | 3 | 7% | 1 | 2% | 5 | 11% | 9 | 20% |
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Public Bodies | 1 | 2% | 0 | 0% | 1 | 2% | 2 | 5% |
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Businesses | 9 | 20% | 1 | 2% | 5 | 11% | 15 | 34% |
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Professional & Academic Bodies | 1 | 2% | 0 | 0% | 0 | 0% | 1 | 2% |
|---|
Voluntary Sector | 2 | 5% | 7 | 16% | 2 | 5% | 11 | 25% |
|---|
Public and Politicians | 0 | 0% | 5 | 11% | 1 | 2% | 6 | 14% |
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Totals | 16 | 36% | 14 | 32% | 14 | 32% | 44 | 100% |
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3.32 There was an alternative body of opinion which felt that the economic case was "not proven", or that it was unlikely that onshore wind developments would have much impact on Scotland's manufacturing capacity, given that much of the technology was mature and based overseas. Some felt there was much more potential in the emerging offshore technologies (tidal and wave power) and that biomass developments could make more of an impact in rural areas.
3.33 A number of local authorities, in particular, sought further guidance regarding the weight to be afforded to local and national economic impacts, and whether it would be competent to require the local sourcing of labour and products as part of the approval process. There were some views that calculation of net economic impact should be robust and consistent and it was suggested that the Treasury Green Book methodology should be used, applied to the whole life of a project and cover supporting infrastructure and operation and maintenance activities. There was a further suggestion that EIAs should be paid for by developers but commissioned by local authorities in order to ensure greater independence and transparency.
3.34 A few respondents highlighted the fact that there were economic costs as well as benefits which should be factored into the assessment. These included the views that wind farms could have a negative impact on the tourism industry and on local house prices in some areas. Another suggestion was that negative environmental impacts on rural communities could be compensated by local economic development initiatives by wind farm developers.
Key Points
3.35 There was overwhelming support for the production of revised guidance on renewable energy. Views differed about whether the document had got the balance right between promoting developments to meet renewable energy targets and protect important landscapes. There were some views therefore that there should be a clearer set of priorities in the final version. There were strong views that in order to build public confidence and trust, a more open and participative process was required. The consultation would suggest that this is an area which requires further examination. Concerns were expressed by some local authorities about the overall resource implications of the guidance.
3.36 There was broad support for the approach embodied in the SPP Principles set out in paragraphs 8 and 9 of the document. As a group, business respondents had the most reservations about the approach. There was a group of responses suggesting that there should be a greater role for the National Planning Framework and in this policy area, as well as suggestions that PAN 45 should be updated to provide the latest available information on new renewable technologies.
3.37 Most respondents broadly supported the "broad areas of search" ( BAS) approach to site selection, although over half of these had queries and reservations about some elements. Views tended to be polarized, with 60% of all business respondents (mainly energy businesses) preferring a criteria-based approach which they considered more flexible and realistic.
3.38 There was near universal support for the need to involve local communities in all stages of the planning process and to encourage local community renewable schemes, however, there were more divergent views on the issue of Community Trust Funds and what their relevance, if any, should be to the decision-making process. Views were also split on the weight that should be attached to public concern or support for renewable schemes.
3.39 Many business respondents thought that the economic benefits arising from renewable projects were the most important consideration in the decision-making process and should be given greater weight. There was an alternative body of opinion which believed that the economic case was "not proven", or that onshore wind developments would be unlikely to have much impact on Scotland's manufacturing capacity.